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Brightline West Victor Valley, CA to Las Vegas, NV High-Speed Rail

Project Reevaluation

1.0 Introduction 

The Brightline West Victor Valley, CA to Las Vegas, NV High-Speed Rail Project (Project) consists of the 

construction and operation of a fully grade-separated, dedicated, passenger-only high-speed rail system 

along an approximately 170-mile corridor connecting Victor Valley, California to Las Vegas, Nevada.1 

In accordance with the National Environmental Policy Act (NEPA), its implementing regulations, and the 

Federal Railroad Administration (FRA) Procedures for Considering Impacts to the Environment

(Environmental Procedures), FRA began the environmental review for the Project in 2006 with the 

publication of a Notice of Intent to initiate an Environmental Impact Statement (EIS). The Project was 

originally evaluated in the following documents (collectively referenced as the DesertXpress EIS):

• March 2009 Draft Environmental Impact Statement (EIS) and 4(f) Evaluation for the proposed 

DesertXpress High-Speed Passenger Train (DesertXpress DEIS)

• April 2010 Supplemental Draft Environmental Impact Statement and 4(f) Evaluation for the proposed 

DesertXpress High-Speed Passenger Train (DesertXpress SEIS)

• March 2011 Final Environmental Impact Statement and Final Section 4(f) Evaluation for the 

Proposed DesertXpress High-Speed Passenger Train Victorville, California to Las Vegas, Nevada 

(DesertXpress FEIS)

FRA was the Lead Federal Agency for the environmental review of the Project. The Federal Highway 

Administration (FHWA), Surface Transportation Board (STB), Bureau of Land Management (BLM), and 

the National Parks Service (NPS) were Cooperating Agencies. On July 8, 2011, FRA issued the Record of 

Decision (ROD) for the Project (DesertXpress ROD). The California and Nevada Divisions of BLM issued a 

ROD for the Project on October 28, 2011, and the California and Nevada Divisions of FHWA also signed a 

ROD for the Project on November 18, 2011.

In January 2019, DesertXpress Enterprises, LLC submitted Project modifications, including a refined 

alignment between Apple Valley and Las Vegas (with a greater proportion within the Interstate 15 [I-15]

freeway median), modified station sites in Apple Valley2and the Las Vegas area, and other changes to

ancillary facilities. Based on the nature of the Project modifications, FRA determined that a reevaluation 

was appropriate.

A reevaluation is not a NEPA document as defined in the Council on Environmental Quality (CEQ)

regulations and is not required to undergo public review. Reevaluations are instead used to document 

an agency’s decision whether a supplemental EIS is required.

In February 2019, FRA initiated a Reevaluation of the DesertXpress FEIS and DesertXpress ROD. FRA in 

cooperation with BLM, STB, FHWA, and the US Army Corps of Engineers (USACE), with the added 

participation of the California Department of Transportation (Caltrans) and the Nevada Department of 

1 The Brightline West Project was initially proposed by DesertXpress Enterprises, LLC, and was previously called the 

DesertXpress Project, and then later as the XpressWest Project. DesertXpress Enterprises, LLC, which is the Project Sponsor,

also previously did business as XpressWest.

2

 Although the modified Project would relocate the Victor Valley Passenger Station platforms (the modified Dale Evans Station) 

to within the Town of Apple Valley, it would serve the purpose of the original Victorville Passenger Stations considered in the 

DesertXpress EIS.
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Transportation (NDOT), analyzed whether changes in the environmental setting due to the passage of 

time or the Project modifications would result in new significant environmental impacts. Concurrently 

with the preparation of the Reevaluation, FRA informally consulted with the United State Fish and 

Wildlife Service (USFWS) pursuant to Section 7 of the Endangered Species Act. Additionally, FRA has

worked with the following Consulting Parties in accordance with Section 106 of the National Historic 

Preservation Act (Section 106)3:

• Advisory Council on Historic Preservation (ACHP)

• California and Nevada State Historic Preservation Officers

• Federally recognized Native American tribes with an interest in the Project area

• Federal agencies (BLM, STB, FHWA, and USACE, Federal Aviation Administration, NPS)

• Interested parties (Clark County Department of Aviation, Old Spanish Trail Association)

• Nevada Department of Transportation (NDOT)

• California Department of Transportation (Caltrans)

In September 2020, FRA determined the Project modifications would result in similar impacts to those 

evaluated in the DesertXpress FEIS, and concluded the Project modifications would reduce the overall 

impacts from the proposed action. Based on the analysis and findings, FRA found that the Project 

modifications do not constitute changes in the proposed action that would result in significant 

environmental impacts that were not evaluated in the DesertXpress FEIS.

4

In 2022, DesertXpress Enterprises, LLC proposed additional Project modifications (described below in 

Section 2.0). FRA determined it was appropriate to conduct a second Reevaluation to consider the 

potential impacts of the additional Project modifications, and initiated this Reevaluation in February 

2022. Based on Project modifications, anticipated permits and licenses needed for construction and 

operation of the Project (identified in Table 1 below), FRA invited the participation of the Cooperating 

Agencies and other agencies previously involved in the NEPA process and continue to have a permit or 

authorization to participate in the reevaluation process. These agencies include: 

• FHWA – California and Nevada Divisions

• BLM – Barstow, Needles, and Las Vegas Field Offices

• STB

• US Army Corps of Engineers (USACE) – Los Angeles District

• USFWS

Specific roles and responsibilities of each Federal agency, including permitting agencies, are further 

described below.

Table 1: Federal Permits or Approvals 

Agency Permit or Approval

Federal Railroad Administration Regulations related to high-speed train operation and safety

Bureau of Land Management Right-of-Way (ROW)

3 The National Park Service (NPS) is no longer a consulting party under Section 106 with the removal of Segment 4A which 

would have traversed a portion of the Mojave National Preserve. The current project design and footprint avoids all NPS 

lands.

4 The September 2020 Reevaluation document and attachments are available at: 

https://railroads.dot.gov/environment/environmental-reviews/desertxpress-xpresswest-las-vegas-victorville. 
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Agency Permit or Approval 

SEPTEMBER 2023 PAGE 3

Federal Highway Administration

• Concurrence for Highway ROW Occupancy and/or Disposal 

• Approving Access Justification Report or Access Modification Report 

• Concurrence on Project Design Elements Related to Highway Operations 

Surface Transportation Board Authority to Construct and Operate Railroad

U.S. Army Corps of Engineers 

• Section 404 Permit (waters of the United States) 

• Section 401 Certification

U.S. Fish and Wildlife Service Section 7 Biological Opinion 

Federal Aviation Administration 14 Code of Federal Regulations Part 77 and Part 157*

* Although not a Federal action, this regulation requires the Federal Aviation Administration to opine on the Project’s impact on the safe and 

efficient use of navigable airspace.

FRA held Cooperating Agency meetings to review the Project modifications as well as solicit input on the 

NEPA reevaluation process and any information pertinent to Cooperating Agencies’ areas of jurisdiction. 

NDOT, Caltrans, and Federal Aviation Administration have not been designated as Cooperating Agencies, 

but these agencies participate in the Cooperating Agency meetings because project modifications place 

the rail alignment within the NDOT and Caltrans rights-of-way (ROW).

Based on the findings of this Reevaluation, FRA determines the Project modifications would not result in 

substantial changes in the evaluation of impacts described in the DesertXpress EIS. Therefore, a 

supplemental EIS is not required for the Project modifications.

This Reevaluation summarizes modifications to Project scope, design, affected environment, impacts, 

mitigation, and other applicable requirements since publication of the 2011 DesertXpress EIS, 

DesertXpress ROD, and September 2020 Reevaluation, and assesses whether the environmental impacts 

or mitigation are different from those previously analyzed in the DesertXpress EIS. This document relies 

on the following Attachments, listed below and incorporated by reference:

• Attachment A: Summary of Project Modifications

• Attachment B: USFWS Concurrence Letter, September 1, 2023

• Attachment C: Biological Resources Technical Report

• Attachment D: Mitigation Measure Summary

2.0 Project Modifications Since the September 2020 Reevaluation

Since 2020, the project sponsor has proposed modifications to the Project, developed through the final 

design phase. These modifications are described in Table 2-1 below. 
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Table 2-1 Project Modifications (Since the September 2020 Reevaluation) 

Project Feature Description of Modification(s)

Alignment

Segment 1 Alignment (Apple 

Valley to Lenwood)

The Project modifications involve relocating the rail alignment between the 

Victor Valley Station and Sidewinder Road from east side of the I-15 freeway to 

the median. As such, the entirety of the Segment 1 rail alignment is now within 

the I-15 freeway median, which would result in reduced impacts and increase the 

efficiency of train operations. This design change is also favorable with Caltrans 

and FHWA as it would improve constructability of potential future I-15 freeway 

improvements in either the northbound or southbound directions.

Additionally, the Segment 1 rail alignment would be extended less than one mile 

south of the Victor Valley Station to access a maintenance of way track that will 

be constructed to move equipment from the median rail mainline to the 

maintenance of way facility. Construction of a median-running rail alignment in 

this area, south of the Dale Evans Parkway intersection, would require 

realignment of the existing I-15 northbound travel lanes approximately 50 feet 

east, and reconstruction of the Dale Evans Parkway interchange including the 

overpass.5 This is discussed further under the Victor Valley Station description 

below. Additionally, the I-15 northbound travel lanes would be elevated 

approximately 25 feet south of the interchange to allow the maintenance of way 

track to pass from the median to the maintenance of way facility. All roadway 

work would occur within existing Caltrans/NDOT ROW.

Segment 5 Alignment 

(Primm to Sloan Road)

Project modifications would relocate the rail alignment, between Primm and 

north of Goodsprings Road near Jean, from the east side of the I-15 freeway to 

the freeway median. As such, the entirety of the Segment 5 rail alignment is now 

located within the I-15 freeway median, which would result in reduced impacts, 

increase the safety and efficiency of train operations, and improve 

constructability for future I-15 widening in this portion of the alignment. 

Additionally, the previously considered Braid Structures near Primm and the 

Union Pacific Railroad (UPRR) crossing are no longer needed and have been 

removed.

5 This Reevaluation has assumed full reconstruction and replacement of the overpass. Caltrans will determine the necessary 

modifications to the I-15/Dale Evans interchange which may not include full reconstruction and replacement of the overpass. 
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Project Feature Description of Modification(s) 

Stations

Victor Valley Station

(previously referred to as 

Dale Evans Station)

The Project design evaluated in September 2020 considered collocating an 

operations, maintenance, and storage facility (OMSF) with the Victor Valley

Station, with a permanent footprint of approximately 300 acres. As discussed 

below, the current Project modifications include a relocation of the Vehicle 

Maintenance Facility (VMF) to a site on the west side of I-15 in Sloan.

The Victor Valley Station permanent footprint would remain unchanged. As 

noted above, under Segment 1, the Project Modifications include relocating the 

rail alignment into the median of the I-15 freeway. To accommodate this new rail

alignment, the Victor Valley Station layout has been revised to include the 

passenger boarding and alighting platforms in the median of the I-15 freeway. In 

order to provide the necessary footprint and access for these platforms, the 

existing I-15 northbound lanes would be raised and moved east within the 

Caltrans ROW south of the Dale Evans Parkway interchange. Passengers would 

access station platforms using a walkway underneath the relocated I-15 freeway 

northbound lanes.

Mainline Ancillary Features

Highway Ramp 

Realignments/Modifications

The Project design evaluated in September 2020 included realignment of 

portions of approximately 17 existing freeway on and off- ramps to 

accommodate the rail line within the I-15 freeway ROW. The current Project 

modifications include extending these on and off ramp realignments and ramp 

modifications, and changing the location where these ramp 

realignment/reconstructions transition to the existing roadway/pavement. There 

are locations where these proposed freeway ramp modifications occur (from 

south to north):

• The I-15 southbound ramps at Dale Evans Parkway

• The I-15 northbound ramps at Main Street in Barstow

• The I-15 northbound ramps and southbound ramps at East Primm 

Boulevard

• The I-15 southbound ramps at Goodsprings Road

• The I-15 southbound ramps at Sloan Road

These modifications would be located primarily on previously evaluated Project 

footprint within existing Caltrans/NDOT, and local ROW along the I-15 freeway. 

These modifications are the result of coordination with Caltrans and NDOT on 

final design details, in order to update the modified median-running alignment to 

adhere to current safety design standards. 

California Highway Patrol 

(CHP) Emergency Crossovers

The Project design evaluated in September 2020 included eight emergency 

crossovers along the alignment in California. The current Project modifications 

include two new emergency crossovers at Zzyzx Road and Halloran Springs. 

Additionally, five previously evaluated emergency crossovers in Segment 3 would 

be relocated. These are located near Coyote Lake Road, Basin Road, Baker, and 

both north and south of Halloran Springs. Emergency crossovers would be 

located mainly on previously evaluated Project footprint within the existing 

Caltrans ROW.

In total, the modified Project would include 10 emergency crossovers in 

California, located in Segment 3 between Yermo and Mountain Pass, and one 

emergency crossover in Nevada approximately 1.5-miles south of Sloan.
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Project Feature Description of Modification(s) 

Roadwork

The Project design evaluated in September 2020 included roadwork at local 

interchanges and along the I-15 freeway at various locations. The current Project 

modifications include:

• Realigning the I-15 freeway northbound lane approximately 50 feet east 

and raising the lane approximately 25 feet, to accommodate the 

passenger platforms in the I-15 median, tail track for train storage, a 

pedestrian underpass for access to/from the platforms, and a 

maintenance of way access track for trains. These roadwork 

improvements would occur along a 60-foot portion of the I-15 freeway 

northbound lane adjacent to the Victor Valley Station.

• Additional roadwork at the Dale Evans Parkway interchange accessing 

the I-15 freeway southbound ramps.

• I-15 freeway median widening at Segment 5 to accommodate the 

modified median-running alignment.

• Raising of I-15 southbound lanes just south of the Sloan Road 

interchange to allow for tracks to exit the I-15 median under the 

southbound lanes and into the Sloan VMF site.

The Project modifications also include small, on-road lane realignments along the 

I-15 freeway at Segment 6, near Silverado Ranch Boulevard and Blue Diamond 

Road.

Culverts

The Project design evaluated in September 2020 included drainage and culvert 

work throughout the Project limits. The current Project modifications include 

revised designs for three culverts and the addition of four culverts within 

Segment 5. The associated drainage and grading activities have also been 

modified accordingly.

Cemex Facility and Rail 

Connection

A new connection to the existing Cemex industrial rail track is proposed on the 

north side of Apple Valley, CA near the proposed Victor Valley Station. The 

connection would consist of a turnout off the existing Cemex track and 

approximately 2 miles of new track along the east side of I-15 freeway heading 

north, all within the Caltrans ROW limit. 

This connection would allow rail transportation of construction materials such as 

track ballast to the Project area. This reduces the need for trucking construction 

materials to the Project area.

Ivanpah Traction Power 

Substation (TPSS)

The Ivanpah modified TPSS 3-mile utility line and 3.5-mile redundant utility line 

would travel north of the existing solar field to connect to a Southern California 

Edison (SCE) substation adjacent to the BrightSource Ivanpah Electrical 

Generating System, west of the I-15 freeway, resulting in the reduction of 

approximately 0.18 acres of permanent footprint. These modifications are the 

result of coordination with SCE, BLM and USFWS.

California Maintenance of 

Way (MOW) Facility

The Project design evaluated in September 2020 considered the relocation of the 

California MOW Facility from Baker, California, to the I-15 freeway median 

approximately six miles south of the California/Nevada state line, adjacent to the 

existing California Agricultural Inspection Station (CAIS). The 25-acre facility was 

proposed to be utilized for passive equipment storage.

The MOW is no longer located adjacent to the CAIS and will be divided between 

the new site at Sloan and the Victor Valley Station area.
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Project Feature Description of Modification(s) 

Sloan Vehicle Maintenance 

Facility (VMF)

The Project design evaluated in the DesertXpress EIS included an OMSF in close 

proximity to the original Victorville Station west of the I-15 freeway, and included 

facilities for maintaining and storing trains. Project modifications evaluated in 

2020 included relocating the Victorville Station to the south side of the I-15 

freeway at Dale Evans Parkway in Apple Valley. At that time, it was proposed the 

OMSF would be collocated with the Victorville Station, and a separate location 

for vehicle maintenance and storage had not been identified. 

The current Project modifications include locating the vehicle maintenance and 

storage activities at a site located in Segment 6 west of and within 1.5 miles of 

the I-15 freeway, and south of Sloan Road; the Victor Valley Station permanent 

footprint would remain unchanged. An additional freight track corridor will be 

constructed to connect the VMF to the adjacent UPRR.

▪ Brightline West have filed a connection request and are coordinating with 

UPRR regarding the connection design and operational concepts. UPRR have 

granted preliminary approval of this rail connection, which would be subject 

to additional design development.

The Sloan VMF and adjacent UPRR connection would require 246 acres of 

permanent footprint and 105 acres of temporary footprint,6 and includes:

▪ Storage and staging tracks and overhead catenary system from which trains 

would be mobilized for daily operations.

▪ Equipment and operations associated with the Sloan VMF, including but not 

limited to a train car wash station, a train performance monitoring station, 

an Operations Control Center, a power substation and distribution lines, 

utility connections, circulation system, site control, fencing, and parking.

The Sloan VMF will be a permanent workplace for approximately 100 employees 

related to either the maintenance of the Brightline West train fleet or performing 

other functions such as driving the trains. These facilities would be located on 

land under BLM jurisdiction and would therefore require a ROW grant lease from 

BLM. 

Temporary Construction Areas (TCAs)

TCAs are areas that would be utilized for construction staging and storage. No permanent project features would 

be installed in these areas, and they would be restored/vacated upon completion of construction. The modified 

Project includes an additional 202 TCAs located within Caltrans/NDOT ROW along the I-15 freeway corridor for 

construction of the rail alignment. These are in addition to TCAs previously identified in the original project 

description and the September 2020 Reevaluation. The majority of these additional TCAs are areas located within 

the existing I-15 freeway ROW. The addition of these TCAs adds 1,492 acres of temporary footprint to the 

project.

7 The Sloan VMF facility footprint includes 105 acres of temporary footprint required for constructing the 

Sloan VMF and UPRR Connection. 

6 While the Sloan VMF would require additional permanent and temporary footprint, the overall modified Project footprint 

would not be significantly larger than the original Project footprint or the footprint evaluated in the September 2020 

Reevaluation, because of footprint reductions in other areas.

7 As more of the alignment has been shifted to be within the I-15 freeway median, additional TCAs are proposed since room for 

construction within the I-15 freeway median is more limited and needs to be spread out throughout the alignment. 
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3.0 Methodology

In analyzing the potential environmental effects of the proposed Project modifications, FRA considered 

whether the proposed Project modifications, including the newly proposed Sloan VMF, could result in 

substantial changes to resource topics evaluated in the 2011 DesertXpress EIS and the September 2020 

Reevaluation. This allowed FRA to assess whether there are substantial changes in the proposed action 

relevant to environmental concerns that would require FRA to prepare a supplemental EIS, consistent 

with FRA’s environmental procedures and 40 CFR § 1502.9I.

Section 4.0 includes the environmental analysis for modifications to the alignment, mainline ancillary 

facilities, and TCAs, as these features are similar in nature and primarily occur along and within the 

existing I-15 freeway ROW. Section 5.0 includes a separate analysis for the Sloan VMF. The analysis of 

impacts for the Sloan VMF is separated to facilitate BLM’s review, as the Sloan VMF is proposed on land 

owned and managed by BLM. FRA’s determination as to whether a supplemental EIS is required

considers the evaluation of all Project modifications listed, including the Sloan VMF.

Regulatory Updates. This category includes new laws, regulations, or policies enacted since the

DesertXpress EIS and September 2020 Reevaluation. Federal, state, and local regulatory updates that 

took place after July 2011 were evaluated to determine applicability to the modified Project. The 2011 

DesertXpress EIS noted that the Project is exempt from the California Environmental Quality Act (CEQA) 

and other state and local land use and environmental regulations, consistent with the Surface 

Transportation Board’s (STB) 2007 declaratory order.

8 Nevertheless, state and local land use and 

environmental regulations were considered in the discussion of resource topics below, consistent with 

the DesertXpress EIS approach which evaluated state and local regulations.

This category also identifies changes in the existing physical environment that have occurred, if any,

since the DesertXpress EIS and September 2020 Reevaluation. The affected environment was assessed 

for each resource topic to identify changes in the resource or features within the Project area. Changes 

in the affected environment are cited, summarized, and evaluated against the Project to determine if 

new significant impacts would occur.

Effects Analysis. This category identifies whether the Project modifications that have occurred since 

issuance of the DesertXpress ROD and September 2020 Reevaluation would result in substantial changes

in impacts from those disclosed in the September 2020 Reevaluation or 2011 DesertXpress EIS. 

Mitigation Measures. This category identifies and addresses the applicability of mitigation measures 

originally established in the DesertXpress EIS, revised in the September 2020 Reevaluation and, where 

applicable, identifies new or revised measures.

4.0 Environmental Consequences: Alignment, Mainline Ancillary 

Features, and Temporary Construction Areas

This section evaluates whether the mainline Project modifications described in Table 2-1 above, except 

for the Sloan VMF, would result in substantial changes to the evaluation of effects established in the 

8 49 U.S.C. § 10901 grants STB exclusive jurisdiction over the construction and operation of interstate railroad projects. STB’s 

declaratory order found that the Project falls under STB’s jurisdiction because the Project alignment would connect California 

and Nevada. https://www.stb.gov/decisions/readingroom.nsf/UNID/0CEC0B2F00B4E90D85257306006C9F38/$file/37656.pdf 
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DesertXpress EIS and September 2020 Reevaluation. Evaluation of the Sloan VMF is provided in Section 

5.0 below. 

To determine whether Project modifications would result in substantial changes to the evaluation of 

environmental impacts described in the DesertXpress EIS, FRA reassessed each of the resources 

analyzed in the DesertXpress EIS based on a 15-percent design for the Project modifications. The 15-

percent design results in a conservative estimate of the modified Project footprint and, therefore, the 

analysis in this Reevaluation conservatively estimates the modified Project impacts. Key design 

refinements from the current project design are evaluated in this Reevaluation to provide a 

comprehensive environmental analysis.

FRA determined that because Project modifications relative to alignment, ancillary facilities and TCAs

are minor in nature and predominately occur within the active I-15 freeway ROW, desktop/qualitative 

evaluation was appropriate for the following environmental topics: land use, community, and 

environmental justice; growth; farmlands and grazing lands; utilities/emergency services; traffic and 

transportation; visual resources; hydrology and water quality; geology and soils; paleontological 

resources; hazardous materials; air quality and global climate change; noise and vibration; energy; and 

cumulative impacts for all resource topics. Changes to the affected environment for these resources 

would be unlikely to occur or were easily assessed using publicly available resources.

More detailed evaluations were conducted relative to cultural resources and biological resources and 

documented in technical reports/memoranda. 

Mitigation measures were evaluated for each resource topic to determine if new or modified mitigation 

measures would be required to address the modified Project’s environmental impacts as discussed in 

Section 6.0, Changes in Mitigation Measures.

4.1 LAND USE, COMMUNITY, AND ENVIRONMENTAL JUSTICE

This section evaluates whether the Project modifications would result in substantial changes to the 

evaluation of effects to land use, community, and environmental justice discussed in the DesertXpress 

EIS and September 2020 Reevaluation. As previously established in the September 2020 Reevaluation, 

the September 2020 Project modifications did not result in substantial changes to the evaluation of land 

use, community, and environment justice impacts disclosed in the DesertXpress EIS.

The evaluation of land use, community, and environmental justice impacts to support this Reevaluation 

considered changes to the Project footprint, existing land uses, community demographics, and local land 

use designations. Consistent with the analysis in the DesertXpress EIS and September 2020 

Reevaluation, local land use designations were considered even though the Project would be exempt 

from local land use regulations.9

9 STB issued a declaratory order on June 25, 2007, regarding STB's authority under 49 U.S.C. 10901. In general, STB has exclusive 

jurisdiction over construction and operation of interstate railroads. STB’s declaratory order determined that the Project falls 

under STB’s jurisdiction because the Project alignment would connect California and Nevada. Under STB’s jurisdiction, the 

Project would be exempt from state and local land use and environmental requirements.
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4.1.1 REGULATORY UPDATES

FEDERAL

The DesertXpress EIS and September 2020 Reevaluation identified Federal agencies with authority over 

land uses within two miles of the Project. The DesertXpress EIS and September 2020 Reevaluation 

assumed the Project would not impact land uses beyond this distance. As the modified Project would 

pass within 1 mile of lands operated by the following Federal agencies, the following land use 

regulations would still apply: 

▪ BLM: Ancillary facility footprint would occur on lands managed by the BLM.

▪ The US Department of Defense: Segment 2 would be within 1 mile of the US Marine Corps logistics 

base in Yermo.

▪ The National Park Service: Segments 3 and 4 would pass within 1 mile of the Mojave National 

Preserve, a preserve managed by the National Park Service. 

▪ Federal Aviation Administration: The Project would be within 1 mile of the proposed Ivanpah Valley 

Airport and the existing Jean Sport Aviation Center.

The Project modifications could potentially conflict with land use policies of the above agencies through 

the use of lands owned by these agencies or through interference with existing land uses where the 

modified Project is adjacent to these lands. The Project modifications would result in the use of land 

managed by BLM in areas where the Project features occur outside of the I-15 freeway ROW along 

Segments 3, 4, 5, and 6. The modified Project facilities would not directly encounter the lands of other 

Federal agencies. As discussed in Section 4.1.3, Conflict with Land Use Plans, Policies, or Regulations, 

mitigation measures would be applied to avoid or reduce any potential conflict with planned uses at 

these locations. 

Desert Renewable Energy Conservation Plan

The Desert Renewable Conservation Plan (DRECP) encompasses 22.5 million acres in the desert regions 

and adjacent lands of seven counties within southern California, including San Bernardino County. The 

DRECP focuses on streamlining renewable energy development and conserving unique and valuable 

desert ecosystems. BLM signed the DRECP Land Use Plan Amendment (LUPA) Record of Decision in 

September 2016, which covers 9.8 million acres of land under BLM management within the total 22.5 

million-acre DRECP plan area. The DRECP LUPA was not assessed in the 2011 DesertXpress EIS but was 

evaluated in the September 2020 Reevaluation for potential conflicts that could result from 

implementation of the Project. 

No updates to the plan have occurred since the September 2020 Reevaluation that would pertain to the 

Project. The BLM would maintain jurisdiction over areas of the Project that cross public land managed 

by BLM and other facilities authorized on such lands. The Project construction and operation within land 

under BLM management would continue to be subject to resource-specific goals, objectives, and 

Conservation and Management Actions (CMAs) outlined within the LUPA. The modified Project would 

be required to address relevant CMAs on parcels of land under BLM management covered by the DRECP 

throughout portions of the Project area in California. TCAs would be located primarily in the Caltrans 

and NDOT ROWs and would be restored/vacated after construction. Additionally, Mitigation Measure 

LU-3 was developed in the September 2020 Reevaluation to ensure compliance with applicable goals, 
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policies, and CMAs in areas where the modified Project would traverse land managed by BLM protected 

by the DRECP.

STATE AND LOCAL

No updates to California regulations governing land use have occurred since the September 2020 

Reevaluation that would pertain to the Project.

Land use designations have been updated within Nevada, as the Clark County Master Plan was updated 

in November 2021 (refer to the discussion of Conflicts with Land Use Plans, Policies, and Regulations in 

Section 4.1.3, Project Modifications).

10 While land designations have changed in Clark County with the 

update to the Master Plan, the mainline Project modifications do not involve any land outside the 

existing I-15 NDOT freeway ROW (refer to Section 5.1.1 for further discussion of land use designations 

under the Clark County Master Plan at the Sloan VMF site).

As the Project still includes land in both California and Nevada, the California Department of 

Transportation, Nevada Department of Transportation and the BLM would have the same authority over

the Project related to facilities located within their area’s of jurisdiction as described in the DesertXpress 

EIS and September 2020 Reevaluation.

Clark County Conservation of Public Land and Natural Resources Act of 2002

The Project would be subject to the Clark County Conservation of Public Land and Natural Resources Act 

of 2002. The September 2020 Reevaluation established Segments 5 and 6 would intersect with a 2,640-

foot-wide corridor designated by this Act for transportation uses and supporting infrastructure between 

the proposed Ivanpah Valley Airport and the City of Las Vegas. The exact boundaries of this corridor 

have not been defined; however, it is anticipated to parallel the east side of the I-15 freeway.

11 The 

modified Project would avoid effects identified in the September 2020 Reevaluation, since the modified 

alignment south of Jean, Nevada has been relocated from the east side of the I-15 freeway into the I-15 

freeway median. In addition, the Project consists of the uses the Act permits: transportation uses and 

associated infrastructure and would therefore not result in land use conflicts under this Act. The Project 

modifications would not result in substantial changes in the evaluation of land use impacts of the 

DesertXpress EIS or September 2020 Reevaluation. 

4.1.2 EFFECTS ANALYSIS

RESIDENTIAL AND BUSINESS DISPLACEMENTS

The former station site identified in the DesertXpress EIS would have required displacement of several 

existing businesses. The proposed Victor Valley Station and Warm Springs Station footprints have not 

changed since the September 2020 Reevaluation; none of the project modifications would result in 

residential or business displacements because they occur predominantly within the I-15 ROW or on 

undeveloped land immediately adjacent to the freeway. Consistent with the September 2020 

10 Clark County, Nevada. 2021. Clark County Master Plan. Available: 

https://www.clarkcountynv.gov/government/departments/comprehensive_planning_department/divisions/advanced_planni

ng_division/comprehensive_master_plan.php. Accessed: April 2022.

11 Bureau of Land Management. 2019. Ivanpah Solar Electric Generating System Final Environmental Impact Statement. 

Available: https://www.energy.gov/sites/prod/files/nepapub/nepa_documents/RedDont/EIS-0416-FEIS-2010.pdf. Accessed: 

April 2022.
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Reevaluation, the Project modifications would reduce residential and business displacement impacts as 

compared to the DesertXpress EIS or September 2020 Reevaluation. 

DIVISION OF AN ESTABLISHED COMMUNITY 

The DesertXpress EIS and September 2020 Reevaluation acknowledged that linear transportation 

projects can divide established communities. However, the Project would not create new physical

divisions because Project facilities would be constructed within or immediately adjacent to existing 

transportation and utility corridors. The modified rail alignment would be primarily constructed within 

the I-15 freeway ROW. Mainline ancillary features such as the Cemex rail connection and Ivanpah 

electrical substation would be located adjacent to the I-15 freeway. As such, the Project modifications 

would not result in substantial changes in the evaluation of community division impacts of the 

DesertXpress EIS or September 2020 Reevaluation. 

INTERFERENCE WITH NORMAL FUNCTIONING OF ADJACENT LAND USES

The DesertXpress EIS and September 2020 Reevaluation assessed the Project’s compatibility with 

adjacent land uses to determine if Project construction or operation would interfere with normal 

functioning of these land uses. The modified Project alignment would be placed within the I-15 freeway 

ROW to greatly reduce conflicts with non-transportation land uses outside of the I-15 freeway ROW. 

As described in Table 2-1, alignment modifications to the Project include modifications to the Segment 1

alignment from Apple Valley to Lenwood, and the Segment 5 alignment from Primm to Sloan Road. Land 

use designations along the alignment include Public Facility, Commercial, Resource/Land Management, 

Mixed-Use, Neighborhood, Business, and Open Lands in San Bernardino County.

12 In Clark County, land 

use designations along the alignment include Entertainment, Neighborhood, Public Use, Business 

Employment, and Neighborhood Commercial land uses.13 However, the alignment modifications 

mentioned above would result in the entirety of the rail alignment in Segment 1 and Segment 5 being

within the I-15 freeway median, resulting in fewer effects to existing adjacent land uses in these areas. 

Likewise, mainline ancillary feature modifications including highway ramp realignments, CHP emergency 

crossover upgrades, additional roadwork at the Dale Evans Parkway roundabout, I-15 freeway median 

widening, culvert additions at Segment 5, and additional Cemex rail connections would be primarily 

located within or along the I-15 freeway ROW to greatly reduce conflicts with non-transportation land 

uses outside of the I-15 freeway ROW. However, other mainline ancillary feature modifications including 

emergency crossovers could result in new or previously identified footprint impacts outside of the I-15 

freeway ROW. Conflicting land use impacts and connected mitigation measures for these facilities are 

further described in the Conflicts with Land Use Plans, Policies, and Regulations discussion, and Conflicts 

with Airport Land Uses discussion below. 

The DesertXpress EIS and September 2020 Reevaluation concluded the Project would not negatively 

impact adjacent land uses through incorporation of mitigation measures pertaining to utilities and 

emergency services, visual resources, transportation, air quality, and noise. The Project modifications 

would not change the DesertXpress EIS or September 2020 Reevaluation conclusions regarding impacts 

12 San Bernardino County. 2020. LU-1 Land Use Map. 

https://www.arcgis.com/apps/webappviewer/index.html?id=f23f04b0f7ac42e987099444b2f46bc2. Accessed: April 2022. 

13 Clark County. 2021. South County Planned Land Use Maps. 

https://www.clarkcountynv.gov/government/departments/comprehensive_planning_department/library/maps.php#outer8513sub-8529. Accessed: April 2022. 
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on adjacent land uses, because the modified Project would still be primarily located within the I-15 

freeway corridor. As such, the mitigation measures identified in the DesertXpress EIS and September 

2020 Reevaluation that would avoid or minimize negative impacts to adjacent land uses would still apply 

to the modified Project. Therefore, the Project modifications would not result in substantial changes in 

the evaluation of impacts on the normal functioning of adjacent land uses of the DesertXpress EIS or 

September 2020 Reevaluation. 

CONFLICT WITH LAND USE PLANS, POLICIES, AND REGULATIONS

The footprints for the proposed station sites have not changed since the September 2020 Reevaluation 

and would therefore not change the previous evaluations’ conclusions regarding land use conflicts. The 

DesertXpress EIS and September 2020 Reevaluation concluded that the Project would be highly 

compatible with transportation land use designations along the I-15 freeway corridor. Because the 

modified alignment would be within the I-15 freeway ROW, the alignment would not result in any 

conflicts with applicable land use plans. The majority of the Project modifications to mainline ancillary 

features would occur within or adjacent to the I-15 freeway ROW and would therefore not conflict with 

existing land use policies, with the exception of the Barstow electrical substation and Ivanpah electrical 

substation. However, both the Barstow and Ivanpah electrical substations would occur within the same 

location as analyzed in the September 2020 Reevaluation, and modifications to the Ivanpah electrical 

substation would result in the reduction of approximately 0.18 acres of permanent impact. The Project 

modifications to ancillary features would therefore not change the DesertXpress EIS or September 2020 

Reevaluation conclusions regarding land use conflicts. 

Table 4-1 compares the compatibility of land use designations encountered by each ancillary facility 

outside of the I-15 freeway ROW to the compatibility of land use designations identified by the 

DesertXpress EIS for these features. Modified Project facilities are classified using the same 

methodology applied as the previous evaluations, each having high, low, or medium compatibility with 

existing land uses or a combination of these three categories where the Project encounters multiple 

land use designations. 

Project modifications, overall, would reduce potential conflicts with applicable land use plans as 

compared to the original DesertXpress EIS. As identified in the September 2020 Reevaluation, Project 

utility corridors and the placement of the alignment would be located within or directly adjacent to the 

I-15 freeway ROW and would avoid substantial land use conflicts identified in the DesertXpress EIS.

Therefore, the Project modifications would not result in substantial changes in the evaluation of land 

use plan, policy, or regulation impacts of the DesertXpress EIS of September 2020 Reevaluation. 
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Table 4-1 Compatibility with Designated Land Use

Segment/ 

Project 

Feature

Modified Project 

Footprint

September 2020 

Reevaluation Land Use 

Designation

September 2020 

Reevaluation 

Compatibility with Land 

Uses

Current Land Use 

Designation

2023 Reevaluation 

Project Compatibility 

with Current Land Uses

Segment 1

Cemex Rail Connection N/A N/A Resource/Land 

Management High

Segment 2 

Barstow Electrical 

Substation,

Temporary 

Construction Areas

Resource Conservation 

Open Space Low Resource Conservation Open Space Low

Segment 2 Temporary 

Construction Areas

Resource/Land 

Management, Commercial Low-High Resource/Land Management, Commercial Low-High

Segment 3 

Temporary 

Construction Areas, 

Emergency Crossovers

General Commercial, 

General Industrial, Diverse 

Use, Public Quasi Public, 

Resource/Land 

Management

Low-High

General Commercial, 

General Industrial, Diverse 

Use, Public Quasi Public, 

Resource/Land 

Management

Low-High

Segment 4 

Ivanpah Electrical 

Substation,

Temporary 

Construction Areas

Resource/Land 

Management Low Resource/Land Management Medium

Segment 5 Temporary 

Construction Areas

Public Facilities, Open 

Lands, Commercial tourist Low-High

Corridor Mixed-Use, 

Neighborhood 

Commercial, Open Lands

Low-High

Segment 6 Temporary 

Construction Areas Commercial Tourist Medium

Business Employment, 

Open Lands, 

Entertainment Mixed Use

Medium

N/A = Not Applicable
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CONFLICTS WITH AIRPORT LAND USES

The September 2020 Reevaluation identified the closest airport to the Project in Apple Valley is the 

Osborne Private Airport, approximately four miles southwest of the Victor Valley Station and OMSF site. 

The September 2020 Reevaluation established that a station site at this location would not create a new 

conflict with this airport. The Victor Valley Station footprint has not changed since the September 2020 

Reevaluation. The Cemex rail connection is located approximately 2.5 miles from the Osborne Private 

Airport. 

The rail alignment would pass in the vicinity of Jean Sport Aviation Center, which is located east of the 

I-15 freeway in Segment 5. The DesertXpress EIS concluded that the Project would not conflict with this 

airport because the alignment would parallel its runways. Paralleling the runways would prevent Project 

facilities, such as overhead catenary lines, from interfering with airport operations. The modified 

alignment would be relocated from east of the I-15 freeway into the I-15 freeway median at this 

location. Thus, the Project modifications would not conflict with the operation of Jean Sport Aviation 

center.

Regarding the planned Ivanpah Valley Airport, the rail alignment would pass near lands designated for 

future construction of the Airport south of the Jean Sport Aviation Center in Segment 5. Clark County 

plans on constructing the proposed Ivanpah Valley Airport along the eastern side of the I-15 freeway

between Primm and Jean in Nevada.14 The modified Project would relocate the rail alignment from the 

east side of the I-15 freeway to the I-15 freeway median in this area. The DesertXpress EIS and 

September 2020 Reevaluation identified Mitigation Measure LU-2 to address potential conflicts with 

planned and existing airports. This mitigation measure would still apply and would avoid or reduce any 

potential conflict with planned uses at this airport facility.

The rail alignments analyzed in the DesertXpress EIS extended along the west side of the I-15 freeway 

past McCarran Airport15. The modified Project would end south of McCarran Airport at the Warm 

Springs Station, as established in the September 2020 Reevaluation. As a result, the modified Project 

does not include facilities within McCarran Airport runway protection zones; the southernmost limit of 

the McCarran Airport runway protection zone is approximately 1 mile northeast from the northernmost 

limit of the Warm Springs Station.16 Consistent with the assessment in the September 2020 

Reevaluation, the modified Project would reduce potential conflicts with the McCarran Airport as 

compared to the DesertXpress EIS.

Portions of the modified alignment would be located within a 60 decibel (dB) subzone surrounding 

McCarran Airport, and the Warm Springs Station would be located within 60- and 65-dB subzones. 

According to the 2014 Enterprise Land Use Plan, land use restrictions do not exist in these subzones for 

transportation land uses such as the Project as disclosed in the September 2020 Reevaluation.

17 The 

14 Federal Aviation Administration. 2007. Southern Nevada Supplemental Airport Environmental Impact Statement. Available: 

http://www.aerohabitat.eu/uploads/media/28-08-2008_-_Southern_Nevada_Airport_EIA_Process_Report_June2007_01.pdf. 

Accessed: April 2022.

15 The McCarran Airport was renamed to the Harry Reid International Airport in December 2021. McCarran Airport is used in 

this document for consistency with the DesertXpress EIS and September 2020 Reevaluation.

16 McCarran Airport Environs. n.d. Available: https://maps.clarkcountynv.gov/gisplot_pdfs/cp/McCarran-AirportEnvirons.pdf. 

Accessed: April 2022.

17 Clark County. 2014. Enterprise Land Use Plan. Available: 

https://files.clarkcountynv.gov/clarknv/Comprehensive%20Planning/Land%20Use%20Planning/Enterprise/2014%20Enterprise

%20Land%20Use%20Plan.pdf?t=1602798319013&t=1602798319013. Accessed: April 2022.
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Project modifications would not result in substantial changes in the evaluation of airport land use 

impacts of the DesertXpress EIS or September 2020 Reevaluation.

ENVIRONMENTAL EFFECTS DISPROPORTIONATELY BORNE BY LOW-INCOME OR MINORITY 

POPULATIONS

The DesertXpress EIS and September 2020 Reevaluation identified locations where the Project would 

intersect or occur within 1 mile of environmental justice communities, using 2000 US Census data, and 

2017 and 2018 US Census data, respectively.

18 Because census tract boundaries have been redrawn 

since publication of the DesertXpress EIS, changes in demographics and the Project impacts on nearby 

communities cannot be described in the exact terms of the DesertXpress EIS analysis. However, the 

DesertXpress EIS analysis was replicated using 2019 US Census data.19,20

Table 4-2 provides a comparison of the modified Project’s proximity to environmental justice block 

groups, relative to those identified in the DesertXpress EIS and September 2020 Reevaluation. 

The DesertXpress EIS and September 2020 Reevaluation concluded that impacts to environmental 

justice block groups would be minimized through mitigation measures to address noise, dust, traffic, 

visual resources, and utilities. Because the Project Modifications move most of the rail facilities to within 

the median of the I-15 freeway and areas added that are outside the I-15 freeway ROW (Sloan VMF) are 

located in areas of industrial uses and undeveloped land, there would be fewer EJ communities crossed 

or within one mile of the Project facilities than those evaluated in the original project and September 

2020 Reevaluation. As a result, impacts to environmental justice communities such as noise, air quality, 

traffic, visual resources, utilities, or community resource impacts would be reduced as a result of the 

project modifications. However, the project would continue to be located in proximity to environmental 

just communities along and near the I-15 freeway corridor and as such the mitigation measures 

established in the DesertXpress EIS and carried forward in the September 2020 Reevaluation (described 

in Section 4.1.3, Mitigation Measures), would remain appropriate in order to reduce and avoid impacts 

to environmental justice block groups. 

Based on this analysis the modified Project would not result in new environmental effects 

disproportionately borne by environmental justice communities and the Project modifications would 

not result in substantial changes in the evaluation of environmental justice impacts of the DesertXpress 

EIS or September 2020 Reevaluation. 

18 Environmental justice communities defined in the DesertXpress EIS include low-income populations greater than 25 percent 

of the total population of the community, minority populations greater than 50 percent of the total population of the 

community, and low-income or more minority populations 10 percentage points higher than the city or county average.

19 United States Environmental Protection Agency. 2019. EJSCREEN: Environmental Justice Screening and Mapping Tool. 

Available: https://www.epa.gov/ejscreen. Accessed April 2022.

20 2019 data is the most recent Census data available; complete 2020 data is unavailable due to the impacts of the COVID-19 

pandemic on data collection.
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Table 4-2 Environmental Justice Communities

Modified Project 

Facilities

Number of 

Environmental Justice 

Block Groups (EJ) 

Communities Crossed 

by or Within One Mile 

of DesertXpress EIS 

Preferred Alternative 

Facilities

Number of EJ 

Communities Crossed 

by or Within One Mile 

of September 2020 

Reevaluation Project 

Facilities

Number of EJ 

Communities Crossed 

by or Within One Mile 

of the Current (2023)

Modified Project 

Facilities

Victor Valley Station Within 1 mile of 2 EJ 

census blocks

Within 1 mile of 2 EJ 

census blocks

Within 1 mile of 1 EJ 

census block

Segment 1 Cross 2 EJ census blocks Cross 3 EJ census blocks Cross 1 EJ census block

Segment 2 Within 1 mile of 4 EJ 

census blocks 

Cross 12 EJ census blocks Cross 6 EJ census blocks

and within 1 mile of 3 EJ 

census blocks

Segment 3 Cross 3 EJ census blocks Cross 2 EJ census blocks Cross 1 EJ census block

Segment 4 Cross 1 EJ census block Cross 1 EJ census blocks Cross 1 EJ census block

Segment 5 Outside any EJ census 

block

Cross 2 EJ census blocks Cross 1 EJ census block

Segment 6 Cross 4 EJ census blocks Cross 5 EJ census blocks Cross 1 EJ census block

Warm Springs Station Within 1 mile of 1 EJ 

census block

Within 1 mile of 6 EJ 

census blocks

Within 1 mile of 1 EJ 

census blocks

4.1.3 MITIGATION MEASURES

The following mitigation measures established in the DesertXpress EIS and revised in the September 

2020 Reevaluation would avoid adverse land use effects:

• Mitigation Measure LU-1: Rail Alignment Design in One-Engine Inoperative Zones

• Mitigation Measure LU-2: Rail Alignment Design in Existing and Planned Runway Zones

• Mitigation Measure LU-3: DRECP Land Use Plane Amendment Conservation and Management 

Action Compliance, established in the September 2020 Reevaluation, would still apply to the 

modified Project to ensure compliance with applicable goals, policies, and CMAs where the Project 

would traverse land under BLM management protected by the DRECP LUPA.

Additionally, mitigation measures pertaining to the resource topics listed below would be implemented 

to avoid and minimize impacts on adjacent land uses and environmental justice communities:

▪ Utilities. Avoidance or minimization of conflicts with existing utility infrastructure (including 

coordination with existing utility providers).

▪ Traffic. The addition of signalization and/or lanes to the intersection approaches.

▪ Visual Resources. Use of aesthetically pleasing materials for the rail alignment that minimize 

reflectivity, use of architecture and earth tone colors at the Victor Valley Station site that reflect the 

surrounding desert landscape, design of signage at the Victor Valley Station site to reflect the scale 

and character of the site and surroundings, use of contour grading, orderly construction site 
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management, minimization of light spillover during construction, and use of visual screening of 

construction areas as appropriate. Coordination with stakeholder agencies to create a unified 

aesthetic theme that supports the aesthetic goals of the community, including specific design 

elements part of the Aesthetic and Landscape Task Force (ALTF). The aesthetic treatment of the 

structures shall involve color, texture, and patterns that tie into the Brightline West Project's Project 

Aesthetic and Landscape Masterplan (PALM) to create a visual link between the structures and 

other Project elements along the corridor.

▪ Air Quality. Use of best management dust control practices to minimize air quality impacts during 

construction.

▪ Noise. Installation of noise barriers, use of sound and vibration reducing materials, relocation of 

crossovers or special track work, property acquisitions, limited construction times, limited locations 

of construction.

4.2 GROWTH

This section evaluates whether the Project modifications would result in substantial changes to the 

evaluation of effects to regional population, housing, and employment effects discussed in the 

DesertXpress EIS and September 2020 Reevaluation. As previously established in the September 2020 

Reevaluation, the September 2020 Project modifications did not result in substantial changes to the 

evaluation of effects to growth of the DesertXpress EIS.

4.2.1 REGULATORY UPDATES

No updates to Federal, state, or local regulation that pertain to the modified Project’s effects on local 

and regional growth have occurred since the September 2020 Reevaluation. Additionally, no changes in 

the physical environment pertaining to the modified Project have occurred since the September 2020 

Reevaluation that would result in substantial changes to the evaluation of local and regional growth.

4.2.2 EFFECTS ANALYSIS

CONSTRUCTION-PERIOD EMPLOYMENT

The DesertXpress EIS estimated that Project design and construction would have a positive economic 

effect on the Project area, generating approximately 28,384 jobs in San Bernardino County and 17,469 

jobs in Clark County, equating to a total of 45,853 new employment opportunities in the Project vicinity. 

The modified Project footprint would not substantially differ, and thus the conclusions regarding 

construction-period employment would not substantially change from those disclosed in the September 

2020 Reevaluation. The modified Project would still contribute positively to local employment 

opportunities and economic growth throughout the modified Project area during construction. 

Voluntary Mitigation Measure GRO-1 would still apply to ensure jobs generated by the Project would be 

made available to Barstow residents. Thus, the Project modifications would not result in substantial 

changes in the evaluation of construction-period employment impacts of the DesertXpress EIS or 

September 2020 Reevaluation.

PERMANENT EMPLOYMENT

The DesertXpress EIS and September 2020 Reevaluation analyzed permanent employment from Project 

operation effects on regional growth. The modified Project would require workers to operate and 

maintain trains, stations, and other Project facilities. Estimates of total permanent jobs created 
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throughout Project operation were compared to regional job projections in the anticipated Project 

buildout year (2030, as established by the DesertXpress EIS). These permanent job estimates did not 

result in significant effects on local employment growth. The modified Project would not change the 

September 2020 Reevaluation conclusions regarding permanent employment because the modified 

footprint would remain relatively the same, and the size and locations of the Victor Valley Station and 

Warm Springs Station have remained unchanged since the September 2020 Reevaluation. Voluntary 

Mitigation Measure GRO-1 would still apply for the modified Project, in order to ensure jobs generated 

by the Project would be made available to Barstow residents. Thus, the Project modifications would not 

result in substantial changes in the evaluation of permanent employment impacts of the DesertXpress 

EIS or September 2020 Reevaluation.

TRANSIT-ORIENTED DEVELOPMENT POTENTIAL

The DesertXpress EIS and September 2020 Reevaluation analyzed the Project’s potential to induce 

transit-oriented development (TOD), which is development that aims to promote sustainable urban 

growth through densification near transit stations. The previous evaluations concluded that the Project 

would result in a small potential to induce TOD because the Project would primarily provide non-work 

trips between the Victorville and Las Vegas stations. The modified Project would not change the 

September 2020 Reevaluation conclusions regarding induced TOD because it would still connect the 

Victorville area and Las Vegas and would not substantially change the nature of trips provided during 

Project operation. Thus, the Project modifications would not result in significant TOD development 

impacts not evaluated in the DesertXpress EIS or September 2020 Reevaluation. Voluntary Mitigation 

Measure GRO-2 would still apply to the modified Project, to encourage implementation of transit 

oriented and master planned development. 

ECONOMIC VITALITY

The economies of several communities in the Project vicinity, including Barstow, Baker, Primm, and 

Jean, are heavily dependent on visitor-serving retail and commercial uses for people driving through the 

I-15 freeway. The ridership study prepared for the DesertXpress EIS estimated up to 5 million annual 

automobile trips between southern California and Las Vegas would be diverted to high-speed rail, 

meaning the Project has the potential to negatively affect future economic growth in these communities 

because the Project would not include stations in the aforementioned communities. Thus, the 

DesertXpress EIS and September 2020 Reevaluation concluded the Project would result in potential 

minor adverse effects to the economic vitality of these communities. 

The proposed Project would not change these conclusions regarding economic vitality because the 

Project modifications are not anticipated to substantially increase or decrease ridership. Furthermore, 

the economic composition of Barstow, Baker, Primm, and Jean have not substantially changed since the 

September 2020 Reevaluation, and travel demand between southern California and Las Vegas is still 

anticipated to increase. Therefore, the Project modifications would not result in substantial changes in 

the evaluation of economic vitality impacts of the DesertXpress EIS or September 2020 Reevaluation. 

4.2.3 MITIGATION MEASURES

Voluntary Mitigation Measures GRO-1 and GRO-2 were established in the DesertXpress EIS and revised 

in the September 2020 Reevaluation. The DesertXpress EIS concluded implementation of the Project 

would not result in any adverse direct or indirect growth effects and that no mitigation measures would 

be required. However, DesertXpress Enterprises, LLC proposed the following voluntary mitigation 
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measures to address concerns raised by local jurisdictions regarding potential economic impacts of the 

Project:

▪ Voluntary Mitigation Measure GRO-1. Voluntary Applicant Coordination with City of Barstow and 

San Bernardino County for Employment.

▪ Voluntary Mitigation Measure GRO-2. Voluntary Applicant Coordination for Land Use Planning. 

4.3 FARMLANDS AND GRAZING LANDS

This section evaluates whether the Project modifications would result in substantial changes to the 

evaluation of effects to farmland and grazing land designations (assigned by the California Department 

of Conservation (DOC), Clark County Comprehensive Plan, and BLM) discussed in the DesertXpress EIS 

and September 2020 Reevaluation. As previously established in the September 2020 Reevaluation, the 

September 2020 Project modifications did not result in substantial changes to the evaluation of visual 

impacts disclosed in the DesertXpress EIS. 

4.3.1 REGULATORY UPDATES

FARMLAND

Within Nevada, there are no designated farmlands within or near the Project area as established in the 

Conservation Element of the Clark County Comprehensive Plan. Within California, the most recent DOC

Farmland Mapping & Monitoring Program update (2016) does not include new Prime Farmland, Unique 

Farmland, Farmland of Statewide Importance, Farmland of Local Importance, nor lands under 

Williamson Act Contracts within the Project area. 

GRAZING LAND

The DesertXpress EIS and September 2020 Reevaluation evaluated the direct and indirect effects to 

grazing lands outlined below:

▪ Permanent conversion of grazing land to transportation uses

▪ Severing of livestock access to available water sources

▪ Removal of livestock fencing

The locations of designated grazing allotments within BLM managed lands within or near the Project 

area have not changed since the September 2020 Reevaluation.21

4.3.2 EFFECTS ANALYSIS

ALIGNMENT 

The modified alignment would not require conversion of grazing land because the modified alignment 

would be constructed within the I-15 freeway ROW from Segment 1 through Segment 5. Additionally, 

given there are no changes in the amount or location of protected farmland in the Project area and the 

modified Project avoids direct and indirect impacts on Prime Farmland, the Project modifications would 

not result in substantial changes in the evaluation of farmland impacts of the DesertXpress EIS or 

September 2020 Reevaluation.

21 Bureau of Land Management. 2022. BLM National Grazing Allotments Map Service. Available: 

https://landscape.blm.gov/geoportal/rest/document?f=html&id=%7B8C2D42AB-A6B9-4DF7-AD77-E98A1BD8468A%7D. 

Accessed: June 2022.
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ANCILLARY FACILITIES 

The modified Project includes additional roadwork proposed for the Project that was not previously 

evaluated. This includes modifications to the I-15 freeway near Victor Valley Station and to the Dale 

Evans Parkway interchange, and the widening of the I-15 median in Segment 5. Though the Dale Evans 

Parkway and Cemex rail connection are adjacent to grazing land, the modified Project would not change 

the September 2020 Reevaluation conclusions regarding grazing land impacted because the Project 

modifications would primarily occur within the I-15 freeway ROW.

Modifications to highway ramp realignments and emergency crossovers would be located primarily 

within the existing Caltrans/NDOT, and local ROWs along the I-15, including the relocation and addition 

of emergency crossovers listed in Table 2-1. Project modifications further include potential I-15 median 

widening and four culvert additions within Segment 5 near the town of Sloan. However, none of the 

Project modifications listed within Segment 5 are located on grazing lands or farmland. 

Mitigation Measures FAR-2, FAR-3, FAR-4, and FAR-5 would still apply to minimize direct and indirect 

effects to grazing land where ancillary facilities would occur outside the I-15 freeway ROW. Thus, the 

modified ancillary facilities would not result in substantial changes in the evaluation of grazing land 

impacts of the DesertXpress EIS or September 2020 Reevaluation.

4.3.3 MITIGATION MEASURES

The following mitigation measures established in the DesertXpress EIS and revised in the September 

2020 Reevaluation would avoid adverse effects related to farmlands and grazing lands. 

▪ Mitigation Measure FAR-2: Livestock Access to Water

▪ Mitigation Measure FAR-3: Fencing and Gate Modifications

▪ Mitigation Measure FAR-5: Purchase Grazing Allotment

4.4 UTILITIES/EMERGENCY SERVICES

This section evaluates whether the Project modifications would result in substantial changes to the 

evaluation of effects to utilities and emergency services discussed in the DesertXpress EIS and 

September 2020 Reevaluation. As previously established in the September 2020 Reevaluation, the 

September 2020 Project modifications did not result in substantial changes to the evaluation of utilities 

and emergency services impacts disclosed in the DesertXpress EIS.

4.4.1 REGULATORY UPDATES

FEDERAL

No updates to Federal, state, or local regulations governing utilities have occurred since the September 

2020 Reevaluation that would pertain to the modified Project. Additionally, no changes in the physical 

environment have occurred since the September 2020 Reevaluation that would result in substantial 

changes to the evaluation of utilities for the modified Project.
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4.4.2 EFFECTS ANALYSIS

ELECTRICITY AND GAS

The modified Project includes electric train locomotives that would require interconnections with 

regional electricity services. Station sites and ancillary features including the electrical substations in 

Ivanpah and Barstow, and the proposed Cemex rail connection, would also require electricity and gas 

services. Mitigation Measure UTIL-1 would still apply to the modified Project to avoid or minimize 

impacts to electrical providers during operation of the modified Project. Furthermore, DesertXpress 

Enterprises, LLC is coordinating with electricity providers to ensure the adequacy of regional power 

delivery systems. Thus, the Project modifications would not result in substantial changes in the 

evaluation of electricity and gas impacts of the DesertXpress EIS or September 2020 Reevaluation.

WATER SUPPLY

The DesertXpress EIS identified the Victorville Water District (VVWD) and the Las Vegas Valley Water 

District (LVVWD) as the Project water providers in California and Nevada, respectively. There would be 

no changes to the proposed station footprints. The rail alignment and ancillary facilities would not 

generate water demand because they would not require landscaping or other water-related uses.

Furthermore, the DesertXpress EIS included Mitigation Measures UTIL-1, UTIL-2, and UTIL-3 to reduce 

water usage, prepare a water supply assessment for the Victor Valley Station site, and procure a water 

commitment from the LVVWD. These mitigation measures would still apply to the Project and the 

Project modifications would not result in substantial changes in the evaluation of water supply impacts 

of the DesertXpress EIS or September 2020 Reevaluation.

SEWAGE AND WASTEWATER

The DesertXpress EIS identified the Victor Valley Wastewater Reclamation Authority and the Clark 

County Wastewater Reclamation District as the water treatment providers that would service the 

Project in California and Nevada, respectively. The station sites and the OMSF would not change as 

evaluated in the September 2020 Reevaluation, and the rail alignment and ancillary facilities would not 

require restrooms or other features that would create sewage or wastewater. Mitigation Measure UTIL1 would still apply to reduce potential impacts of the Project on wastewater treatment services by 

subsidizing the applicable wastewater treatment service providers. This mitigation measure would still 

apply to the modified Project and the Project modifications would not result in substantial changes in 

the evaluation of wastewater impacts of the DesertXpress EIS or September 2020 Reevaluation.

STORMWATER

The DesertXpress EIS determined operation of the Project would introduce new impermeable surfaces 

that could increase stormwater flows into local stormwater systems. The modified Project would not 

change the September 2020 Reevaluation conclusions regarding stormwater because it would not 

substantially alter the amount of impervious surface introduced by the Project. The rail alignment, 

station sites and OMSF, and ancillary features, would not introduce new impervious footprint areas 

throughout the Project footprint, and Mitigation Measures UTIL-4 and UTIL-5 would still apply to 

minimize impacts to stormwater systems. The Project modifications would not result in substantial 

changes in the evaluation of stormwater impacts of the DesertXpress EIS or September 2020 

Reevaluation. Refer to Section 4.8, Hydrology and Water Quality, for a discussion of Project impacts to 

stormwater during construction.
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SOLID WASTE

The DesertXpress EIS identified the Victorville Sanitary Landfill and the Apex Regional Landfill as the 

landfills that would service the Project in California and Nevada, respectively. While the location and 

layout of the Project alignment and ancillary features have changed for the modified Project, the 

anticipated volume of solid waste generated by these facilities during construction and operation would 

not substantially differ from the assumptions established in the September 2020 Reevaluation. The 

modified Project would not change the September 2020 Reevaluation conclusions regarding solid waste 

because substantial capacity still exists at these facilities to accommodate construction-period and 

operational waste generated by the Project.22,23 The Project modifications would not result in substantial 

changes in the evaluation of solid waste impacts of the DesertXpress EIS or September 2020 

Reevaluation.

UTILITY INFRASTRUCTURE CROSSINGS

The Project would cross numerous utility conveyance systems, including gas pipelines, electrical 

transmission lines, water and wastewater conveyances, and communications lines, potentially reducing 

the effectiveness of these systems or resulting in human health and safety concerns. New alignment or 

footprint areas could intersect with utility conveyance systems that were not identified in the 

DesertXpress EIS or September 2020 Reevaluation, and new conveyance systems may have been 

constructed since the September 2020 Reevaluation. However, the modified Project would not change 

the September 2020 Reevaluation conclusions regarding utility infrastructure crossings because 

Mitigation Measure UTIL-8 would still apply to the Project to avoid or minimize potential adverse effects 

to water, wastewater, communications, local gas pipelines, and other physical facilities that the 

proposed rail alignments and stations would cross. The Project modifications would not result in 

substantial changes in the evaluation of utility infrastructure crossing impacts of the DesertXpress EIS or 

September 2020 Reevaluation.

EMERGENCY SERVICES

The Project would increase the need for emergency services by creating a new passenger rail system. 

The modified Project would not change the September 2020 Reevaluation conclusions regarding 

emergency services because the Project modifications to the alignment and mainline ancillary features

would not increase the risk of catastrophic accidents. Additionally, the Project modifications would not 

result in changes to ridership, emergency protocols, and safety systems such as clear zones and barriers

to avoid vehicle intrusion into the modified Project ROW described in Mitigation Measure TRAF-4 (refer 

to Section 4.5).

The modified Project would incorporate design guidelines provided in the 2011 DesertXpress Highway

Interface Manual to facilitate emergency access crossings of portions of the Project alignment located 

within the I-15 freeway ROW. The Project evaluated in the September 2020 Reevaluation included eight

access-controlled emergency crossovers. The modified Project would include two new emergency 

crossovers at Zzyzx Road and Halloran Springs. Additionally, five previously evaluated emergency 

crossovers, located near Coyote Lake Road, Basin Road, Baker, and both north and south of Halloran 

Springs, would be relocated, mainly within existing Caltrans/NDOT ROW. In total, the modified Project 

22 County of San Bernardino. 2018. Countywide Siting Element.

23 State of Nevada. 2017. Solid Waste Management Plan.
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would include 10 emergency crossovers in California, located in Segment 3 between Yermo and 

Mountain Pass, and one emergency crossover in Nevada approximately 1.5-miles south of Sloan.

Modified Project facilities would be constructed across the same jurisdictions analyzed in the September 

2020 Reevaluation and would be served by the same emergency service providers. Mitigation Measures 

UTIL-6 and UTIL-7 would still apply to the Project, which would require the payment of impact fees for 

police, fire, and emergency services, and the development and implementation of a comprehensive 

emergency operations plan. Therefore, the Project modifications would not result in substantial changes 

in the evaluation of emergency services impacts of the DesertXpress EIS or September 2020 

Reevaluation.

4.4.3 MITIGATION MEASURES

The following mitigation measures established in the DesertXpress EIS and revised in the September 

2020 Reevaluation would avoid adverse effects to utilities and emergency services:

▪ Mitigation Measure UTIL-1: Payment of connection and or user/service/tipping fees

▪ Mitigation Measure UTIL-2: Minimize water usage through the incorporation of water saving devices 

wherever required or feasible; require drought-tolerant landscaping at all facilities

▪ Mitigation Measure UTIL-3: Obtain a water commitment from the LVVWD during the design phase

▪ Mitigation Measure UTIL-4: Rail segments within freeway ROWs shall tie into existing freeway 

stormwater conveyance devices

▪ Mitigation Measure UTIL-5: Develop appropriate stormwater conveyance structures/systems at 

station and maintenance facility sites, as well as points along railroad segments where it is not 

possible to connect to existing systems

▪ Mitigation Measure UTIL-6: Payment of impact fees for police, fire, and emergency services

▪ Mitigation Measure UTIL-7: Develop a comprehensive emergency operations plan

▪ Mitigation Measure UTIL-8: Avoid or minimize conflicts with existing utility infrastructure

4.5 TRAFFIC AND TRANSPORTATION

This section evaluates whether the Project modifications would result in substantial changes to the 

evaluation of effects to traffic and transportation discussed in the DesertXpress EIS and September 2020 

Reevaluation. As previously established in the September 2020 Reevaluation, the September 2020 

Project modifications did not result in substantial changes to the evaluation of traffic and transportation 

disclosed in the DesertXpress EIS.

4.5.1 REGULATORY UPDATES

No updates to Federal, state, or local regulations governing traffic and transportation have occurred 

since the September 2020 Reevaluation that would pertain to the modified Project. Additionally, no 

changes in the physical environment have occurred since the September 2020 Reevaluation that would 

result in substantial changes to the evaluation of traffic and transportation for the modified Project.
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4.5.2 EFFECTS ANALYSIS

FREEWAY LEVEL OF SERVICE

There are no changes to the Victor Valley Station or Warm Springs Station footprints since the 

September 2020 Reevaluation. 

Brightline West has coordinated with FHWA and Caltrans on the proposed roadway modifications along 

the I-15 freeway for the modified Project. The Project modifications include additional roadwork at the 

Dale Evans Parkway such as realigning and raising the I-15 freeway northbound lane and additional 

roadwork at the I-15 southbound ramps. As evaluated in the September 2020 Reevaluation, the Level of 

Service (LOS) at the southbound on- and off-ramps would operate at unacceptable LOS F during the 

2042 Build Out Year. The additional roadwork may improve LOS at the Southbound ramps and 

Mitigation Measures TRAF-1 and TRAF-4 would still be incorporated to improve LOS at the Victor Valley

Station and the I-15 southbound ramps and to mitigate potential adverse effects on highway traffic 

safety. Thus, the modified Project would still result in LOS impacts at the I-15 southbound ramps at Dale 

Evans Parkway and would not result in substantial changes in the evaluation of effects to the Victor 

Valley Station and Warm Springs Station of the DesertXpress EIS or September 2020 Reevaluation.

INTERSECTION LEVEL OF SERVICE

There have been no changes to the Victor Valley Station or Warm Springs Station footprints since the 

September 2020 Reevaluation. The Project modifications include additional roadwork at Dale Evans 

Parkway such as realigning and raising the I-15 freeway northbound lane and additional roadwork at the 

I-15 southbound ramps. The additional roadwork may improve LOS at the southbound ramps at Dale

Evans Parkway, and Mitigation Measures TRAF-1 and TRAF-2 would still be incorporated to improve LOS

at the Victor Valley Station, the I-15 southbound ramps at Dale Evans Parkway, and the Warm Springs

Station. It is anticipated the modified Project would still result in LOS impacts at the I-15 southbound

ramp intersections as determined in the September 2020 Reevaluation. The Project modifications would

not result in substantial changes in the evaluation of effects to the Victor Valley Station and Warm

Springs Station of the DesertXpress EIS or September 2020 Reevaluation.

VEHICLE MILES TRAVELED

The Project is exempt from state and local land use and environmental regulations, including CEQA and 

the CEQA Guidelines updates addressing vehicle miles traveled (VMT) impacts of projects. While these 

updates to the CEQA Guidelines were adopted in December 2018, a brief discussion of the modified 

Project’s VMT-related effects was provided in the September 2020 Reevaluation for informational 

purposes. The September 2020 Reevaluation estimated the Project would result in an annual VMT 

reduction of approximately 564 million VMT by the build out year in 2042, but would further result in an 

increase of 46 million VMT annually from induced demand generated by the Project, and an increase of 

16 million VMT annually from employee commute trips. 24,25 Overall, the September 2020 Reevaluation 

concluded the Project would still result in a substantial reduction in annual VMT (approximately 502 

24 VMT reduction associated with trips diverted from automobiles to rail assumed an estimated 8,061,000 passengers annually 

for the Project by build out year in 2042.

25 VMT increase associated with employee commute trips conservatively assumed 572 daily employees at the Victor Valley

Station, and 462 daily employees at the Warms Springs Station, for a total of 1,034 daily employees.
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million VMT) due to diversion from automobiles to rail within the I-15 freeway corridor, resulting in a 

beneficial effect.

The modified Project would still provide an alternate transportation mode from automobiles between 

Apple Valley and Las Vegas, as the proposed station locations have remained unchanged. Additionally, 

estimates regarding annual ridership diverted from automobiles during the build out year have not 

changed under the Project modifications. Thus, the modified Project would still result in substantial 

reductions in annual VMT along the I-15 freeway corridor and would not result in substantial changes in 

the evaluation of effects to VMT of the DesertXpress EIS or September 2020 Reevaluation.

ROADWAY SAFETY

Highways

The DesertXpress EIS included a qualitative discussion of highway traffic safety, primarily focusing on 

clear zones, sight distance, and visual distraction. Project modifications include changes in alignment 

and other ancillary features, which would affect the ultimate design of facilities, such as earthwork, 

structural supports, overhead catenary systems, and other components. 

While the geographic location of specific safety-related impacts would be different than the Project 

evaluated in the September 2020 Reevaluation, the nature of these impacts would generally remain 

unchanged. These impacts could include potential effects related to obstruction of motorists’ sight 

distance, increased severity of run-off road crashes, and visual distractions for motorists (particularly 

train headlights) during operation of the modified Project, as well as temporary reductions in horizontal 

and vertical clearances during construction of the Project. However, given the market diversion from 

automobiles to rail in the I-15 freeway corridor, the modified Project (and associated roadway 

modifications) would also result in some beneficial effects to highway safety due to a reduction in 

collisions. Mitigation Measure TRAF-4 would still be applied to fully mitigate the modified Project’s 

potentially adverse effects on highway safety. Therefore, the modified Project would not result in 

substantial changes in the evaluation of effects to highway safety of the DesertXpress EIS or September 

2020 Reevaluation.

Local Streets

While the modified Project would result in added traffic on local streets surrounding the Victor Valley

Station and the Warm Springs Station, an increase in traffic alone would generally not constitute a safety 

hazard. The intersection improvements for both station sites, described in Mitigation Measures TRAF-1 

and TRAF-2 respectively, are specifically intended to provide safe and adequate connections between 

the station and the existing circulation network, and include new traffic signals, turn pockets, and other 

measures that would minimize traffic hazards such as ROW conflicts. All improvements would be 

designed according to accepted industry standards such as the Manual on Uniform Traffic Control 

Devices (MUTCD), the American Association of State Highway and Transportation Officials (AASHTO) 

Policy on Geometric Design of Highways and Streets, and the National Association of City Transportation 

Officials Urban Street Design Guide, and would be coordinated with local jurisdictions to ensure 
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conformance with their specific design practices.26,27,28 Thus, the Project modifications would not result 

in substantial changes in the evaluation of street safety impacts of the DesertXpress EIS or September 

2020 Reevaluation.

4.5.3 MITIGATION MEASURES

The following mitigation measures established in the DesertXpress EIS and revised in the September 

2020 Reevaluation would avoid adverse effects on traffic and transportation:

▪ Mitigation Measure TRAF-1: Victor Valley Station

▪ Mitigation Measure TRAF-2: Warm Springs Station

▪ Mitigation Measure TRAF-4: Conduct a Design Review within the Parameters Defined in the Highway

Interface Manual

4.6 VISUAL RESOURCES

This section evaluates whether the Project modifications would result in substantial changes to the 

evaluation of aesthetic and visual resources discussed in the DesertXpress EIS and September 2020 

Reevaluation. As previously established in the September 2020 Reevaluation, the September 2020 

Project modifications did not result in substantial changes to the evaluation of visual impacts disclosed 

in the DesertXpress EIS. 

The visual landscape surrounding the Project area has not changed substantially since the September 

2020 Reevaluation. Undeveloped areas traversed by the Project corridor are characterized by low-lying 

shrubs, desert soils, rolling dunes, and occasional manmade development such as lights and billboards. 

Human development constitutes a majority of local viewsheds within urban areas (Barstow, Baker, 

Primm, Jean, and Las Vegas).

4.6.1 REGULATORY UPDATES

The September 2020 Reevaluation utilized a blended methodology to assess effects by individual project 

components based on guidelines provided by the BLM and FHWA, consistent with the methodology 

used in the DesertXpress EIS. These visual quality guidelines have not changed since publication of the 

DesertXpress EIS. No changes in the physical environment have occurred since the September 2020 

Reevaluation that would result in substantial changes to the evaluation of visual resources for the 

modified Project.

4.6.2 EFFECTS ANALYSIS

CONSTRUCTION

The DesertXpress EIS established Project construction activities would involve the use of heavy 

equipment, stockpiling of soils and materials, and other visual signs of construction. Constructionrelated visual impacts along the alignment would be temporary in nature and small in scale. 

26 Federal Highway Administration. 2019. Manual on Uniform Traffic Control Devices. 

https://mutcd.fhwa.dot.gov/pdfs/2009r1r2/pdf_index.htm. Accessed: April 2022.

27 American Association of State Highway and Transportation Officials. 2018. A Policy on Geometric Design of Highways and 

Streets, 7th Edition. https://trust.dot.state.wi.us/ftp/dtsd/bts/environment/library/PE/AASHTO-GreenBook-7thedition(2018).pdf. Accessed: April 2022. 

28 National Association of City Transportation Officials. 2022. Urban Street Design Guide. https://nacto.org/publication/urbanstreet-design-guide/. Accessed: April 2022.
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Construction of stations, alignment, and ancillary features related to the Project would involve site 

preparation and foundation work, framing, and structural construction and finishing work; these visual 

impacts would be temporary. As the modified Project would remain of a comparable size, scope, and 

location as analyzed in both the September 2020 Reevaluation and DesertXpress EIS, visual impacts 

would occur over a similar area. 

The modified Project would not require several TCAs, previously identified in the DesertXpress EIS, along 

the I-15 freeway ROW. Additionally, impacts to the southerly Ivanpah Utility Corridor would be avoided

as this Project feature is no longer being considered. However, new TCAs are proposed for the modified 

Project, which would be primarily located within the I-15 freeway ROW. Visual impacts from 

construction activities and TCAs would be minimized through implementation of Mitigation Measures 

VIS-7 through VIS-10. The Project modifications would not result in substantial changes in the evaluation 

of construction effects to visual quality of the DesertXpress EIS or September 2020 Reevaluation.

OPERATION

Alignment

The modified Project would relocate rail alignment previously adjacent to the I-15 freeway to be within 

the I-15 freeway median for the entirety of Segment 1 and Segment 5. In addition, as established in the 

September 2020 Reevaluation, the modified alignment would be largely at-grade, rather than being 

situated on elevated structures. This would decrease adverse visual impacts, identified in the 

DesertXpress EIS, since at-grade portions would appear less visually dominant compared to elevated 

tracks. The modified alignment, which would include passing trains, would not substantially add to the 

visual impact already created by the I-15 freeway corridor. Mitigation Measures VIS-1 and VIS-4 would 

still apply to minimize impacts to visual quality resulting from the alignment. The modified alignment 

would not result in substantial changes in the evaluation of effects to visual quality of the DesertXpress 

EIS or September 2020 Reevaluation.

Mainline Ancillary Features

Since the September 2020 Reevaluation, several modifications to previously evaluated ancillary features 

have been proposed. These include the Project modification and relocation of highway on- and offramps along the I-15 freeway, the Project modification and addition of new CHP emergency crossovers

along the I-15 freeway in Segment 3, additional roadwork to the Dale Evans Parkway roundabout in 

Segment 1 and widening of portions of the I-15 freeway median near Victor Valley Station and at 

Segment 5, and the Project modification and addition of culverts along the modified alignment in 

Segment 5. These Project modifications would not change the conclusions in the September 2020 

Reevaluation because these features would be located within the I-15 freeway ROW and would be 

visually consistent with the existing transportation corridor. Mitigation Measure VIS-1 would still apply 

to further minimize visual effects associated with the Project modifications to highway on- and offramps, and the Project modification and addition of emergency crossovers, roadwork, and culverts.

Thus, these modified Project features would not result in substantial changes in the evaluation of effects 

to visual quality of the DesertXpress EIS or September 2020 Reevaluation.

The September 2020 Reevaluation also evaluated the potential for visual impacts from the Ivanpah 

Electric Substation, and associated utility corridor which would travel around the BrightSource Energy 

Ivanpah Solar Electric Generating System. It concluded that the substation and utility corridor would be 

visually consistent with the existing metal towers, utility lines, electrical generation equipment, and 
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other infrastructure in the area, and would not result in substantial changes in the evaluation of visual 

resource impacts from that of the DesertXpress EIS. Since the September 2020 Reevaluation, the 

Ivanpah Electric Substation utility line has been modified such that it would travel north of, rather than 

around, the existing solar field to connect to the BrightSource Energy Ivanpah Electrical Generating 

System, resulting in the reduction of approximately 0.18 acres of permanent footprint. Mitigation 

Measure VIS-1 would still apply to further minimize visual effects associated with the new electrical 

substation and utility corridor. Thus, the Ivanpah Electric Substation would not result in substantial 

changes in the evaluation of effects to visual quality of the DesertXpress EIS or September 2020 

Reevaluation.

Areas of Critical Environmental Concern

BLM established numerous ACECs throughout the Project landscape in California that may exhibit scenic 

value. After BLM’s issuance of the Record of Decision for the Desert Renewable Energy Conservation 

Plan (DRECP) in 2016, five new ACEC’s were established that occur within the modified Project footprint. 

These were the Superior-Cronese, Ivanpah, Shadow Valley, Northern Lucerne Wildlife Linkage, and Soda 

Mountains Expansion. However, as established in the September 2020 Reevaluation, these ACECs were 

designated for the value they provide to biological resources and other natural systems, not their 

potential for scenic value. No new ACECs have been established near the Project footprint since the 

September 2020 Reevaluation. The Project modifications would not result in substantial changes in the 

evaluation of visual ACEC impacts of the DesertXpress EIS or September 2020 Reevaluation.

4.6.3 MITIGATION MEASURES

The following mitigation measures established in the DesertXpress EIS and revised in the September 

2020 Reevaluation would avoid adverse effects to visual resources:

• Mitigation Measure VIS-1: Rail Features

• Mitigation Measure VIS-2: Victor Valley Station Features

• Mitigation Measure VIS-3: Maintenance Facility Features

• Mitigation Measure VIS-4: Contour Grading

• Mitigation Measure VIS-5: Light and Glare Reduction

• Mitigation Measure VIS-6: Educational Displays

• Mitigation Measure VIS-7: Construction Site Management

• Mitigation Measure VIS-8: Construction Site Lighting

• Mitigation Measure VIS-9: Visual Screening

• Mitigation Measure VIS-10: Freeway Landscaping

4.7 CULTURAL RESOURCES

This section evaluates whether the Project modifications would result in substantial changes to the 

evaluation of effects to archaeological resources and historic built resources discussed in the 

DesertXpress EIS and September 2020 Reevaluation. 29 

29 ICF and Dudek. 2022. FINAL XpressWest High-Speed Passenger Train Project Archaeological Inventory Report, San Bernardino 

County, California. Prepared for FRA. February 2022; Hale et al. 2022. FINAL XpressWest High-Speed Passenger Train Project 

Archaeological Inventory Report, Clark County, Nevada. Prepared for FRA. February 2022; ICF and HNTB. 2022a. FINAL

XpressWest High-Speed Passenger Train Project Historic Built Environment Technical Report: California. Prepared for FRA;
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Cultural resources within the modified Project’s Area of Potential Effect (APE), as defined in 36 Code of 

Federal Regulations (CFR) 800.16(d), were evaluated for the purposes of this analysis. For the purposes 

of this evaluation, the Project area is synonymous with the APE. The APE is based on preliminary design 

plans and is the area within which direct, indirect, and cumulative effects from the Project are

considered. The APE is characterized by an area of direct impact (APE-ADI), which takes into account 

vertical depth of ground disturbance and includes the footprint of the alignment, facility features, and 

ancillary features, and an area of indirect impact (APE-AII), which encompasses and extends beyond the 

entire area included in the APE-ADI, and takes into account where historic properties may be directly 

affected by construction and operational activities in addition to changes in patterns of use or changes 

in historic character through visual interventions, noise, and/or vibration (ICF and Dudek 2022, Hale et 

al. 2022, ICF and HNTB 2022a, ICF and HNTB 2022b). 

4.7.1 REGULATORY UPDATES

No updates to Federal, state, or local regulations governing cultural resources, nor any changes to the 

existing physical environment, have occurred since the September 2020 Reevaluation that would 

pertain to the Project. Additionally, no changes in the physical environment have occurred since the 

September 2020 Reevaluation that would result in substantial changes to the evaluation of cultural 

resources for the modified Project. FRA is the lead for compliance with Section 106 of the NHPA for the 

Project. 

4.7.2 EFFECTS ANALYSIS 

ARCHAEOLOGICAL RESOURCES

An inventory of archaeological resources has been conducted within the APE for both California (ICF and 

Dudek 2022; Barton and Hale 2022a) and Nevada (Hale et al. 2022; Barton and Hale 2022b).30 The intent 

of these inventory reports is to provide a status of existing knowledge about cultural resources within 

the APE identified for the September 2020 Reevaluation including information obtained from the 

records search and pedestrian survey. Those inventory reports provide an understanding of the likely 

nature and extent of potential historic properties in proximity to the APE.

Considerations of National Register of Historic Places (NRHP) eligibility and effects to historic properties 

have been completed for the September 2020 Reevaluation (Hale and Barton 2022a; Hale and Barton 

2022b) and will be considered through the process established in the Programmatic Agreement (PA) 

executed for the Project for this reevaluation and any future APE modifications or design changes. This 

PA governs compliance with Section 106 of the National Historic Preservation Act (NHPA) to include the 

process for identification, evaluation, and assessment of effects as a result of APE modifications and 

design changes. The PA outlines the process for consultation with the Native American Tribes (Tribes) 

and other Consulting Parties. FRA will seek comment from Tribes and other Consulting Parties on the 

significance of resources documented through the PA process and will provide separate reporting

documenting determinations of eligibility and effects at a later date. Compliance with the terms of the 

PA signifies compliance with Section 106 of the NHPA for the Project.

March 2022 ICF and HNTB. 2022b. FINAL XpressWest High-Speed Passenger Train Project Historic Built Environment Technical 

Report: Nevada. Prepared for FRA. March 2022.

30 The proposed modified Project footprint at the Sloan VMF/UPRR connection, Cemex connection, and Ivanpah substation

were not included in the APE. However, the footprint associated with these modifications are being evaluated and addressed 

pursuant to the requirements outlined in the PA.
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California

In March of 2022, analysts conducted a Class III cultural resources inventory of the Project APE in 

California as identified in the September 2020 Reevaluation. Descriptions and locations of these 

resources appear in the Archaeological Inventory Report for California (ICF and Dudek 2022; Barton and 

Hale 2022a). Determinations of NRHP eligibility and finding of effect are provided separately in the 

Archaeological Finding of Eligibility and Effect for California (Hale and Barton 2022a). 

The Class III inventory of the current Project APE-ADI (which included records search, intensive 

pedestrian survey, subsurface testing, and Tribal consultation) resulted in the identification of 142 

archaeological cultural resources. Of these, 23 (4 archaeological districts, 14 sites within the 

archaeological districts, and 5 sites unaffiliated with archaeological districts) have been determined 

eligible for listing on the NRHP and therefore considered historic properties.

The Class III inventory of the APE-AII (which included records search and Tribal consultation but not field 

inspection) resulted in identification of 330 archaeological cultural resources. One archaeological district 

in the APE-AII was determined eligible for listing on the NRHP and all other archaeological cultural

resources in the Project APE-AII were assumed eligible for listing on the NRHP for the purposes of this 

undertaking only. All assumed eligible archaeological cultural resources in the APE-AII will be avoided.

The California State Historic Preservation Officer (CA SHPO) concurred with some of the NRHP eligibility 

determinations for the archaeological cultural resources in California on December 20, 2022 and did not 

object with the remaining NRHP eligibility determinations on February 14, 2023.31

The DesertXpress EIS and September 2020 Reevaluation outlined the process for Section 106 

compliance first through the 2011 PA, and then through FRA’s planned efforts to continue to advance 

the Section 106 compliance process through consultation and identification, evaluation, and assessment 

of effects efforts for the September 2020 Reevaluation. Subsequently, full historic property inventories 

have been completed for the APE-ADI and APE-AII, including an assessment of effects, and treatment 

measures for avoidance and mitigation of adverse effects, as documented in the 2023 PA and associated 

Historic Properties Treatment Plan (HPTP). The PA and HPTP also provide for treatment of inadvertent 

discoveries.

Nevada

In March of 2022, analysts conducted a Class III cultural resources inventory of the Project APE in 

Nevada as identified in the September 2020 Reevaluation (which does not include the proposed Sloan 

VMF – see Section 5.7). Descriptions and locations of these resources appear in the Archaeological 

Inventory Report for Nevada (Hale et al. 2022; Barton and Hale 2022b). Determinations of NRHP 

eligibility and finding of effect are provided separately in the Archaeological Finding of Eligibility and 

Effect for California (Hale and Barton 2022b). 

The Class III inventory of the current Project APE-ADI (which included records search, intensive 

pedestrian survey, subsurface testing, and Tribal consultation) resulted in the identification of 115 

archaeological cultural resources. Of these, 4 archaeological sites have been determined eligible for 

listing on the NRHP and therefore considered historic properties.

The Class III inventory of the APE-AII (which included records search and Tribal consultation but not field 

inspection) resulted in identification of 99 archaeological cultural resources. All resources in the Project 

31 California SHPO. 2022 and 2023. Letters to Melissa Ivie, Deputy Federal Preservation Officer, Federal Railroad Administration.
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APE-AII were assumed eligible for listing on the NRHP for the purposes of this undertaking only and will 

be avoided. The Nevada State Historic Preservation Officer (NV SHPO) concurred with the NRHP 

eligibility determinations for the archaeological cultural resources in Nevada on August 22, 2022.32

The DesertXpress EIS and September 2020 Reevaluation outlined the process for Section 106 

compliance first through the 2011 PA, and then through FRA’s planned efforts to continue to advance 

the Section 106 compliance process through consultation and identification, evaluation, and assessment 

of effects efforts for the September 2020 Reevaluation. Subsequently, full historic property inventories 

have been completed for the APE-ADI and APE-AII, including an assessment of effects, and treatment 

measures for avoidance and mitigation of adverse effects, as documented in the 2023 PA and associated 

HPTP. The PA and HPTP also provide for treatment of inadvertent discoveries.

HISTORIC BUILT RESOURCES

California

Analysts identified 794 built environment resources located within the APE in California. Two built 

environment resources are considered NRHP eligible, and two are exempt from the requirements of 

Section 106. Analysts surveyed the remaining built environment resources within the APE that required 

evaluation for NRHP eligibility, of which 765 were newly identified as part of this survey. Analysts 

evaluated and/or updated records for these built environment resources, and FRA determined that they 

do not meet the minimum significance or integrity to be considered eligible for NRHP listing and are, 

therefore, not considered historic properties for the purposes of this undertaking. The CA SHPO 

concurred with this finding on February 3, 2022.33

As stated above, two built environment resources within the APE were previously evaluated and 

determined eligible for NRHP listing with SHPO concurrence: the SCE’s Boulder Dam–San Bernardino 

Transmission Line ; and LADWP’s Boulder Dam–Los Angeles Transmission Lines: Boulder Lines 1, 2, and 

3. Analysts surveyed the portions of these properties within the APE and concluded that two historic 

towers and associated transmission line of the Boulder Dam–San Bernardino Transmission Line within 

the APE approximately 6.5 miles southwest of Primm contribute to the property’s significance. Analysts 

concluded that four other segments approximately 16 miles northeast of Baker, approximately 8.5 miles 

northeast of Baker, 31 miles northeast of Yermo, and approximately 18 miles northeast of Yermo retain 

historic integrity and continue to convey the property’s significance. Additionally, segments of the 

Boulder Dam–Los Angeles Transmission Lines crossing the APE approximately 4.5 miles northeast of 

Yermo and 8.5 miles northeast of Victorville retain historic integrity and continue to convey the 

property’s significance. The portions of these properties within the APE are considered eligible for the 

NRHP (ICF and HNTB 2022a). The CA SHPO concurred with this finding on February 3, 2022. 39

The DesertXpress EIS and September 2020 Reevaluation outlined the process for Section 106 

compliance first through the 2011 PA, and then through FRA’s planned efforts to continue to advance 

the Section 106 compliance process through consultation and identification, evaluation, and assessment 

of effects efforts for the September 2020 Reevaluation. Subsequently, full historic property inventories 

have been completed for the APE-ADI and APE-AII, including an assessment of effects, and treatment 

measures for avoidance and mitigation of adverse effects, as documented in the 2023 PA and associated 

32 Nevada SHPO. 2022. Letter to Amanda Murphy, Acting Federal Preservation Officer, Federal Railroad Administration.

33 California SHPO. 2022. Letter to Katherine Zeringue, Federal Preservation Officer, Federal Railroad Administration. 
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Historic Properties Treatment Plan (HPTP). The PA and HPTP also provide for treatment of inadvertent 

discoveries.

Nevada

In Nevada, analysts identified a total of 43 built environment resources located within the APE. Eleven of 

these built environment resources are exempt from the requirements of Section 106 (the I-15 freeway 

and ten I-15 freeway bridges), and four were previously determined to be NRHP eligible. FRA has 

determined that these 4 built environment historic properties remain eligible for listing in the NRHP 

within the APE. One built environment resource, the Old Spanish Trail/Mormon Road, is listed on the 

NRHP (outside the Project area and on a separate trail alignment than this one), and FRA has 

determined that none of the segments of this linear resource within the APE are eligible for listing in the 

NRHP.34 Additionally, one segment of the Arrowhead Trail remains unevaluated for this undertaking. It is 

assumed NRHP eligible for the purposes of this undertaking. The segment would not be impacted. The 

remaining (newly-identified) 27 built environment resources within the APE in Nevada required 

evaluation for NRHP eligibility. After evaluating or updating documentation of these properties, FRA 

determined that none of the remaining properties within the APE were eligible for listing in the NRHP

(ICF and HNTB 2022b). The NV SHPO concurred with FRA’s findings on December 6, 2021.35

The four eligible properties within the APE that were previously recorded and determined eligible for 

NRHP listing with SHPO concurrence include: the Jean Underpass and LADWP’s Bolder Dam–Los Angeles 

Transmission Lines, Boulder Line 1, Boulder Dam Line 2, and Boulder Line 3. Architectural historians 

resurveyed the Jean Underpass and the segments of the Boulder Dam–Los Angeles Transmission Lines 

within the APE north of Primm. FRA has determined that the Jean Underpass and the segments of 

Boulder Lines 1, 2, and 3 within the APE retain historic integrity and continue to convey the properties’ 

significance but given the lack of physical evidence in the APE, the Jean Underpass and the segments of 

Boulder Dam Lines 1, 2, and 3 within the APE are considered eligible for NRHP listing and the 

unevaluated segment of the Arrowhead Trail within the APE will be treated as NRHP eligible for the 

purposes of this undertaking, only. 

Project construction would directly impact a portion of the Project area, which is referred to as the APEADI. Damage, displacement, or removal of artifacts within the APE-ADI is considered an impact. The 

impact area (the APE-ADI) is small relative to the overall APE and the Project area. The Project 

modifications would not result in substantial changes in the evaluation of impacts to archaeological or 

historic built environment resources from construction of the Project as described in the 2011 

DesertXpress EIS or the September 2020 Reevaluation. The execution of a PA accounts for the 

archaeological impacts and treatment for future changes to the APE and project design modifications as 

well as the inadvertent discovery of buried cultural deposits. The DesertXpress EIS and September 2020 

Reevaluation outlined the process for Section 106 compliance first through the 2011 PA, and then 

through FRA’s planned efforts to continue to advance the Section 106 compliance process through 

consultation and identification, evaluation, and assessment effects efforts for the September 2020 

Reevaluation. Subsequently, full historic property inventories have been completed for the APE-ADI and 

APE-AII, including an assessment of effects, and treatment measures for avoidance and mitigation of 

34 McBride, Terri. 2001. National Register of Historic Places Registration Form: Old Spanish Trail/Mormon Road Historic District. 

U.S. Department of the Interior, National Park Service. Accessed: May 2022.

35 Nevada SHPO. 2021. Letter to Katherine Zeringue, Federal Preservation Officer, Federal Railroad Administration. 
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adverse effects, as documented in the 2023 PA and associated Historic Properties Treatment Plan 

(HPTP). The PA and HPTP also provide for treatment of inadvertent discoveries.

4.7.3 MITIGATION MEASURES

The following mitigation measures established in the DesertXpress EIS and revised in the September 

2020 Reevaluation, as well as execution of the PA for the Project and conformance with its terms would 

avoid, minimize, or resolve adverse effects to cultural resources:

• Mitigation Measure CR-1: Avoidance of Archaeological Resources

• Mitigation Measure CR-2: Evaluation

• Mitigation Measure CR-3: Treatment

• Mitigation Measure CR-4: Monitoring

• Mitigation Measure CR-5: Preconstruction Meeting and Worker Awareness Training

• Mitigation Measure CR-6: Human Remains and Stop Work Requirement

• Mitigation Measure CR-7: Annual Reporting

• Mitigation Measure CR-8: Quarterly Reporting

4.8 HYDROLOGY AND WATER QUALITY

This section evaluates whether the Project modifications would result in substantial changes to the 

evaluation of effects to hydrology and water quality discussed in the DesertXpress EIS and September 

2020 Reevaluation. As previously established in the September 2020 Reevaluation, the September 2020 

Project modifications did not result in substantial changes to the evaluation of hydrology and water 

quality disclosed in the DesertXpress EIS.

The modified Project rail alignment follows the I-15 freeway corridor and generally encounters the same 

regions evaluated in the September 2020 Reevaluation and DesertXpress EIS. Therefore, the 

DesertXpress EIS discussions of affected environment remain applicable to the modified Project 

footprint.

4.8.1 REGULATORY UPDATES

No updates to state or local regulation that pertain to the modified Project’s effects on hydrology and 

water quality have occurred since the September 2020 Reevaluation. Additionally, no changes in the 

physical environment have occurred since the September 2020 Reevaluation that would result in 

substantial changes to the evaluation of hydrology and water quality for the modified Project.

The environmental analysis conducted in the DesertXpress EIS, the September 2020 Reevaluation, and 

this Reevaluation evaluates effects of hydrology, water quality, drainage patterns, and stormwater 

runoff to aquatic resources throughout the Project area regardless of WOTUS jurisdiction. While the 

definition of WOTUS has changed since publication of the DesertXpress EIS, including the EPA and 

USACE’s 2015 Rule, 2020 Rule, and 2021 Rule, these regulatory updates do not affect the evaluation of 

aquatic feature affected by the project as the evaluation is not specific to WOTUS and considers all 

aquatic resources within the project area.
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4.8.2 EFFECTS ANALYSIS

AQUATIC FEATURES WITHIN THE MODIFIED FOOTPRINT

The DesertXpress EIS and September 2020 Reevaluation identified aquatic resources that would be 

affected by implementation of the Project. The Mojave River and its adjacent wetlands are the only

Waters of the United States (WOTUS) in proximity to the modified Project area. Segments of the Mojave 

River were delineated south of Barstow and south of Basin Road, but no wetlands were delineated in 

association of these river segments. The only wetlands delineated are associated with the Mojave River 

crossing at Victorville, which is south of the Victor Valley Station. The various desert ephemeral stream 

channels and man-made ditches the modified Project crosses in California are non-jurisdictional waters. 

For the Nevada segments of the modified Project area, the USACE has verified that all delineated 

aquatic resource features in the Jean, Roach and Ivanpah Dry Lake watersheds are isolated nonjurisdictional waters. The resources are non-jurisdictional either because (1) the delineated features are 

isolated waters in closed basin watersheds that have no significant nexus to interstate commerce or 

Traditional Navigable Waters, or (2) the delineated waters are ephemeral stream channels that were 

exempt from regulation.

36

Thus, the Project modifications would not result in substantial changes in the evaluation of effects to 

aquatic resources of the DesertXpress EIS or September 2020 Reevaluation.

WATER QUALITY

The DesertXpress EIS and September 2020 Reevaluation identified that construction-period water 

quality effects would result from increased erosion and sedimentation during grading and excavation, as 

well as from accidental spills or improper storage of hazardous materials. Additionally, operational 

water quality effects would result from polluted stormwater runoff generated at the stations and 

maintenance facilities.

The modified Project would not change the September 2020 Reevaluation conclusions regarding water 

quality effects because the modifications to the rail alignment and ancillary features, and construction

and operations activities would occur within a similar area and scope and would not result in new 

significant effects to water quality. The DesertXpress EIS and September 2020 Reevaluation concluded 

that Mitigation Measures HYD-1 through HYD-4 would minimize adverse effects to hydrological 

resources during construction and operation. These mitigation measures would still apply to the 

modified Project. Therefore, the modified Project would not result in substantial changes in the 

evaluation of water quality impacts of the DesertXpress EIS or September 2020 Reevaluation.

36 At the time of the analysis for the September 2020 Reevaluation the 2020 Navigable Waters Rule was in effect, which was 

later vacated. On September 3, 2021, EPA and USACE announced they have halted implementation of the 2020 Rule and will 

interpret the “waters of the United States” consistent with the pre-2015 regulatory regime. On March 20, 2023, the 2020 Rule 

was replaced by the 2023 Navigable Waters Rule. This analysis was conducted in October 2022, consistent with the pre-2015 

regulatory regime and in coordination with USACE. 
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ALTERATION OF EXISTING DRAINAGE PATTERNS

Construction

The DesertXpress EIS determined that Project construction would potentially alter drainage patterns 

through the exposure of soils susceptible to erosion during earthmoving activities. The September 2020 

Reevaluation determined the September 2020 modifications would require a slightly shorter 

construction period and less earthmoving activity since the overall Project footprint would be reduced. 

The modified Project includes an additional 202 TCAs, within the Caltrans/NDOT ROW, adding 

approximately 1,492 acres of temporary footprint since the September 2020 Reevaluation. As the 

project design has progressed Brightline has sought input from contractors who have identified the need 

for additional temporary construction areas for material laydown and access.

37 These newly considered 

TCAs would be located within Caltrans/NDOT ROW along the modified alignment, which would follow 

the I-15 freeway corridor as previously evaluated in the DesertXpress EIS and September 2020 

Reevaluation. Mitigation Measures HYD-2 and HYD-9 would still be applied to reduce impacts on existing 

drainage patterns during construction. Therefore, the Project modifications would not result in 

substantial changes in the evaluation of alteration to existing drainage patterns from construction 

compared with the DesertXpress EIS or September 2020 Reevaluation.

Operation

The DesertXpress EIS determined that the alignment and ancillary features, including proposed 

paralleling sites, would cross numerous ephemeral hydrological features between Apple Valley and Las 

Vegas. The modified alignment would not change the September 2020 Reevaluation conclusions 

regarding the alteration of drainage patterns because the modified alignment would still follow the I-15 

freeway corridor, relocating the alignment in Segment 1 and Segment 5 from being adjacent to the I-15 

freeway into the I-15 freeway median. New and modified ancillary features, including highway ramp 

realignments, emergency crossovers, roadwork, and culverts would be located within the I-15 freeway 

ROW. No modifications to the Victor Valley Station site, Warm Springs Station site, or paralleling sites 

are proposed. Mitigation Measure HYD-5 would still be applied to reduce impacts from the modified 

Project on existing drainage patterns. The Project modifications would not result in substantial changes 

in the evaluation of alteration to existing drainage patterns from operations compared with the 

DesertXpress EIS or September 2020 Reevaluation.

FLOOD FLOW IMPEDIMENT

The DesertXpress EIS determined that portions of alignment and ancillary facilities would traverse areas 

with a 1 percent annual chance of experiencing flooding, which could impede or redirect flood flows. 

The September 2020 Reevaluation established most of the 1 percent annual chance floodplain 

boundaries did not change since publication of the DesertXpress EIS, although the Warm Springs Station 

was found to overlap with a 1 percent annual chance floodplain that was not previously evaluated.

37 Not including temporary footprint required for construction of the Sloan VMF. The Sloan VMF is discussed in Section 5.0.
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Since the September 2020 Reevaluation, the 1 percent annual chance floodplain boundaries have not 

changed.38, 39Modified mainline ancillary features located along the alignment, including highway ramp 

realignments, emergency crossovers, roadwork, and culverts, would encounter previously evaluated 1

percent annual chance floodplains in proximity to the I-15 freeway. The Cemex rail connection south of 

Victor Valley Station would not encounter designated 1 percent annual chance flood plains. Mitigation 

Measures HYD-6 and HYD-7 would still be required to minimize impacts from floodplains. The Project 

modifications would not result in substantial changes in the evaluation of floodplains of the 

DesertXpress EIS or September 2020 Reevaluation.

ADDITIONAL SOURCES OF STORMWATER RUNOFF

Construction

The DesertXpress EIS determined that Project construction could introduce new sources of polluted 

stormwater runoff through the release of construction-related chemicals, especially from TCAs. The 

September 2020 Reevaluation established the reduction of the overall 2020 Project footprint compared 

to the DesertXpress EIS Project footprint would allow for a slightly shorter construction period and a 

reduction in the use of construction-related chemicals. Reduction of the intensity of the construction 

activities during the period would reduce the potential for chemical releases by shortening the amount 

and time chemicals would be stored and used within the construction footprint, resulting in a beneficial 

effect.

The overall modified Project footprint would not significantly change from the footprint evaluated in the 

September 2020 Reevaluation, and thus the intensity of the construction activities, which could affect

the potential for chemical releases and the amount and time chemicals would be stored and used within 

the construction footprint, would not substantially differ. Mitigation Measures HYD-2, HYD-3, and HYD-4 

would still be applied to reduce impacts from chemical releases during construction. The Project 

modifications would not result in substantial changes in the evaluation of stormwater runoff during 

construction, compared with the DesertXpress EIS or September 2020 Reevaluation.

Operation

The DesertXpress EIS determined that new impervious surfaces at the station and maintenance facilities 

could produce increased stormwater runoff. The modified Project would not change the September 

2020 Reevaluation’s conclusions regarding polluted runoff because the quantity of impervious surface 

areas included in the modified Project would not substantially differ from the surface areas evaluated in 

the September 2020 Reevaluation or DesertXpress EIS. Therefore, the Project modifications would not 

result in substantial changes in the evaluation of stormwater runoff during operations, compared with 

the DesertXpress EIS or September 2020 Reevaluation.

38 California Department of Water Resources. 2022. Best Available Map. https://gis.bam.water.ca.gov/bam/. Accessed: April 

2022.

39 Federal Emergency Management Agency. 2021. FEMA Flood Map Service Center. https://msc.fema.gov/portal/home. 

Accessed: April 2022.
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REDUCTION IN GROUNDWATER AVAILABILITY

Mitigation Measure HYD-10, developed in the DesertXpress EIS and revised in the September 2020 

Reevaluation, would still apply to the Project, which would require water supply for construction, 

operation, and maintenance activities be obtained from existing water purveyors instead of surface or 

groundwater resources. Therefore, the Project modifications would not result in substantial changes in 

the evaluation of groundwater availability of the DesertXpress EIS or September 2020 Reevaluation.

WATERS OF THE UNITED STATES

The DesertXpress EIS determined that the alignment would cross numerous ephemeral hydrological 

features between Apple Valley and Las Vegas. The Mojave River and its adjacent wetlands are the only 

WOTUS in proximity to the modified Project. Segments of the Mojave River were delineated south of 

Barstow and south of Basin Road, but no wetlands were delineated in association of these river 

segments. The only wetlands delineated are associated with the Mojave River crossing at Victorville, 

which is south of the Victor Valley Station. The various desert ephemeral stream channels and manmade ditches the modified Project crosses in California are non-jurisdiction waters not currently subject 

to the USACE’s permitting regulations. There are no jurisdictional waters located in Nevada that would 

be affected by the Project.

Mitigation Measure HYD-5 would still apply to reduce hydraulic impacts where the modified Project 

alignment and ancillary facilities encounter ephemeral drainages. Therefore, the Project modifications 

would not result in substantial changes in the evaluation of WOTUS impacts of the DesertXpress EIS or 

September 2020 Reevaluation.

4.8.3 MITIGATION MEASURES

The following mitigation measures established in the DesertXpress EIS and revised in the September 

2020 Reevaluation would avoid adverse effects to hydrology and water quality:

▪ Mitigation Measure HYD-1: Incorporate Site-Specific Water Treatment Devices

▪ Mitigation Measure HYD-2: Implement Construction-Related Best Management Practices

▪ Mitigation Measure HYD-3: Comply with the National Pollutant Discharge Elimination System 

(NPDES) Construction General Permit

▪ Mitigation Measure HYD-4: Implement Spill Prevention, Control, and Countermeasure Plan

▪ Mitigation Measure HYD-5: Proper Design of Drainage Systems

▪ Mitigation Measure HYD-6: Reduce Encroachment into the 100-Year Floodplain.

▪ Mitigation Measure HYD-7: No Storage of Construction Equipment or Materials within the 100-Year 

Floodplain

▪ Mitigation Measure HYD-9: Minimize Impacts of Temporary Construction Areas on Water Resources

▪ Mitigation Measure HYD-10: Minimize Impacts on Water Availability

▪ Mitigation Measure BIO-1: Conduct Mandatory Environmental Awareness Training Program

▪ Mitigation Measure BIO-3: Conduct Construction Monitoring

▪ Mitigation Measure BIO-5: Confine Construction Equipment to a Designated Work Zone (Including 

Access Roads) at Each Project Site

▪ Mitigation Measure BIO-19: Construct Exclusion Fencing, Culverts to Sustain Hydrologic Function, 

and Provide Wildlife Crossings
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4.9 GEOLOGY AND SOILS 

This section evaluates whether the Project modifications would result in substantial changes to the 

evaluation of effects to geology and soils discussed in the DesertXpress EIS and September 2020 

Reevaluation. As previously established in the September 2020 Reevaluation, the September 2020 

Project modifications did not result in substantial changes to the evaluation of geology and soils

disclosed in the DesertXpress EIS.

4.9.1 REGULATORY UPDATES

No updates to Federal, state, or local regulations governing geological hazards have occurred since the 

September 2020 Reevaluation that would pertain to the Project. Additionally, no changes in the physical 

environment have occurred since the September 2020 Reevaluation that would result in substantial 

changes to the evaluation of geological hazards for the modified Project. 

4.9.2 EFFECTS ANALYSIS

SURFACE FAULT RUPTURE AND GROUND SHAKING

The DesertXpress EIS determined the hazards of fault rupture and ground shaking hazards depend on 

the Project location relative to active faults. The modified Project would not change the conclusions 

regarding surface fault rupture and ground shaking because the Project modifications do not 

substantially change the location of the Project in relation to active faults analyzed in the DesertXpress 

EIS. No new faults have been identified in the Project region. Mitigation Measures GEO-1 and GEO-2 

would still apply to reduce impacts from these seismic hazards. Thus, the Project modifications would 

not result in substantial changes in the evaluation of surface fault rupture and ground shaking impacts 

of the DesertXpress EIS or September 2020 Reevaluation.

LIQUEFACTION, SETTLEMENT, CORROSIVE SOILS, EXPANSIVE SOILS, LANDSLIDES, AND SHALLOW 

GROUNDWATER

The DesertXpress EIS determined that soil hazard potential depends on soil composition and depth to 

groundwater, which can affect the foundation and design of overlying structures. Soil moisture content 

is the chief factor associated with liquefaction, corrosive soils, and expansive soil risks, and can 

exacerbate hazards related to settlement and landslides. Thus, shallow groundwater may increase soil 

hazard potential.

The modified Project includes new footprint for highway ramp realignments and modifications, 

emergency crossovers, TCAs, Cemex connection, and modifications to portions of the alignment along 

Segments 1 and 5. However, the modified Project would not change the conclusions regarding soil 

hazards because these areas of new footprint would be near areas previously analyzed in the 

DesertXpress EIS and September 2020 Reevaluation, encountering similar soil and groundwater 

conditions. Additionally, Mitigation Measures GEO-3, GEO-5, GEO-6, GEO-7, and GEO-10 would still 

apply to address the need for site-specific evaluation of soil and groundwater conditions. Thus, the 

Project modifications would not result in substantial changes in the evaluation of liquefaction, 

settlement, corrosive soil, expansive soil, landslide, or shallow groundwater impacts of the DesertXpress 

EIS or September 2020 Reevaluation.
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DAM INUNDATION

The DesertXpress EIS identified the Mojave River and surrounding lands as subject to potential 

inundation from dam failure at Lake Arrowhead and Silverado Lake. These waterbodies are located 

upstream of the Project. Current dam inundation maps do not exist for these water bodies. However, 

the Federal Emergency Management Agency’s flood insurance maps for the Project vicinity provide 

mapping of potential flooding in the Project region. The modified Project would not change the 

September 2020 Reevaluation conclusions regarding dam inundation because the risk of flooding along 

the Mojave River and the rail alignment’s location in relation to flood-prone areas has not changed since 

the September 2020 Reevaluation.

40 The revised alignment and ancillary facilities would still encounter 

the Lake Arrowhead and Silverado Lake dam inundation areas. The Cemex rail connection would not 

encounter areas prone to flooding. Mitigation Measure GEO-4 would still be applied in the areas 

identified as susceptible to dam inundation. Thus, the Project modifications would not result in 

substantial changes in the evaluation of dam inundation impacts of the DesertXpress EIS or September 

2020 Reevaluation.

GROUND FISSURES

The Project could encounter unmapped, unidentified, or newly formed ground fissures. The 

DesertXpress EIS identified the Las Vegas area as susceptible to ground fissures. The Cemex rail 

connection would add approximately 2 miles of new track along the I-15 freeway. However, Mitigation 

Measure GEO-12 would still be applied to reduce the impact of ground fissures, and the Project 

modifications would not result in substantial changes in the evaluation of ground fissure impacts of the 

DesertXpress EIS or September 2020 Reevaluation.

CALICHE/HARD ROCK EXCAVATION

Sediments of certain ages, such as quaternary deposits in southern Nevada, have the potential to form 

caliche layers. Hard rock layers occur across the Project vicinity and footprint. The DesertXpress EIS 

identified areas of hard rock or caliche along the entire corridor. The modified Project would not change 

the DesertXpress EIS or September 2020 Reevaluation conclusions regarding caliche and hard rock 

excavation because the Project would remain of a similar scope and geographic location. Thus, the 

Project modifications would not result in substantial changes in the evaluation of caliche and hard rock 

excavation impacts of the DesertXpress EIS or September 2020 Reevaluation.

4.9.3 MITIGATION MEASURES

The following mitigation measures established in the DesertXpress EIS and revised in the September 

2020 Reevaluation would avoid adverse geology and soils effects. 

▪ Mitigation Measure GEO-1: Surface Fault Rupture

▪ Mitigation Measure GEO-2: Ground Shaking

▪ Mitigation Measure GEO-3: Liquefaction

▪ Mitigation Measure GEO-4: Dam Inundation

▪ Mitigation Measure GEO-5: Settlement

▪ Mitigation Measure GEO-6: Corrosive Soils

40 California Department of Water Resources. 2022. Best Available Map. Available: https://gis.bam.water.ca.gov/bam/. 

Accessed: April 2022.
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▪ Mitigation Measure GEO-7: Expansive Soils

▪ Mitigation Measure GEO-8: Landslides

▪ Mitigation Measure GEO-9: Caliche/Hard Rock Excavation

▪ Mitigation Measure GEO-10: Shallow Groundwater

▪ Mitigation Measure GEO-12: Ground Fissures

4.10 PALEONTOLOGICAL RESOURCES

This section evaluates whether the Project modifications would result in substantial changes to the 

evaluation of effects to paleontological resources (e.g. fossils) discussed in the DesertXpress EIS and

September 2020 Reevaluation. As previously established in the September 2020 Reevaluation, the 

September 2020 Project modifications did not result in substantial changes to the evaluation of 

paleontological impacts disclosed in the DesertXpress EIS.

4.10.1 REGULATORY UPDATES

No updates to Federal, state, or local regulations governing paleontological resources have occurred 

since the September 2020 Reevaluation that would pertain to the Project. Additionally, no changes in 

the physical environment have occurred since the September 2020 Reevaluation that would result in 

substantial changes to the evaluation of paleontological resources for the modified Project. 

4.10.2 EFFECTS ANALYSIS

This paleontological resource evaluation focuses on Project modifications that would result in new or 

previously unanalyzed footprint. The DesertXpress EIS concluded that large areas of Project footprint, 

including the entirety of the rail alignment, would encounter areas of high paleontological sensitivity. 

The modified Project would only encounter geologic units that were previously evaluated in the 

DesertXpress EIS. Therefore, the Project modifications would result in similar paleontological resource 

effects. 

Although several types of ancillary features would be modified and relocated, the scale and severity of 

impacts from these facilities would be minor. While the Cemex rail connection, modified emergency 

crossovers, highway ramp realignments, and TCAs would be constructed within footprint areas not 

considered in the DesertXpress EIS or September 2020 Reevaluation, these new areas would be minimal 

and would be constructed over previously evaluated geologic units.

The entire rail alignment would still encounter areas of high paleontological sensitivity. However, as the 

modified alignment would be constructed in the same general location as the alignment analyzed in the 

DesertXpress EIS and September 2020 Reevaluation, it would not substantially increase the Project 

footprint underlain by areas of high paleontological sensitivity. Mitigation measures CR-7 through CR-13 

would still apply to minimize impacts on paleontological resources from the Project. Thus, the Project 

modifications would not result in substantial changes in the evaluation of paleontological impacts of the 

DesertXpress EIS or September 2020 Reevaluation.

4.10.3 MITIGATION MEASURES

The following mitigation measures established in the DesertXpress EIS and revised in the September 

2020 Reevaluation would avoid adverse effects to paleontological resources:

▪ Mitigation Measure CR-7: Annual Reporting
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▪ Mitigation Measure CR-8: Quarterly Reporting

▪ Mitigation Measure CR-9: Further Evaluation of Geologic Units

▪ Mitigation Measure CR-10: Preconstruction Meeting and Worker Awareness Training

▪ Mitigation Measure CR-11: Paleontological Monitoring

▪ Mitigation Measure CR-12: Stop Work Requirement

▪ Mitigation Measure CR-13: Fossil Recovery and Curation

4.11 HAZARDOUS MATERIALS

This section evaluates whether the Project modifications would result in substantial changes to the 

evaluation of effects to hazardous materials discussed in the DesertXpress EIS and September 2020 

Reevaluation. As previously established in the September 2020 Reevaluation, the September 2020 

Project modifications did not result in substantial changes to the hazardous materials impacts disclosed 

in the DesertXpress EIS.

4.11.1 REGULATORY UPDATES

No Federal regulatory updates pertaining to hazardous materials have occurred since the September 

2020 Reevaluation. No changes in the physical environment have occurred since the September 2020 

Reevaluation that would result in substantial changes to the evaluation of hazardous materials for the 

modified Project. State and local agencies that regulate hazardous materials may have updated 

regulations regarding hazardous material management. Mitigation measures identified in the 

DesertXpress EIS and updated in the September 2020 Reevaluation require the project to comply with 

State and local regulations pertaining to hazardous materials including contaminated soil and materials 

handling. As such these State and local regulatory updates would not result in substantial changes in 

the evaluation of hazardous materials impacts disclosed in the September 2020 Reevaluation. Effects 

Analysis

SITES OF ENVIRONMENTAL CONCERN

Sites of environmental concern include hazardous material release sites, railroad corridors, and freeway 

corridors that could contain contaminated soil or groundwater. The DesertXpress EIS determined that 

construction near sites of environmental concern could expose or mobilize in-situ contamination. 

The modified rail alignment would be within the I-15 freeway ROW in the median or immediately 

adjacent to the roadway travel lanes. As originally evaluated in the DesertXpress EIS, ancillary features, 

including roadway improvements, highway ramp realignments, emergency crossovers, and utility 

corridors would be located along existing roadways and utility corridors. Existing transportation and 

utility corridors through rural and urban communities along the I-15 freeway were previously evaluated 

for the potential to encounter hazardous materials. 

The modified mainline ancillary features, including the Cemex rail connection, may encounter new sites 

of environmental concern. However, the modified Project footprint has not changed substantially, and 

therefore such sites would be unlikely to result in new types or higher quantities of hazardous material 

effects (such as the exposure or mobilization of in-situ soil or groundwater contamination) from those

evaluated in the DesertXpress EIS or September 2020 Reevaluation. The DesertXpress EIS also 

developed Mitigation Measures HAZ-2 and HAZ-4 to reduce potential hazardous material impacts 

associated with contamination encountered during Project construction, which would still apply to the 
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Project. Thus, the Project modifications would not result in substantial changes in the evaluation of sites 

of environmental concern impacts of the DesertXpress EIS or September 2020 Reevaluation.

UNIDENTIFIED HAZARDOUS MATERIALS

The DesertXpress EIS determined that the Project could encounter previously unidentified hazardous 

materials during construction. The modified Project would not change the conclusions regarding 

unidentified hazardous materials because Project modifications would be constructed in similar 

locations as analyzed in the DesertXpress EIS and September 2020 Reevaluation. Additionally, since the 

modified Project footprint has not changed substantially, the scale, location, and severity of impacts 

from unidentified hazardous materials would be similar to those previously identified in the 

DesertXpress EIS and September 2020 Reevaluation. Furthermore, Mitigation Measures HAZ-3 and HAZ4 would still be applied to address risks associated with unidentified hazardous materials. Thus, the 

Project modifications would not result in substantial changes in the evaluation of unidentified hazardous

material impacts of the DesertXpress EIS or September 2020 Reevaluation.

BUILDINGS CONSTRUCTED BEFORE 1980

The DesertXpress EIS concluded that Project construction could require the demolition of structures 

built before 1980, which could mobilize hazardous materials such as lead-based paint and asbestoscontaining materials. Project modifications would reduce this potential impact since the modified rail 

alignment would be located predominantly within the vacant I-15 freeway median or ROW, which would 

reduce the need for demolition. However, demolition of infrastructure, including bridges and elements 

associated with roadway reconstruction areas, would be required throughout the modified Project 

footprint. Mitigation Measure HAZ-1 and HAZ-4 would still be applied to reduce potential impacts from 

this demolition. Thus, the Project modifications would not result in substantial changes in the evaluation 

of impacts from buildings constructed before 1980 of the DesertXpress EIS or September 2020 

Reevaluation.

NATURALLY OCCURRING ASBESTOS AND ERIONITE

Naturally occurring asbestos (NOA) and erionite are naturally-occurring hazardous materials with the 

potential to occur in the Project vicinity that were not considered in the DesertXpress EIS but were 

evaluated in the September 2020 Reevaluation. NDOT informed FRA that the presence of NOA could be 

found in certain rock types present in Nevada, given NDOT’s knowledge of projects that have occurred 

since the DesertXpress EIS. 

The September 2020 Reevaluation assessed two sections of the September 2020 Project alignment 

overlaying rock types with potential to contain NOA and erionite. The first section was at the south end 

of Ivanpah Valley south of Jean, which exhibited a low-to-moderate risk for NOA, and the second section 

was located approximately three miles north of Jean, which exhibits a moderate-to-high risk for erionite.

Based on these findings, NOA and erionite were determined to be unlikely to occur within the 

September 2020 Project footprint. These findings would remain valid for the modified Project as the 

modified Project alignment would still be located in these areas. Thus, the Project modifications would 

not result in substantial changes in the evaluation of impacts from naturally occurring asbestos and 

erionite of the September 2020 Reevaluation.
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4.11.2 MITIGATION MEASURES

The following mitigation measures identified in the DesertXpress EIS would avoid adverse hazardous 

material effects:

▪ Mitigation Measure HAZ-1: Structures Built Prior to 1980

▪ Mitigation Measure HAZ-2: Contaminated Soil and/or Groundwater

▪ Mitigation Measure HAZ-3: Previously Unidentified Hazardous Materials

▪ Mitigation Measure HAZ-4: Hazardous Material Disposal

▪ Mitigation Measure HAZ-5: Operationally Generated Hazardous Materials

4.12 AIR QUALITY AND GLOBAL CLIMATE CHANGE

This section evaluates whether the Project modifications would result in substantial changes to the 

evaluation of effects on air quality and global climate change discussed in the DesertXpress EIS and 

September 2020 Reevaluation. As previously established in the September 2020 Reevaluation, the 

September 2020 Project modifications resulted in fewer criteria pollutants and greenhouse gas (GHG) 

emissions during construction and operation compared to the levels of emissions identified in the 

DesertXpress EIS due to reductions in proposed construction activities and the overall Project footprint. 

The modified Project would still be in both the Mojave Desert Air Basin (MDAB)in California and the 

Clark County Area in Nevada. The characterization of these two air basins is consistent with the 

September 2020 Reevaluation, except for slight changes to basin ambient air quality. However, the 

Federal attainment statuses for these two air basins have not changed. The MDAB and Clark County 

Area remain designated Federal Non-attainment for ozone, and the MDAB also remains designated nonattainment for respirable particulate matter (PM10).41

 

4.12.1 REGULATORY UPDATES

No updates to Federal, California state, or local regulations that pertain to the modified Project’s effects 

on air quality and global climate change have occurred since the September 2020 Reevaluation, except

the passing of Nevada Senate Bill 448 in June 2021. This law advances the energy portfolio requirements 

for the state of Nevada, requiring utilities to forecast a path to achieve an 80 percent reduction in 

carbon dioxide emissions from 2005 levels by 2030, facilitating Nevada’s goal to reach 100 percent 

renewable electricity generation by 2050.42 This regulatory update would not result in substantial 

changes in the evaluation of effects to air quality and global climate change disclosed in the September 

2020 Reevaluation.

No changes in the physical environment have occurred since the September 2020 Reevaluation that 

would result in substantial changes to the evaluation of the modified Project’s effects on air quality and 

global climate change.

41 United States Environmental Protection Agency. 2022. Current Nonattainment Counties for all Criteria Pollutants. 

https://www3.epa.gov/airquality/greenbook/ancl.html. Accessed April 2022.

42 Nevada Legislature. 2021. SB448. https://www.leg.state.nv.us/App/NELIS/REL/81st2021/Bill/8201/Text. Accessed April 2022.
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4.12.2 EFFECTS ANALYSIS

CONSTRUCTION

The modified Project would not result in significant changes to the total rail alignment length or miles of 

elevated and at-grade track disclosed in the September 2020 Reevaluation since the alignment 

modifications would only involve relocating the rail alignment from being adjacent to the I-15 freeway 

to the I-15 freeway median at Segment 1 and Segment 5. The modified Project is still anticipated to take 

approximately three years to construct, and the level of construction effort and intensity needed to 

construct the modified Project would not change from those disclosed in the September 2020 

Reevaluation. Compared to the Project evaluated in the DesertXpress EIS, there would still be

substantial reductions in construction emissions due to reduced elevated alignment and the elimination 

of tunneling. The resulting reduced level of construction activity and intensity would result in fewer air 

pollutants and GHG emissions.

Emissions associated with the modified Project would be temporary and would cease when construction 

activities are complete. Since the emissions intensity of equipment and trucks varies by year and trends

down over time due to fleet turnover (i.e., emission factors for construction equipment were higher in 

2020 than current emissions expected in 2022), emissions from individual pieces of off-road equipment, 

passenger vehicles, and trucks is expected to be cleaner and emit fewer criteria pollutants and GHGs 

during construction of the modified Project. Additionally, continuous updates to federal and state plans, 

policies, regulations, and Eos are still being introduced that clarify new, or expand upon previous air 

quality and GHG emission reduction goals, such as Nevada Senate Bill 448 (see Section 4.12.1). The 

benefits of these regulations and policies to the emissions generated during modified Project 

construction would be realized throughout the construction period. Additionally, Mitigation Measures 

AQ-1, AQ-3, and AQ-5 would still apply to reduce construction air quality effects from the Project. Thus, 

the Project modifications would not result in substantial changes in construction-period air quality and 

GHG emission impacts evaluated in the DesertXpress EIS or September 2020 Reevaluation.

OPERATION

Energy Demand Emissions

As disclosed in the September 2020 Reevaluation, service would start with 25 round trips per day but 

would escalate to a maximum of 49 round trips per day by the modified Project buildout year in 2042.

Based on the buildout level of train activity, annual electricity demand was evaluated to be 

approximately 162,753,500 kWh, and criteria pollutant and GHG emissions related to this level of 

electricity generation reduced when compared to the emissions evaluated in the DesertXpress EIS.

The anticipated annual electricity demand for the modified Project is not anticipated to change 

significantly from what was evaluated in the September 2020 Reevaluation, since the buildout level of 

operations and train activity would not differ substantially. Therefore, the Project modifications would 

not result in substantial changes in operational air quality or GHG emission impacts evaluated in the 

DesertXpress EIS or September 2020 Reevaluation.

Carbon Monoxide Concentrations

The September 2020 Reevaluation established carbon monoxide (CO) emissions factors and ambient 

background CO concentrations have decreased since the DesertXpress EIS assessment, and the modified 

Project would not result in operational CO hotspot formation conditions. Congestion at local 
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intersections surrounding the Victor Valley Station site and Warm Springs Station site were similar or 

below estimated congestion associated with the original Victorville and Las Vegas station locations. The 

modified Project does not include changes to the Victor Valley Station and Warm Springs Station 

footprints. Therefore, the Project modifications would not result in substantial changes in CO emission

impacts evaluated in the DesertXpress EIS or September 2020 Reevaluation.

4.12.3 MITIGATION MEASURES

The DesertXpress EIS identified no operational mitigation measures, as potential impacts were 

demonstrated to be less than significant under the fully electric technology option. Given that 

operational impacts for the Project, as currently modified, would be similar to the impacts determined 

in the DesertXpress EIS, no mitigation measures would be applied during Project operation.

The following mitigation measures established in the DesertXpress EIS and revised in the September 

2020 Reevaluation would avoid adverse air quality effects during construction:

▪ Mitigation Measure AQ-1: Fugitive Dust Control Plan during Construction to Meet MDAQMD Rule 

403.2 Requirements

▪ Mitigation Measure AQ-3: Fugitive Dust Control Plan during Construction to Meet Clark County DES 

Requirements

▪ Mitigation Measure AQ-5: Utilize additional means to reduce construction period emissions of air 

pollutants.

4.13 NOISE AND VIBRATION

This section evaluates whether the Project modifications would result in substantial changes to the 

evaluation of effects to noise and vibration sensitive receptors discussed in the DesertXpress EIS and 

September 2020 Reevaluation. As previously established in the September 2020 Reevaluation, the 

September 2020 Project modifications did not result in substantial changes to the evaluation of noise 

and vibration impacts disclosed in the DesertXpress EIS.

4.13.1 REGULATORY UPDATES

No updates to Federal, state, or local regulation that pertain to the modified Project’s effects on noise 

and vibration have occurred since the September 2020 Reevaluation. Additionally, no changes in the 

physical environment have occurred since the September 2020 Reevaluation that would result in 

substantial changes to the evaluation of noise and vibration for the modified Project.

4.13.2 EFFECTS ANALYSIS

CONSTRUCTION NOISE

The DesertXpress EIS evaluated 29 TCAs requiring 463 acres of temporary footprint located along the 

alignment between Victorville and Las Vegas. The Project evaluated in the September 2020 Reevaluation

included a subset of the TCAs evaluated in the DesertXpress EIS as well as locations previously 

designated for autotransformers in the DesertXpress EIS, totaling 30 TCAs. The Project modifications 

would require an additional 202 TCAs located along the alignment, adding approximately 1,492 acres of 

temporary footprint and would be located primarily within existing Caltrans/NDOT ROW immediately 

adjacent to permanent facilities to be constructed in the I-15 freeway corridor. These newly considered

TCAs would not result in new noise impacts as freeway traffic would continue to be the dominant noise 
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source. There are currently no sensitive receivers within the existing Caltrans/NDOT ROW, and thus the 

new TCAs added by the modified Project would not result in new moderate or severe noise effects on 

sensitive receivers. Additionally, construction techniques have not changed, and TCAs would be restored

and vacated upon completion of construction. Mitigation Measure NV-10 would still apply to minimize 

construction noise effects from the Project to sensitive receivers. The Project modifications would not 

result in substantial changes in the evaluation of construction noise impacts of the DesertXpress EIS or 

September 2020 Reevaluation.

CONSTRUCTION VIBRATION

As described above, the Project modifications would result in new TCAs that were not previously

evaluated. However, all newly considered TCAs would be located primarily within existing 

Caltrans/NDOT ROW immediately adjacent to permanent facilities to be constructed in the I-15 freeway 

corridor. As such, these newly considered TCAs would not result in new vibration impacts because 

construction techniques have not changed and there are currently no sensitive receivers within the 

existing Caltrans/NDOT ROW, and thus the new TCAs added by the modified Project would not result in 

new moderate or severe noise effects on sensitive receivers. Additionally, construction techniques have 

not changed, and TCAs would be restored and vacated upon completion of construction. Mitigation 

Measure NV-10 would still apply to minimize construction vibration effects from the Project to sensitive 

receivers. The Project modifications would not result in substantial changes in the evaluation of 

construction vibration impacts of the DesertXpress EIS or September 2020 Reevaluation.

HIGH-SPEED RAIL NOISE

The Project modifications would not result in additional moderate and severe noise effects at locations 

identified in the September 2020 Reevaluation. The Project modifications would relocate the rail 

alignment from the east side of the I-15 freeway into the I-15 freeway median for portions of Segments 

1 and 5. The September 2020 Reevaluation did not identify any noise impacts within the I-15 freeway 

median, since there were no sensitive receivers at these locations. There are currently no sensitive 

receivers within the I-15 freeway median, and thus the relocation of the modified Project alignment into 

the I-15 freeway median would not result in new moderate or severe noise effects on sensitive 

receivers. Mitigation Measures NV-1, NV-3, and NV-4 would still apply to minimize noise effects from 

high-speed rail operations. The Project modifications would not result in substantial changes in the 

evaluation of operational noise impacts of the DesertXpress EIS or September 2020 Reevaluation.
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TRAFFIC NOISE

There are no locations where the change in traffic conditions resulting from the Project modifications 

would result in potential traffic noise impacts, above the levels described in the September 2020 

Reevaluation, and therefore, FRA relied on the noise assessment conducted for the September 2020 

Reevaluation. The Project modifications include additional roadwork at the I-15 freeway northbound 

lane adjacent to the Victor Valley Station, the Dale Evans Parkway interchange accessing the I-15 

freeway southbound ramps, the I-15 freeway median widening at Segment 5, and the I-15 southbound 

lanes just south of the Sloan Road interchange. While roadwork may increase traffic volume a

substantial amount (3 dB or more) near Dale Evans Parkway; sensitive receivers are all located outside 

the 100-foot screening distances from where the modified roadwork would occur. Therefore, the 

Project modifications would not result in substantial changes in the evaluation of traffic noise impacts of

the DesertXpress EIS or September 2020 Reevaluation.

OPERATIONAL VIBRATION

Project vibration impacts were assessed on an absolute basis using the FRA criterion of 72 vibration 

decibels (VdB) for residential land uses for the DesertXpress EIS and September 2020 Reevaluation. The 

September 2020 Reevaluation concluded no vibration impacts would occur from Project operations. As 

described above, the Project modifications would relocate the rail alignment from the east side of the I15 freeway into the I-15 freeway median for portions of Segments 1 and 5. The Project modifications to 

the rail alignment would not result in new vibration impacts since these modifications would not be in 

closer proximity to existing sensitive receivers. The Project modifications would not result in substantial 

changes in the evaluation of operational vibration impacts of the DesertXpress EIS or September 2020 

Reevaluation.

4.13.3 MITIGATION MEASURES

The following mitigation measures established in the DesertXpress EIS and revised in the September 

2020 Reevaluation would avoid adverse effects from noise and vibration:

▪ Mitigation Measure NV-1: Noise Barriers

▪ Mitigation Measure NV-3: Building Sound Insulation

▪ Mitigation Measure NV-4: Property Acquisitions or Easements

▪ Mitigation Measure NV-10: Construction Noise and Vibration Measures

4.14 ENERGY

This section evaluates whether the Project modifications would result in substantial changes to the 

evaluation of effects from construction-related energy consumption, operational energy consumption, 

and peak-period electricity demand discussed in the DesertXpress EIS and September 2020 

Reevaluation. As previously established in the September 2020 Reevaluation, the September 2020 

Project modifications did not result in substantial changes to the evaluation of energy impacts disclosed 

in the DesertXpress EIS.

4.14.1 REGULATORY UPDATES

No updates to Federal, California state, or local regulations that pertain to the modified Project’s effects 

on energy have occurred since the September 2020 Reevaluation. The only relevant regulatory update 

since September 2020 is the passing of Nevada Senate Bill 448 in June 2021. This law advances the 
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energy portfolio requirements for the state of Nevada, requiring utilities to forecast a path to achieve an 

80 percent reduction in carbon dioxide emissions from 2005 levels by 2030, facilitating Nevada’s goal to 

reach 100 percent renewable electricity generation by 2050.

43 Regional transition from fossil fuels could 

result in a slightly lower proportional energy savings resulting from the Project; however, this would not 

result in substantial changes in the evaluation of energy impacts of the DesertXpress EIS or September 

2020 Reevaluation.

No changes in the physical environment have occurred since the September 2020 Reevaluation that 

would result in substantial changes to the evaluation of the modified Project’s effects on energy.

4.14.2 EFFECTS ANALYSIS

CONSTRUCTION-RELATED ENERGY CONSUMPTION

The DesertXpress EIS and September 2020 Reevaluation calculated construction-related energy 

consumption using energy intensity factors based on the number of track miles and stations. The 

DesertXpress EIS determined that Project construction would consume approximately 5.0 million British 

Thermal Units (MMBTU), whereas construction of the Project modifications under the September 2020 

Reevaluation would consume approximately 2.4 million MMBTU. It is not anticipated that the 

construction energy requirements of the modified Project would substantially differ from those 

disclosed in the September 2020 Reevaluation, since the miles of at-grade alignment, elevated 

alignment, and proposed station footprints have not changed. Thus, the Project modifications would not 

result in substantial changes in the evaluation of energy impacts from construction compared with the 

DesertXpress EIS or September 2020 Reevaluation.

OPERATIONAL ENERGY CONSUMPTION

Operational energy consumption compares the Project’s anticipated energy usage against the energy 

uses of other transportation modes along the Project corridor (e.g., automobiles). This evaluation 

calculates the reduction in VMT that would occur with implementation of the Project. The September 

2020 Reevaluation established the Project is anticipated to result in a net reduction of approximately 

502 million-mile VMT annually.

44 Estimates regarding annual ridership diverted from automobiles during 

the build out year have not changed under the Project modifications, and would still divert a substantial 

amount of automobiles to rail within the I-15 freeway corridor. The Project modifications would not 

result in substantial changes in the evaluation of operational energy consumption of the DesertXpress 

EIS or September 2020 Reevaluation.

PEAK-PERIOD ELECTRICITY DEMAND

Peak-period electricity demand represents the time of highest electricity usage within a specific region. 

The DesertXpress EIS evaluated the Project peak-period electricity demand by comparing the Project 

annual energy consumption against supply capacity estimates within the applicable regions assigned by 

the US Energy Information Administration’s (EIA) Electricity Market Modular (EMM). The EIA redefined 

the EMM Regions in 2011, after publication of the DesertXpress EIS. Project Segments in California were

43 Nevada Legislature. 2021. SB448. https://www.leg.state.nv.us/App/NELIS/REL/81st2021/Bill/8201/Text. Accessed April 2022.

44 VMT reduction associated with trips diverted from automobiles to rail assumed an estimated 8,061,000 passengers annually 

for the Project by build out year in 2042.
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within EMM Region 20 and Project Segments in Nevada are within EMM Region 21.45 Table 4-3 presents 

the electricity capacity projections for these respective regions. Assuming a maximum hourly peak 

energy demand of 44.2 MW by 2024 (the Project buildout year) the Project was found to utilize 

approximately 0.04 percent and 0.07 percent of the total regional energy demand, respectively.46 

Table 4-3 Regional Energy Demand (2019)47

Region 2017 2020 2023 2030 2040

Region 20 (CA) 73.42 GW 76.70 GW 74.44 GW 88.99 GW 105.73 GW

Region 19 (NV) 47.95 GW 47.64 GW 50.07 GW 54.63 GW 63.38 GW

As of June 2020, Project Segments in California are within EEM Region 22 and Project Segments in 

Nevada are within EMM Region 25.48 Table 4-4 presents the current electricity capacity for these 

regions. 

Table 4-4 Regional Energy Demand (2022)

49

Region 2021 2022 2023 2030 2040

Region 22 (CA) 43.52 GW 46.20 GW 49.26 GW 49.36 GW 52.37 GW

Region 25 (NV) 28.72 GW 29.21 GW 31.10 GW 37.21 GW 45.11 GW

It is assumed the Project modifications would not result in significant changes to operational energy use

since the length of the alignment and ridership projections (including train headways and average train 

capacity) remain consistent with the September 2020 Project. Thus, it is anticipated that the previously 

assumed maximum hourly peak energy demand of 44.2 MW from the September 2020 Reevaluation 

would not significantly change. Assuming all energy required for the Project is drawn from California, or 

from Nevada, the Project would utilize approximately 0.08 percent and 0.09 percent of the total 

regional energy demand, respectively. The Project would likely split the energy demand between 

California and Nevada, which would require lower proportions of energy in each region. Thus, the 

modified Project would not adversely impact regional energy supply. The Project modifications would 

not result in substantial changes in the evaluation of peak-period electricity demand impacts of the 

DesertXpress EIS or September 2020 Reevaluation.

45 U.S. Energy Information Administration. 2017. The electricity Market Module of the National Energy Modeling System: Model 

Documentation 2016. July 2017. https://www.eia.gov/outlooks/aeo/nems/documentation/electricity/pdf/m068(2016).pdf. 

Accessed October 2019.

46 Operational hourly peak demand calculations utilized 3-hour energy consumption for with 16-car electric trains. Calculations 

considered worst-case parameters; thus, realistic hourly peak demand is likely to be lower

47 U.S. Department of Energy, Energy Information Administration. 2019. Annual Energy Outlook 2019: Supplemental Tables 

(Table 57). http://www.eia.doe.gov/oiaf/aeo/supplement/pdf/sup_elec.pdf. Accessed October 2019.

48 U.S. Energy Information Administration. 2020. The electricity Market Module of the National Energy Modeling System: Model 

Documentation 2020. July 2020. https://www.eia.gov/outlooks/aeo/nems/documentation/electricity/pdf/m068(2020).pdf.

Accessed April 2022.

49 U.S. Department of Energy, Energy Information Administration. 2022. Annual Energy Outlook 2022: Supplemental Tables 

(Table 54.22 and Table 54.25). https://www.eia.gov/outlooks/aeo/tables_ref.php. Accessed October 2019.
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4.14.3 MITIGATION MEASURES

The DesertXpress EIS and September 2020 Reevaluation both determined mitigation measures would 

not be necessary because the Project would result in an overall reduction in total energy consumption. 

As the modified Project would still result in an overall reduction in total energy consumption, no 

mitigation measures would be applied.

4.15 BIOLOGICAL RESOURCES

This section evaluates whether the Project modifications would result in substantial changes to the 

evaluation of effects to biological resources discussed in the DesertXpress EIS and September 2020 

Reevaluation. As previously established in the September 2020 Reevaluation, the September 2020 

Project modifications generally reduced impacts to biological resources relative to the DesertXpress EIS. 

Refer to Attachment C, Biological Resources Technical Report, for further discussion of effects to 

biological resources in proximity to the modified Project.

4.15.1 REGULATORY UPDATES

Below describes changes to the regulatory environment for biological resources since the September 

2020 Reevaluation.

FRA informally consulted with the USFWS regarding the September 2020 Project modifications and on 

May 6, 2021, the USFWS concurred that re-initiation of formal consultation under Section 7 of the 

Endangered Species Act was not required (see Attachment B, USFWS Concurrence Letter, September 1, 

2023). The USFWS also acknowledged that Southern California Edison would apply to BLM for separate 

authorization for the construction of the two electrical substations and transmission lines that would 

supply power to the rail line. In addition, the USFWS issued revised desert tortoise protective measures 

for the Project’s Biological Opinion (FWS-SB-20B0244-21TA0969) based on the modified Project 2020 

footprint evaluated in the September 2020 Reevaluation. These revised protective measures were 

incorporated into the September 2020 Reevaluation. FRA determined, in consultation with USFWS, that 

the project changes have substantially reduced impacts on species listed as threatened or endangered 

and critical habitat, and no new impacts would occur as a result of the Project modifications that would 

require re-initiation of formal Section 7 consultation, and the Biological Opinion issued would apply to 

the Project, subject to the revised mitigation measures (see Attachment B). 

On October 15, 2019, the California Department of Fish and Wildlife (CDFW) received a petition from 

the Center for Biological Diversity to list the Western Joshua Tree (Yucca brevifolia) as threatened under 

the California Endangered Species Act (CESA). On September 24, 2020, CDFW published notice that the 

Western Joshua Tree is a candidate species as defined by Section 2068 of the Fish and Game Code. In 

the June 16, 2022, commission hearing to list the Joshua tree under CESA resulted in a tie. At its 

February 10, 2023 meeting in light of the introduction of the Western Joshua Tree Conservation Act, the 

Commission voted to continue its decision on listing western Joshua tree under CESA to a future 

meeting commission. 
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4.15.2 EFFECTS ANALYSIS

INTRODUCTION OR SPREAD OF INVASIVE, NON-NATIVE WEED SPECIES INTO NATURAL VEGETATION 

COMMUNITIES

The effects related to the introduction and spread of invasive, non-native weed species discussed in the 

DesertXpress EIS and the September 2020 Reevaluation would still apply to the modified Project 

footprint. The implementation of Mitigation Measure BIO 4 (avoid dispersal) from the DesertXpress EIS 

would reduce or mitigate adverse effects from noxious weeds, and the Project modifications would not 

result in substantial changes in the evaluation of invasive, non-native weed species impacts of the 

DesertXpress EIS or September 2020 Reevaluation.

LOSS OF OR DAMAGE TO NATIVE VEGETATION COMMUNITIES

The effects related to the loss of or damage to native vegetation communities, as described in the 

DesertXpress EIS, still apply to the modified Project footprint. The modified Project footprint would 

result in reduced acreages of permanent and temporary impacts on these vegetation communities 

relative to the DesertXpress EIS. Based on the vegetation mapping and application of removed impact 

areas and added impact areas since September 2020 Reevaluation, the modified Project footprint would 

permanently convert between 127 to 146 acres and temporarily affect between 670 to 710 acres of 

native vegetation communities. The sum of the modified Project 2022 footprint and the modified 

Project 2020 footprint results in approximately 1,280 acres of permanent impacts and approximately 

1,400 acres of temporary impacts, whereas the DesertXpress EIS estimated that the Preferred 

Alternative would permanently convert approximately 1,500 acres and temporarily affect 4,500 acres of 

native vegetation communities. In addition, most of the modified Project impacts now occur within or 

adjacent to the I-15 freeway ROW, which contains degraded quality native vegetation communities. 

Mitigation Measures BIO-5 (confine equipment), BIO-6 (revegetation), BIO-7 (retain topsoil), BIO-8 

(restore topography), BIO-9 (erosion control), BIO-18 (Nevada compensatory mitigation), and BIO-18 

(California compensatory mitigation) from the DesertXpress EIS would be implemented to avoid, 

minimize or mitigate adverse effects from loss of or damage to native vegetation communities. Thus, 

the Project modifications would not result in substantial changes in the evaluation of native community 

impacts of the DesertXpress EIS or September 2020 Reevaluation.

SENSITIVE VEGETATION COMMUNITIES

The effects related to the loss of sensitive vegetation communities, as described in the DesertXpress EIS, 

still apply to the modified Project footprint. A previously evaluated sensitive plant community, Joshua 

Tree Wooded Shrubland, is present within Segment 3 of the modified Project footprint. However, the 

acreage of permanent and temporary impacts on this sensitive vegetation community has been reduced 

substantially relative to the DesertXpress EIS analysis because the modified Project footprint is now 

primarily located within or adjacent to the I-15 freeway ROW. The DesertXpress EIS estimated that the 

Preferred Alternative would permanently convert approximately 84 acres and temporarily affect 194 

acres of Joshua Tree Wooded Shrubland. Based on the vegetation mapping, the modified Project 

footprint would reduce overall impact to the Joshua Tree Wooded Shrubland and result in significantly 

fewer permanent ( approximately 4.9 acres) and temporary (approximately 15.3 acres) impacts.

The DesertXpress EIS estimated that the Preferred Alternative would permanently convert 

approximately two acres and temporarily affect 13 acres of Mesquite Shrubland. The modified Project 
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footprint is no longer anticipated to permanently affect Mesquite Shrubland, however 2 acres of 

temporary impacts may occur.

Mitigation Measures BIO-5 (confine equipment), BIO-6 (revegetation), BIO 7 (retain topsoil), BIO-8 

(restore topography), BIO-9 (erosion control), BIO-10 (tree removal permit), BIO 11 (compensatory 

mitigation), and BIO-13 (pre-construction surveys) from the DesertXpress EIS would be implemented to 

reduce or mitigate adverse effects from loss of sensitive vegetation communities. Thus, the Project 

modifications would not result in substantial changes in the evaluation of sensitive vegetation 

community impacts of the DesertXpress EIS or September 2020 Reevaluation.

POTENTIAL EFFECTS ON SPECIAL-STATUS PLANT POPULATIONS

The effects related to construction and operational activities on special-status plant populations, as 

described in the DesertXpress DEIS, still apply to the modified Project footprint. The modified Project 

footprint minimizes adverse impacts on sensitive species identified in the DesertXpress EIS because 

most of the Project footprint is now within or adjacent to the I-15 freeway ROW, which provides little 

habitat for special-status plant species. The biological resources are degraded within the modified 

Project footprint due to the proximity to existing maintained roadway infrastructure. Special-status 

plant surveys were conducted within the Ivanpah Utility Corridor and the Sloan VMF site (see Section 

5.15.2 for discussion of the Sloan VMF effects analysis on biological resources). Special-status plants 

listed under the Endangered Species Act or designated sensitive by the BLM were not identified during 

the surveys. The implementation of Mitigation Measures BIO-5 (confine equipment), BIO-14 (avoid 

known populations), and BIO-15 (mitigation) from the DesertXpress EIS would be implemented to 

reduce or mitigate adverse effects on special-status plant populations, and the Project modifications 

would not result in substantial changes in the evaluation of special-status plant population impacts of 

the DesertXpress EIS or September 2020 Reevaluation.

POTENTIAL EFFECTS ON SPECIAL STATUS WILDLIFE

The modified Project footprint is now primarily located within the I-15 freeway ROW, which provides 

little to no habitat for special-status wildlife due to the proximity to existing maintained roadway 

infrastructure. The modified Project footprint would result in fewer acres of permanent and temporary 

impacts on wildlife habitat relative to the impacts evaluated in the DesertXpress EIS (refer to Section 

7.2.6 of Attachment C for further discussion of effects to special-status wildlife species and wildlife 

movement from implementation of the modified Project). Therefore, the Project modifications would 

not result in substantial changes in the evaluation of special-status wildlife impacts of the DesertXpress 

EIS or September 2020 Reevaluation.

POTENTIAL EFFECTS ON SPECIAL MANAGEMENT LANDS

The effects related to construction and operational activities on Special Management Lands, as 

described in the DesertXpress EIS, still apply to the modified Project footprint, though in a greatly 

reduced capacity now that the modified Project footprint would primarily be within the I-15 freeway 

corridor. The modified Project footprint would affect three types of Special Management Lands: USFWS 

critical habitat, BLM-administered public lands, and BLM ACECs. Table 7.2 3 and Table 7.2 4 in 

Attachment C show the permanent and temporary impacts from the DesertXpress EIS and the modified 

Project 2020 and 2022 footprints on Special Management Lands. 
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Although the modified Project footprint would intersect USFWS critical habitat and BLM ACECs, 

biological resource degradation has occurred in most areas where impacts would occur and no longer 

provide the habitat or unique value for which the area was designated. Each of these Special 

Management Lands are bound by I-15 freeway on one side or are bisected by I-15 freeway. Most of the 

modified Project footprint is within the I-15 freeway ROW, which is relatively degraded and subject to 

trash, routine roadway maintenance, recreational off highway vehicle (OHV) use, and shoulder 

disturbances from vehicles leaving the freeway. Thus, the Project modifications would not result in 

substantial changes in the evaluation of impacts to Special Management Lands of the DesertXpress EIS 

or September 2020 Reevaluation.

Critical Habitat

The SCE Utility Corridor previously crossed the Mojave River in Victorville, which is designated as critical 

habitat for the southwestern willow flycatcher. This component is no longer a part of the modified 

Project; therefore, the Project would not affect Southwestern willow flycatcher critical habitat.

Designated critical habitat for desert tortoise is present within the modified Project footprint. Based on 

modified Project construction and operation activities as well as the modified Project footprint occurring 

within the I-15 freeway median, the modified Project footprint is not expected to change the intended 

conversion purpose or inhibit the ability of the Primary Constituent’s Elements to be functionally 

established within the critical habitat. The Project modifications would not result in substantial changes 

in the evaluation of critical habitat impacts of the DesertXpress EIS or September 2020 Reevaluation.

Areas of Critical Environmental Concern

Impacts on the Cronese Basin and Halloran Wash ACECs were evaluated in the DesertXpress EIS. In 

September 2016, the BLM issued the ROD for the DRECP, which added five new ACECs within the 

modified Project footprint; therefore, impacts on these five ACECs were not previously evaluated in the 

DesertXpress EIS. They were, however, discussed and evaluated in September 2020 Reevaluation. Table 

7.2 5 in Attachment C summarizes the impacts on BLM-administered public lands within ACECs and their 

associated disturbance caps by impact type, for the DesertXpress EIS Preferred Alternative, September 

2020 Reevaluation, and modified Project footprints.

POTENTIAL EFFECTS ON WILDLIFE MOVEMENT

The section describes the potential for the modified Project alignment to interfere with wildlife 

movement. As described in Section 2.0, the modified alignment would be located entirely within the I-15 

freeway, with Segment 1 through Segment 5 being located within the I-15 freeway median.

Suitable habitat for desert bighorn sheep, as well as other desert wildlife species, occurs in several areas 

in proximity to the Project corridor, primarily within the California portion of the Project. Along the I-15

freeway, there are four potential bighorn sheep habitat connectivity corridors within the Project study 

area; specifically, I-15 freeway bridges cross washes in areas of bighorn sheep populations at Rocky 

Wash (Cady Mountains), Zzyzx Road and Oat Ditch (Soda Mountains), Kali Ditch, and the Clark Mountain 

Ditch (Mountain Pass). Existing underpasses along the I--15 freeway facilitate travel of diverse desert 

wildlife species, including several species of medium to large-bodied mammals as well as several smaller 

species of mammals, birds, and reptiles, including desert tortoise. However, because the I-15 freeway 

underpasses do not have sufficiently large openings beneath the roadway to promote large animal 

crossing and are not placed near frequently used bighorn habitat, they are not currently known to direct 

or facilitate bighorn sheep movement across the I-15 freeway
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The California Department of Fish and Wildlife, the National Park Service, and a non-governmental 

organization raised concerns that the inclusion of the rail alignment within the I-15 freeway median

would restrict wildlife movement by creating a more impermeable barrier, and therefore restrict wildlife 

movement across the I-15 freeway. To ensure the safety of both highway and rail travelers, the Project 

would require the construction of intrusion barriers along the alignment and exclusionary fencing. 

Although the I-15 freeway is located within habitat connectivity corridors, wildlife movement across the 

freeway is rare.

50 The infrequency of crossings suggests that the I-15 currently acts a substantial barrier 

to wildlife movement independent of the rail alignment. As such, the inclusion of the rail line within the 

I-15 highway median, or directly adjacent to the I-15 will not result in a significant effect to the wildlife 

beyond the existing conditions. 

In addition, by co-locating the Project with the existing I-15 highway, the Project would not result in new

impacts to wildlife by avoiding the creation of new barriers within these connectivity corridors. The 

effects of the rail line will be confined to the existing barrier (i.e., the I-15 highway). Furthermore, the 

Project will maintain or enhance all existing I-15 freeway culverts and bridges across washes. For 

example, where the I-15 freeway utilizes a culvert to convey water under the freeway, the rail alignment 

will include a culvert of the same size and capacity. The same approach will be implemented where the 

freeway crosses washes on bridge or viaduct structures. As a result, wildlife movement in this area 

should remain at approximately the same levels, though surface-level crossings would be restricted. 

Since such crossings are rare, this restriction is unlikely to affect these species. 

4.15.3 MITIGATION MEASURES

The Biological Opinion (BO) prepared in 2011 by USFWS for the Project stipulated conservation 

measures to avoid or reduce potential impacts on Federally protected species. These conservation 

measures were incorporated as commitments the project sponsor will implement, as documented in the 

2011 DesertXpress ROD.

51 Many of the original BO protective measures apply to desert tortoise ‘suitable 

habitat.’ 

The mitigation measures developed in the DesertXpress EIS and revised in the September 2020 

Reevaluation would mitigate for and avoid adverse effects to biological resources. Refer to Attachment 

D for the full list and descriptions of mitigation measures, which includes desert tortoise conservation 

measures, terms and conditions of the BO specific to desert tortoise, and general biological resource 

mitigation measures.

As discussed in Attachment D, FRA revised mitigation measures since the September 2020 Reevaluation, 

in consultation with the USFWS. FRA sent a concurrence letter to USFWS on August 11, 2023 and 

received USFWS concurrence on the revised mitigation measures on September 1, 2023.

50 See Prentice, Paige, Ashley Evans, Danielle Glass, Richard Ianniello, and Tom Stephenson. Desert Bighorn Sheep Status Report: 

November 2013 to October 2016. California Department of Fish and Wildlife, Region 6 (September 2018); Dekelaita, Daniella 

J., Clinton W. Epps, David W. German, Jenny G. Powers, Ben J. Gonzales, Regina K. Abella-Vu, Neal W. Darby, Debra L. 

Hughson, and Kelley M. Stewart, Animal Movement and Associated Infectious Disease Risk in a Metapopulation, Royal Society 

Open Science (2023). These studies explain that of the 94 unique bighorn sheep collared from 2013-2020 in mountain ranges

near the I-15, two individuals, an ewe accompanied by a lamb, have successfully crossed the I-15.

51 As lead Federal agency, FRA will monitor compliance with these mitigation measures, except for activities that occur on BLMmanaged lands, for which BLM will monitor compliance.
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Furthermore, Mitigation Measures BIO-2 and BIO-19, which were included in the 2011 DesertXpress EIS 

and revised in the September 2020 Reevaluation, would remain in effect and address potential impacts 

to wildlife connectivity.52

4.16 CUMULATIVE IMPACTS

This section evaluates whether the Project modifications would result in substantial changes to the 

evaluation of cumulative impacts discussed in the DesertXpress EIS. As previously established in the 

September 2020 Reevaluation, the September 2020 Project contributions to cumulative impacts were 

unchanged or reduced because of reductions in the overall Project footprint and location within the I-15 

freeway ROW.

Review of present and reasonably foreseeable projects within the Project vicinity did not identify new 

information that would substantially affect the cumulative impacts conclusions or assessment 

conducted in the DesertXpress EIS or September 2020 Reevaluation.

4.16.1 REGULATORY UPDATES

No updates to Federal, state, or local regulations that pertain to cumulative impacts analysis have 

occurred since the September 2020 Reevaluation. Review of present and reasonably foreseeable 

projects within the modified Project vicinity did not identify new information that would substantially 

affect the cumulative impacts conclusions or assessment conducted in the DesertXpress EIS or 

September 2020 Reevaluation.

4.16.2 ANALYSIS OF CUMULATIVE IMPACTS

The evaluation of cumulative impacts for this Reevaluation considered impacts from the Project 

modifications in combination with current, planned, and reasonably foreseeable projects in the Project 

vicinity. Overall, the modified Project’s contributions to cumulative impacts would be unchanged or 

reduced because of the modified Project’s reduced footprint and location within the I-15 freeway ROW. 

Furthermore, the mitigation measures developed in the DesertXpress EIS and revised in the September 

2020 Reevaluation to reduce Project impacts would still apply to the modified Project to reduce 

contributions to cumulative effects. Thus, the type and magnitude of impacts resulting from the Project 

modifications would be comparable to those identified in the DesertXpress EIS and September 2020 

Reevaluation. The evaluation of cumulative impacts from the modified Project is provided below.

Land Use, Communities, and Environmental Justice: The DesertXpress EIS concluded that the Project 

would not substantially alter existing land uses in the area and would not have a considerable 

contribution to cumulative land use, community, and environmental justice impacts, because the 

Project follows the I-15 freeway and proposes land uses that would be compatible with the existing 

transportation corridor. The conclusions of the DesertXpress EIS remain valid because the modified 

Project would still be located within the I-15 freeway ROW and the proposed station locations would be 

on undeveloped lands adjacent to the I-15 freeway. As a result, the Project modifications would not 

52 The California Department of Transportation (Caltrans), the California Department of Fish and Wildlife (CDFW) and Brightline 

West have entered into an agreement to design and construct three wildlife overcrossings across Interstate 15 (I-15) and the 

Project. These dedicated overcrossings can provide a sustainable and safe path for wildlife – especially for bighorn sheep –

over the existing northbound and southbound highway lanes and the future high-speed rail system to be built within the 

median. These crossings are being implemented by Caltrans, CDFW and Brightline West, and are not part of this Project.
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result in substantial changes in the evaluation of cumulative land use, community, and environmental 

justice impacts of the DesertXpress EIS or September 2020 Reevaluation.

Growth: The DesertXpress EIS concluded that the Project, in combination with the construction of the 

proposed Ivanpah Valley Airport, could have a negative economic impact on the City of Barstow by 

reducing automobile travel through the Barstow area. However, the DesertXpress EIS noted that the 

assumption of construction and operation of this airport would be speculative in the absence of a formal 

airport implementation plan. Without the construction of the Ivanpah Valley Airport, the Project would 

likely contribute to a positive economic impact to the City of Barstow through the generation of 

employment opportunities. As the completion of the Ivanpah Valley Airport remains uncertain, the 

Project modifications would not result in substantial changes in the evaluation of cumulative growth 

impacts of the DesertXpress EIS or September 2020 Reevaluation.

Farmlands and Grazing Land: The DesertXpress EIS determined that the Project’s contribution to 

cumulative farmland impacts would be negligible because the Project would not require substantial 

conversion of farmlands. However, the DesertXpress EIS concluded that the Project, in combination with 

regional energy projects, would result in cumulative impacts on grazing lands by dividing grazing lands 

and converting such lands to non-grazing uses. The modified Project alignment is located within or 

immediately adjacent to the I-15 freeway, which would minimize the conversion of farmlands and 

grazing land and reduce the Project contribution to cumulative farmland and grazing land impacts. Thus, 

the Project modifications would not result in substantial changes in the evaluation of cumulative 

farmland and grazing land impacts of the DesertXpress EIS or September 2020 Reevaluation.

Utilities/Emergency Services: The DesertXpress EIS concluded that the Project could contribute to 

cumulative utility/emergency service impacts by increasing utility demand and requiring emergency 

services. However, the DesertXpress EIS noted that mitigation measures applied to the Project would 

avoid and minimize impacts on utility and emergency service providers, thus reducing the Project 

contribution to this cumulative impact. The Project modifications would not create additional demand 

for utilities and emergency services, and sufficient regional utility capacity still exists to serve the 

Project. Furthermore, mitigation measures developed in the DesertXpress EIS and revised in the 

September 2020 Reevaluation to minimize impacts on utility and emergency service providers would 

still apply to the Project. Thus, the Project modifications would not result in substantial changes in the 

evaluation of cumulative utilities/emergency service impacts of the DesertXpress EIS or September 2020 

Reevaluation.

Traffic and Transportation: The DesertXpress EIS determined that the Project, in combination with 

other regional projects, could contribute to cumulative traffic impacts. However, the DesertXpress EIS 

included mitigation measures to avoid and minimize the Project’s contribution to cumulative traffic 

impacts. The September 2020 Reevaluation determined the September 2020 modifications would result 

in similar traffic impacts to those identified in the DesertXpress EIS, although these impacts would occur 

at different locations within the transportation network due to the relocated Dale Evans and Warm 

Springs stations. Thus, the aforementioned mitigation measures were revised in the September 2020 

Reevaluation to accommodate the relocated Dale Evans and Warm Springs stations, which have not 

changed for the modified Project. Mitigation measures developed in the DesertXpress EIS and revised in 

the September 2020 Reevaluation would minimize or avoid such impacts through implementation of 

roadway improvements. Thus, the Project modifications would not result in substantial changes in the 

evaluation of cumulative traffic impacts of the DesertXpress EIS or September 2020 Reevaluation.
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Visual Resources: The DesertXpress EIS concluded that the Project, in combination with other projects 

in the area, would change the visual character of the Project vicinity. However, the DesertXpress EIS 

included mitigation measures to avoid and minimize the Project contribution to this cumulative impact. 

As the modified Project proposes structures of the same size and approximate locations as evaluated in 

the DesertXpress EIS and September 2020 Reevaluation, mitigation measures developed in the 

DesertXpress EIS and revised in the September 2020 Reevaluation would still apply and remain 

adequate to reduce the Project’s visual impacts. Thus, the Project modifications would not result in 

substantial changes in the evaluation of cumulative visual impacts of the DesertXpress EIS or September 

2020 Reevaluation.

Cultural and Paleontological Resources: The DesertXpress EIS concluded that the Project could 

contribute to cumulative impacts in combination with nearby projects, such as capacity improvements 

to the I-15 freeway, through disturbing significant cultural and paleontological resources in the area. 

However, because of the regulatory protections given to significant cultural and paleontological 

resources, mitigation measures would be applied to the Project and would likely be applied to other 

nearby projects. The Project modifications would not substantially increase the scope of the Project to 

result in greater impacts on significant cultural or paleontological resources and mitigation measures 

developed in the DesertXpress EIS and revised in the September 2020 Reevaluation would still apply to 

the modified Project. Thus, the Project modifications would not result in substantial changes in the 

evaluation of cumulative cultural and paleontological impacts of the DesertXpress EIS or September 

2020 Reevaluation.

Hydrology and Water Quality: The DesertXpress EIS concluded that the Project, in combination with 

other nearby projects, would result in cumulative impacts resulting from traversing ephemeral 

drainages. The modified Project would traverse the same aquatic features as the Preferred Alternative 

analyzed in the DesertXpress EIS as well as the September 2020 Reevaluation and would not result in 

new types of hydrological and water quality impacts. Thus, the Project modifications would not result in 

substantial changes in the evaluation of cumulative hydrology and water quality impacts of the 

DesertXpress EIS or September 2020 Reevaluation.

Geology and Soils: The DesertXpress EIS concluded the Project would be unlikely to contribute to 

cumulative geology and soils impacts because such impacts depend on the local geological setting. The 

modified Project is of a similar scope and location to the Project as evaluated in the DesertXpress EIS 

and September 2020 Reevaluation. Therefore, the Project modifications would not result in substantial 

changes in the evaluation of cumulative geology and soils impacts of the DesertXpress EIS or September 

2020 Reevaluation.

Hazardous Materials: The DesertXpress EIS concluded that the Project would be unlikely to contribute 

to cumulative impacts relating to hazardous materials because environmental effects relating to 

hazardous materials are generally site-specific. The Project modifications would not include new 

activities requiring the use of previously unevaluated hazardous materials. Thus, the Project 

modifications would not result in substantial changes in the evaluation of cumulative hazardous 

materials impacts of the DesertXpress EIS or September 2020 Reevaluation.

Energy, Air Quality, and Global Climate Change: The DesertXpress EIS concluded that the Project would 

have a positive effect on energy and air quality during operation because electric trains employed in 

Project operation would provide an energy efficient, lower-emission alternative to automobile travel. 

The modified Project would still employ electric train technology and reduce VMT through diverting 
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automobile traffic from the I-15 freeway. Thus, the Project modifications would not result in substantial 

changes in the evaluation of cumulative energy, operational air quality, and global climate change 

impacts of the DesertXpress EIS or September 2020 Reevaluation.

The DesertXpress EIS also concluded that the Project would be unlikely to contribute to cumulative 

energy impacts during construction because the Project would include mitigation measures – such as 

the use of energy efficient construction equipment – that would avoid excessive energy use. As the 

Project modifications reduce the original overall Project construction footprint, Project construction 

would require less energy than considered in the DesertXpress EIS. Additionally, the Project would still 

include mitigation measures to reduce construction energy consumption. Thus, the Project 

modifications would not result in substantial changes in the evaluation of cumulative construction 

energy impacts of the DesertXpress EIS or September 2020 Reevaluation.

The DesertXpress EIS determined that Project construction, in combination with other nearby energy 

and transportation projects, would result in cumulative impacts from construction emissions, such as 

fugitive dust and emissions from construction equipment. The modified Project would require less 

ground disturbance during construction relative to the Project evaluated in the DesertXpress EIS and 

would likely result in fewer construction-period emissions. Thus, the Project modifications would not 

result in substantial changes in the evaluation of cumulative construction air quality impacts of the 

DesertXpress EIS or September 2020 Reevaluation.

Noise and Vibration: The DesertXpress EIS concluded that vibration generated by the Project would not 

result in cumulative impacts because of the localized nature of vibration. As the Project modifications 

would not introduce vibration impacts beyond those considered in the DesertXpress EIS or September 

2020 Reevaluation, the modified Project would not result in new cumulative vibration impacts.

The DesertXpress EIS determined that Project noise, combined with noise resulting from other nearby 

projects, could result in cumulative noise impacts. The Project modifications would not result in noise 

impacts along the alignment than those considered in the September 2020 Reevaluation. The 

DesertXpress EIS concluded that mitigation measures prescribing the use of sound barriers would avoid 

and minimize these impacts. Consistent with the September 2020 Reevaluation, refinements to 

mitigation measures would place barriers in new locations selected to avoid and minimize the modified 

Project noise impacts. Thus, the Project modifications would not result in substantial changes in the 

evaluation of cumulative noise and vibration impacts of the DesertXpress EIS or September 2020 

Reevaluation.

Biological Resources: The DesertXpress EIS determined that the Project, in combination with nearby 

transportation and energy projects, would result in cumulative impacts on biological resources. By 

relocating the entire alignment to the I-15 freeway ROW, the Project modifications would result in fewer 

biological impacts than identified in the DesertXpress EIS. Thus, the Project modifications would not 

result in substantial changes in the evaluation of cumulative biological resource impacts of the 

DesertXpress EIS or September 2020 Reevaluation.

5.0 Environmental Consequences: Sloan Vehicle Maintenance 

Facility

This section evaluates whether the Sloan VMF would result in substantial changes to the evaluation of 

effects established in the DesertXpress EIS and September 2020 Reevaluation.
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The Project design evaluated in the DesertXpress EIS included an operations, maintenance, and storage 

facility (OMSF) in close proximity to the original Victorville Station west of the I-15 freeway and included 

facilities for train washing, repair, parts, storage, and an operation control center. . The OMSF would 

have required approximately 50 acres53 of permanent footprint, and approximately 400 employees.

In the September 2020 Reevaluation, the OMSF was relocated with the Victorville Station to the south 

side of the I-15 freeway at Dale Evans Parkway in Apple Valley and the MOW facility was relocated to

approximately six miles south of the California/Nevada state line, adjacent to the existing California 

Agricultural Inspection Station. The MOW facility would have required 25 acres of permanent footprint.

At that time a location for vehicle maintenance and storage had not been identified. 

Based on additional design considerations, Brightline West proposes to locate the vehicle maintenance 

and storage activities to a site located in Segment 6 west of the I-15 freeway and south of Sloan Road.

Brightline West also proposes to construct an additional freight track corridor to connect the VMF to the 

adjacent UPRR line. The Sloan VMF and adjacent UPRR connection would require 246 acres of 

permanent footprint and 105 acres of temporary footprint, and includes: 

▪ Storage and staging tracks and overhead catenary system from which trains would be mobilized for 

daily operations.

▪ Appurtenances associated with the Sloan VMF, including but not limited to a train car wash station, 

a train performance monitoring station, an Operations Control Center, a power substation and 

distribution lines, utility connections, circulation system, site control, fencing, and parking.

The MOW facility would also be removed and divided between the Sloan VMF and the Victor Valley 

Station. The Sloan VMF will be a permanent workplace for approximately 100 employees related to 

either the maintenance of the Brightline West train fleet or performing other functions such as driving 

the trains. These facilities would be located on land under BLM jurisdiction and would therefore require 

a ROW grant lease from BLM.

5.1 LAND USE, COMMUNITY, AND ENVIRONMENTAL JUSTICE

This section evaluates whether the Sloan VMF would result in substantial changes to the evaluation of 

effects to land use, community, and environmental justice discussed in the DesertXpress EIS and 

September 2020 Reevaluation.

5.1.1 REGULATORY UPDATES

FEDERAL

The Sloan VMF would result in the use of land managed by BLM, and therefore could potentially conflict 

with BLM land use policies. However, the Sloan VMF is not located within BLM-designated ACECs,

Resource Management Plan Areas, nor Natural Conservation Areas.

54 As discussed in Section 4.1.3, 

Conflict with Land Use Plans, Policies, or Regulations, mitigation measures would be applied to avoid or 

reduce any potential conflict with planned uses at these locations.

53 The 2011 DesertXpress EIS states that site envelopes for the OMSF range from about 95 acres to 260 acres, but the final 

footprint is anticipated to be notably smaller than the areas surveyed. 

54 Bureau of Land Management (BLM). 2023. Nevada Planning and NEPA. https://www.blm.gov/programs/planning-andnepa/plans-in-development/nevada. Accessed: August 2023.
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Clark County Conservation of Public Land and Natural Resources Act of 2002

As discussed in the DesertXpress EIS and September 2020 Reevaluation, the Act directed BLM to 

establish the Sloan Canyon National Conservation Area, expanded the Red Rock National Conservation 

Area and preserved petroglyph sites near Sloan. These areas were designated to conserve significant 

scenic and important cultural resources in southern Nevada.

STATE AND LOCAL

The Clark County Master Plan was updated in November 2021, resulting in updates to land use 

designations where the modified Project would traverse Nevada. The Sloan VMF would be located on 

Open Space and Business Employment land uses.55

5.1.2 EFFECTS ANALYSIS

RESIDENTIAL AND BUSINESS DISPLACEMENTS

The Sloan VMF would be constructed on undeveloped land and thus would not result in residential or 

business displacements, and therefore would not result in changes in the evaluation of residential and 

business displacements of the DesertXpress EIS or September 2020 Reevaluation.

DIVISION OF AN ESTABLISHED COMMUNITY

The Sloan VMF site is located adjacent to the I-15 freeway and is not located in proximity to existing 

communities. The closest residential community to the Sloan VMF is the Southern Highlands residences 

approximately 2 miles north. As such, the Sloan VMF would not result in substantial changes in the 

evaluation of community division impacts of the DesertXpress EIS or September 2020 Reevaluation.

INTERFERENCE WITH NORMAL FUNCTIONING OF ADJACENT LAND USES

The Sloan VMF would result in new or previously identified footprint impacts outside of the I-15 freeway 

ROW. The Sloan VMF would be adjacent to Business Employment, Open Lands, Corridor Mixed-Use, and 

Public Use land uses.

56 Mitigation measures identified in the DesertXpress EIS and September 2020 

Reevaluation that would avoid or minimize negative impacts to adjacent land uses would still apply to 

the Sloan VMF. Therefore, the Sloan VMF would not result in substantial changes in the evaluation of 

impacts on the normal functioning of adjacent land uses of the DesertXpress EIS or September 2020 

Reevaluation.

CONFLICT WITH LAND USE PLANS, POLICIES, OR REGULATIONS

The Sloan VMF would not result in new or previously unidentified footprint impacts and would be 

located on Business Employment and Open Space land uses.

40 The Sloan VMF would not be located in 

any areas designated under the Clark County Conservation of Public Land and Natural Resources Act of 

2002 or impact the preserved petroglyph sites near Sloan. The Sloan VMF is anticipated to have high 

55 Clark County. 2021. South County Planned Land Use Maps. 

https://www.clarkcountynv.gov/government/departments/comprehensive_planning_department/library/maps.php#outer8513sub-8529. Accessed: June 2022.

56 Clark County. 2021. South County Planned Land Use Maps. 

https://www.clarkcountynv.gov/government/departments/comprehensive_planning_department/library/maps.php#outer8513sub-8529. Accessed: June 2022.
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compatibility with Business Employment land uses, but low compatibility with Open Space land use, 

based on the compatibility of land use designations identified by the DesertXpress EIS.

The Sloan VMF is located on land under BLM jurisdiction; the September 2020 Reevaluation identified 

Mitigation Measure LU-3 to address potential conflicts with existing land use designations in accordance 

with the DRECP LUPA. This mitigation measure would apply and would avoid or reduce any potential 

conflicts with planned uses designated by the DRECP LUPA at this location. Thus, the Sloan VMF would 

not result in substantial changes in the evaluation of land use plan, policy, or regulation impacts of the 

DesertXpress EIS or September 2020 Reevaluation.

CONFLICTS WITH AIRPORT LAND USES

The Sloan VMF would not be in proximity to existing or planned airport facilities such that conflicts with 

airport land uses would occur. The nearest airport to the Sloan VMF is the Henderson Executive Airport 

located approximately 4.5 miles northeast. The Sloan VMF would not result in substantial changes in the 

evaluation of airport land use impacts of the DesertXpress EIS or September 2020 Reevaluation.

ENVIRONMENTAL EFFECTS DISPROPORTIONATELY BORNE BY LOW-INCOME OR MINORITY 

POPULATIONS

The Sloan VMF is not located within or adjacent to environmental justice block groups.57 Therefore, the 

Sloan VMF would not result in new environmental effects disproportionately borne by environmental 

justice communities, and the Project modifications would not result in substantial changes in the 

evaluation of environmental justice impacts of the DesertXpress EIS or September 2020 Reevaluation.

5.1.3 MITIGATION MEASURES

The following mitigation measures established in the DesertXpress EIS and revised in the September 

2020 Reevaluation would avoid adverse land use effects:

• Mitigation Measure LU-1: Rail Alignment Design in One-Engine Inoperative Zones

• Mitigation Measure LU-2: Rail Alignment Design in Existing and Planned Runway Zones

Mitigation Measure LU-3: DRECP Land Use Plane Amendment Conservation and Management Action 

Compliance, established in the September 2020 Reevaluation, would still apply to the modified Project 

to ensure compliance with applicable goals, policies, and CMAs where the Project would traverse land 

under BLM management protected by the DRECP LUPA.

Additionally, mitigation measures pertaining to the resource topics listed below would be implemented 

to avoid and minimize impacts on adjacent land uses:

▪ Utilities. Avoidance or minimization of conflicts with existing utility infrastructure (including 

coordination with existing utility providers).

▪ Traffic. The addition of signalization and/or lanes to the intersection approaches.

▪ Visual Resources. Use of aesthetically pleasing materials for the rail alignment that minimize 

reflectivity, use of architecture and earth tone colors at the Victor Valley Station site that reflect the 

surrounding desert landscape, design of signage at the Victor Valley Station site to reflect the scale 

and character of the site and surroundings, use of contour grading, orderly construction site 

57 United States Environmental Protection Agency. 2019. EJSCREEN: Environmental Justice Screening and Mapping Tool. 

Available: https://www.epa.gov/ejscreen. Accessed April 2022.
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management, minimization of light spillover during construction, and use of visual screening of 

construction areas as appropriate. Coordination with stakeholder agencies to create a unified 

aesthetic theme that supports the aesthetic goals of the community, including specific design 

elements part of the Aesthetic and Landscape Task Force (ALTF). The aesthetic treatment of the 

structures shall involve color, texture, and patterns that tie into the Brightline West Project's Project 

Aesthetic and Landscape Masterplan (PALM) to create a visual link between the structures and 

other Project elements along the corridor.

▪ Air Quality. Use of best management dust control practices to minimize air quality impacts during 

construction.

▪ Noise. Installation of noise barriers, use of sound and vibration reducing materials, relocation of 

crossovers or special track work, property acquisitions, limited construction times, limited locations 

of construction.

5.2 GROWTH

This section evaluates whether the Sloan VMF would result in substantial changes to the evaluation of 

effects to regional population, housing, and employment effects discussed in the DesertXpress EIS and 

September 2020 Reevaluation. 

5.2.1 REGULATORY UPDATES

No updates to Federal, state, or local regulation that pertain to the modified Project’s effects on local 

and regional growth have occurred since the September 2020 Reevaluation.

5.2.2 EFFECTS ANALYSIS

CONSTRUCTION-PERIOD EMPLOYMENT

The DesertXpress EIS estimated that Project design and construction would have a positive economic 

effect on the Project area, generating approximately 17,469 jobs in Clark County, Nevada. Construction 

of the Sloan VMF is not anticipated to have a significant effect on construction-period employment

relative to the overall Project. Therefore, the Sloan VMF would not result in substantial changes in the 

evaluation of construction-period employment impacts as disclosed in the DesertXpress EIS or 

September 2020 Reevaluation. Voluntary Mitigation Measure GRO-1 would still apply in order to ensure 

jobs generated by the Project would be made available to county residents. 

PERMANENT EMPLOYMENT

The Sloan VMF will provide a permanent workplace for approximately 100 employees related to 

operations and maintenance of the train fleet, and thus the Project modifications would result in higher 

permanent employment overall in the Las Vegas area. The removal of the collocated OMSF at the Victor 

Valley Station would result in a reduction in projected permanent employment in the Victor Valley area. 

Voluntary Mitigation Measure GRO-1 would still apply for the modified Project, to ensure jobs 

generated by the Project would be made available to county residents. Thus, the Sloan VMF would not 

result in substantial changes in the evaluation of permanent employment impacts of the DesertXpress 

EIS or September 2020 Reevaluation.
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TRANSIT-ORIENTED DEVELOPMENT POTENTIAL 

The relocation of the VMF would not change the September 2020 Reevaluation conclusions regarding 

induced TOD because modified Project would continue to connect the Victorville area and Las Vegas 

and, would not substantially change the nature of trips provided during Project operations. Thus, the 

Sloan VMF would not result in significant TOD development impacts not evaluated in the DesertXpress 

EIS or September 2020 Reevaluation. Voluntary Mitigation Measure GRO-2 would still apply to the 

modified Project to encourage implementation of transit oriented and master planned development. 

ECONOMIC VITALITY 

The September 2020 Reevaluation disclosed that the Project has the potential to negatively affect future 

economic growth in the towns of Barstow, Baker, Primm, and Jean because the Project would not 

include stations in these visitor-dependent communities. The relocation of the VMF would not change 

these conclusions regarding economic vitality because the relocation is not anticipated to substantially 

increase or decrease ridership and the economic composition of the communities listed have not 

changed significantly sense the September 2020 Reevaluation. Therefore, the Sloan VMF would not 

result in substantial changes in the evaluation of economic vitality impacts disclosed in the DesertXpress 

EIS or September 2020 Reevaluation. 

5.2.3 MITIGATION MEASURES 

Voluntary Mitigation Measures GRO-1 and GRO-2 were established in the DesertXpress EIS and revised 

in the September 2020 Reevaluation. The DesertXpress EIS concluded implementation of the Project 

would not result in any adverse direct or indirect growth effects and that no mitigation measures would 

be required. However, DesertXpress Enterprises, LLC proposed the following voluntary mitigation 

measures to address concerns raised by local jurisdictions regarding potential economic impacts of the 

Project:

▪ Voluntary Mitigation Measure GRO-1. Voluntary Applicant Coordination with City of Barstow and 

San Bernardino County for Employment.

▪ Voluntary Mitigation Measure GRO-2. Voluntary Applicant Coordination for Land Use Planning.

5.3 FARMLANDS AND GRAZING LANDS

This section evaluates whether the Sloan VMF would result in substantial changes to the evaluation of 

effects to farmland and grazing land designations (assigned by the DOC, Clark County Comprehensive 

Plan, and BLM) discussed in the DesertXpress EIS and September 2020 Reevaluation.

5.3.1 REGULATORY UPDATES

FARMLAND

Within Nevada, there are no designated farmlands within or near the Project area as established in the 

Clark County Comprehensive Plan Conservation Element.
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GRAZING LAND

The locations of designated grazing allotments within BLM managed lands within or near the Project 

area have not changed since the September 2020 Reevaluation.

58

5.3.2 EFFECTS ANALYSIS

The Sloan VMF would not be located within or near designated farmlands and would therefore not 

result in the conversion of designated farmlands to non-agricultural use. The Sloan VMF would not 

result in changes in the evaluation of farmland impacts of the DesertXpress EIS or September 2020 

Reevaluation.

The Sloan VMF would not be located within designated grazing land as identified by the BLM Grazing 

Allotments map but would be in proximity to the Hidden Valley grazing allotment east of the I-15 

freeway. Mitigation Measures FAR-2 and FAR-3 would still apply to minimize indirect effects. Thus, the 

Sloan VMF would not result in substantial changes in the evaluation of grazing land impacts of the 

DesertXpress EIS.

5.3.3 MITIGATION MEASURES

The following mitigation measures established in the DesertXpress EIS and revised in the September 

2020 Reevaluation would avoid adverse effects related to farmlands and grazing lands. 

▪ Mitigation Measure FAR-2: Livestock Access to Water

▪ Mitigation Measure FAR-3: Fencing and Gate Modifications

5.4 UTILITIES/EMERGENCY SERVICES

This section evaluates whether the Sloan VMF would result in substantial changes to the evaluation of 

effects to utilities and emergency services discussed in the DesertXpress EIS.

5.4.1 REGULATORY UPDATES 

No updates to Federal, state, or local regulation that pertain to the modified Project’s effects on utilities 

and emergency services have occurred since the September 2020 Reevaluation.

5.4.2 EFFECTS ANALYSIS

ELECTRICITY AND GAS

The Sloan VMF would require the use of natural gas and electricity services. Natural gas would be 

provided by Southwest Gas Corporation (SGC) and electricity would be provided by NV Energy. As 

evaluated in the DesertXpress EIS, SGC has capacity to serve the existing needs and those of the Project.

Mitigation Measure UTIL-1 would still apply to the modified Project to avoid or minimize impacts to 

electrical providers during operation of the modified Project. Furthermore, DesertXpress Enterprises, 

LLC is coordinating with electricity providers to ensure the adequacy of regional power delivery systems.

Thus, the Sloan VMF would not result in substantial changes in the evaluation of natural gas and 

electricity impacts of the DesertXpress EIS or September 2020 Reevaluation.

58 Bureau of Land Management. 2022. BLM National Grazing Allotments Map Service. Available: 

https://landscape.blm.gov/geoportal/rest/document?f=html&id=%7B8C2D42AB-A6B9-4DF7-AD77-E98A1BD8468A%7D. 

Accessed: June 2022.
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WATER SUPPLY 

The Sloan VMF would generate water demand associated with employee operations. Using Las Vegas 

Valley Water Demand commercial water demand flow rates, estimated demand on an annual basis 

would be approximately 904.7 acre feet per annum (AFA), but would be within future projections for the 

service area.59 Furthermore, the DesertXpress EIS included Mitigation Measures UTIL-1, UTIL-2, and 

UTIL-3 to reduce water usage, prepare a water supply assessment for the Sloan VMF, and procure a 

water commitment from the LVVWD. These mitigation measures would still apply to the Sloan VMF, and 

therefore the Sloan VMF would not result in substantial changes in the evaluation of water supply 

impacts of the DesertXpress EIS.

SEWAGE AND WASTEWATER

Operation of the Sloan VMF would not create demand for sewage and wastewater treatment facilities, 

as it would include its own septic system. The Sloan VMF would not result in substantial changes in the 

evaluation of wastewater impacts of the DesertXpress EIS or September 2020 Reevaluation.

STORMWATER 

The area proposed for the Sloan VMF is largely unimproved at present. The construction and operation 

of these facilities will convert approximately 27 acres of undeveloped lands to paved and/or built 

facilities, decreasing permeability and potentially creating stormwater. The Sloan VMF would not change 

the DesertXpress EIS conclusion regarding stormwater because it would not substantially alter the 

amount of impervious surface introduced by the overall Project. Mitigation Measures UTIL-4 and UTIL-5 

would still apply to minimize impacts to stormwater systems. The Sloan VMF would not result in 

substantial changes in the evaluation of stormwater impacts of the DesertXpress EIS or September 2020 

Reevaluation. Refer to Section 5.8, Hydrology and Water Quality, for a discussion of Project impacts to 

stormwater during construction.

SOLID WASTE

The DesertXpress EIS identified the Apex Regional Landfill as the landfills that would service the Project 

in Nevada. The Sloan VMF would generate solid waste due to ongoing uses by employees. Using the 

assumptions in the DesertXpress EIS, waste generated from the 100 permanent employees for the Sloan 

VMF is approximately 0.7 tons per day or 255.5 tons annually.60 As of 2017, the Apex Landfill was 

receiving 6,800 tons of waste each day.61 The addition of 0.7 daily tons associated with the Sloan VMF 

would have a minimal effect on the landfill’s capacity to receive solid waste. The Sloan VMF would not 

result in substantial changes in the evaluation of solid waste impacts of the DesertXpress EIS or 

September 2020 Reevaluation.

UTILITY INFRASTRUCTURE CROSSINGS

The Sloan VMF could intersect with utility conveyance systems that were not identified in the 

DesertXpress EIS or September 2020 Reevaluation. However, the Sloan VMF would not change the 

DesertXpress EIS conclusions regarding utility infrastructure crossings because Mitigation Measure UTIL59 Southern Nevada Water Authority. 2020. 2020 Water Resource Plan.

60 The DesertXpress EIS assumes a waste generation rate of 14 pounds of solid waste per employee per day in the Las Vegas 

area.

61 State of Nevada. 2017. Solid Waste Management Plan.
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8 would still apply to the Sloan VMF to avoid or minimize potential adverse effects to water, 

wastewater, communications, local gas pipelines, and other physical facilities that features of the 

modified Project would cross. The Sloan VMF would not result in substantial changes in the evaluation 

of utility infrastructure crossing impacts of the DesertXpress EIS or September 2020 Reevaluation.

EMERGENCY SERVICES

The Sloan VMF would be served by Las Vegas Fire and Rescue (LVFR). As evaluated in the DesertXpress 

EIS, LVFR, has sufficient staffing levels to serve the Project. Additionally, Mitigation Measures UTIL-6 and 

UTIL-7 would still apply to the modified Project, including the Sloan VMF, which would require the 

payment of impact fees for police, fire, and emergency services, and the development and 

implementation of a comprehensive emergency operations plan. Therefore, the Sloan VMF would not 

result in substantial changes in the evaluation of emergency services impacts of the DesertXpress EIS or 

September 2020 Reevaluation.

5.4.3 MITIGATION MEASURES 

The following mitigation measures established in the DesertXpress EIS and revised in the September 

2020 Reevaluation would avoid adverse effects to utilities and emergency services:

▪ Mitigation Measure UTIL-1: Payment of connection and or user/service/tipping fees

▪ Mitigation Measure UTIL-2: Minimize water usage through the incorporation of water saving devices 

wherever required or feasible; require drought-tolerant landscaping at all facilities

▪ Mitigation Measure UTIL-3: Obtain a water commitment from the LVVWD during the design phase

▪ Mitigation Measure UTIL-4: Rail segments within freeway ROWs shall tie into existing freeway 

stormwater conveyance devices

▪ Mitigation Measure UTIL-5: Develop appropriate stormwater conveyance structures/systems at 

station and maintenance facility sites, as well as points along railroad segments where it is not 

possible to connect to existing systems

▪ Mitigation Measure UTIL-6: Payment of impact fees for police, fire, and emergency services

▪ Mitigation Measure UTIL-7: Develop a comprehensive emergency operations plan

▪ Mitigation Measure UTIL-8: Avoid or minimize conflicts with existing utility infrastructure

5.5 TRAFFIC AND TRANSPORTATION

This section evaluates whether the Sloan VMF would result in substantial changes to the evaluation of 

effects to traffic and transportation discussed in the DesertXpress EIS and September 2020 

Reevaluation.

5.5.1 REGULATORY UPDATES

FEDERAL AND STATE

No updates to Federal, state, or local regulation that pertain to the modified Project’s effects on traffic 

and transportation have occurred since the September 2020 Reevaluation.
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5.5.2 EFFECTS ANALYSIS

FREEWAY LEVEL OF SERVICE (LOS)

The relocation of the VMF would increase ramp queues near Sloan. However, as evaluated in the 

DesertXpress EIS, the Project would have a beneficial effect on traffic conditions from Primm to Sloan.

The Sloan VMF would employ approximately 100 employees, which is less than the 400 employees 

projected for the Victorville OMSF evaluated in the DesertXpress EIS. As such, the Sloan VMF would 

result in fewer trips, and would not be located in a high traffic volume area, and thus would have a 

reduced effect on traffic conditions. Therefore, the modified Project would not result in substantial 

changes in the evaluation of freeway LOS of the DesertXpress EIS or September 2020 Reevaluation.

INTERSECTION LEVEL OF SERVICE

The relocation of the VMF would increase intersection LOS near Sloan. However, as evaluated in the 

DesertXpress EIS, the Project would have a beneficial effect on traffic conditions from Primm to Sloan. 

As stated above, the Sloan VMF would generate fewer trips as the Victorville OMSF evaluated in the 

DesertXpress EIS, and would not be located in a high traffic volume area, and would thus have a minimal 

effect on traffic conditions. Therefore, the modified Project would not result in substantial changes in 

the evaluation of intersection LOS of the DesertXpress EIS or September 2020 Reevaluation.

VEHICLE MILES TRAVELED

The Sloan VMF would require approximately 100 employees, which may result in further increases to 

annual VMT from employee commute trips. However, this increase would not be significant, since the 

previous estimate used in the September 2020 Reevaluation for annual VMT from employee commute 

trips was evaluated assuming approximately 1,034 daily employees.62 Thus, the modified Project, 

including the Sloan VMF, would still result in substantial reductions in annual VMT along the I-15 

freeway corridor due to diversion from automobiles to rail (approximately 502 million VMT), and would 

therefore not result in substantial changes in the evaluation of effects to VMT of the DesertXpress EIS or 

September 2020 Reevaluation.

ROADWAY SAFETY 

Highways

While the geographic location of specific safety-related impacts at the Sloan VMF would be different 

than the Project evaluated in the September 2020 Reevaluation, the nature of these impacts would 

generally remain unchanged. These impacts could include potential effects related to obstruction of 

motorists’ sight distance, increased severity of run-off road crashes, and visual distractions for motorists 

(particularly train headlights) during operation of the modified Project, as well as temporary reductions

in horizontal and vertical clearances during construction of the Project. However, given the market 

diversion from automobiles to rail in the I-15 freeway corridor, the modified Project, including the Sloan 

VMF (and associated roadway modifications) would also result in some beneficial effects to highway 

safety due to a reduction in collisions. Mitigation Measure TRAF-4 would still be applied to fully mitigate 

the modified Project’s potentially adverse effects on highway safety. Therefore, the Sloan VMF would 

62 The modified Project conservatively assumes 572 daily employees at the Victor Valley Station and OMSF, and 462 daily 

employees at the Warms Springs Station, for a total of 1,034 daily employees.
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not result in substantial changes in the evaluation of effects to highway safety of the DesertXpress EIS or 

September 2020 Reevaluation.

Local Streets

While the modified Project would result in added traffic on local streets surrounding the Sloan VMF, an 

increase in traffic alone would generally not constitute a safety hazard. All improvements would be 

designed according to accepted industry standards such as the Manual on MUTCD, AASHTO Policy on 

Geometric Design of Highways and Streets, and the National Association of City Transportation Officials 

Urban Street Design Guide and would be coordinated with local jurisdictions to ensure conformance 

with their specific design practices. Thus, the Sloan VMF would not result in substantial changes in the 

evaluation of local street safety impacts of the DesertXpress EIS or September 2020 Reevaluation.

5.5.3 MITIGATION MEASURES

The following mitigation measure established in the DesertXpress EIS and revised in the September 2020 

Reevaluation would avoid adverse effects on traffic and transportation:

▪ Mitigation Measure TRAF-4: Conduct a Design Review within the Parameters Defined in the Highway 

Interface Manual

5.6 VISUAL RESOURCES 

This section evaluates whether the Sloan VMF would result in substantial changes to the evaluation of 

aesthetic and visual resources discussed in the DesertXpress EIS and September 2020 Reevaluation. 

5.6.1 REGULATORY UPDATES

No updates to Federal regulations governing visual resources have occurred since the September 2020 

Reevaluation that would pertain to the Project. 

5.6.2 EFFECTS ANALYSIS

CONSTRUCTION

The modified Project proposes 105 acres of TCAs for the Sloan VMF and UPRR. Proposed TCAs would be 

located adjacent to existing industrial development to the north, the I-15 freeway to the east, and the 

existing UPRR tracks to the west. Visual impacts from construction activities and TCAs would be 

minimized through implementation of Mitigation Measures VIS-7 through VIS-10. The Project 

modifications would not result in substantial changes in the evaluation of construction effects to visual 

quality of the DesertXpress EIS or September 2020 Reevaluation.

OPERATION

The DesertXpress EIS evaluated visual effects from the implementation of the previously considered 

OMSF in proximity to the original Victorville Station, and developed Mitigation Measures VIS-3, VIS-4, 

and VIS-5 to reduce effects to visual quality from this maintenance facility. The Sloan VMF would 

introduce a facility and various appurtenances, including a train wash station, a train performance 

monitoring station, a power substation and distribution lines, utility connections, fencing, and facilities 

for parking. Additionally, a new UPRR rail connection would be implemented to connect the Sloan VMF 

to the adjacent UPRR rail tracks to the west, requiring between 16 and 34 acres depending on the 

alternative chosen. As described above, the Sloan VMF and UPRR rail connection would be located in 
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Segment 6 just west of the I-15 freeway and south of Sloan Road. The DesertXpress EIS determined this 

area to have medium visual quality and medium viewer sensitivity. However, it did not evaluate effects 

from visual quality from the introduction of Project features in this location.

The Sloan VMF site is mostly undeveloped, and is characterized by low-lying shrubs, desert soils, and 

dunes, with adjacent industrial development located north along Sloan Road. The site is located 

between two existing transportation corridors, with the I-15 freeway adjacent to the east and the 

existing UPRR rail corridor adjacent to the west. Given that motorists, traveling at freeway speeds, 

would only view the Sloan VMF and UPRR rail connection for several seconds, and that the site is located 

adjacent to existing industrial development and transportation infrastructure, the proposed Sloan VMF 

would be somewhat consistent with the existing character and would only slightly reduce the visual 

quality. Mitigation Measures VIS-3, VIS-4, and VIS-5 would still apply to minimize impacts to visual 

quality resulting from the Sloan VMF. These measures shall include coordinating with stakeholder 

agencies to create a unified aesthetic theme that supports the aesthetic goals of the community, and to 

collaborate on decisions regarding specific design elements. The aesthetic treatment of the structures 

shall involve color, texture, and patterns that tie into the Brightline West Project's Project Aesthetic and 

Landscape Masterplan (PALM), to create a visual link between the structures and other project elements 

along the corridor while also tying in with the overall unified corridor concept. The Sloan VMF would not 

result in substantial changes in the evaluation of permanent effects to visual quality disclosed in the

DesertXpress EIS or September 2020 Reevaluation.

5.6.3 MITIGATION MEASURES

The following mitigation measures established in the DesertXpress EIS and revised in the September 

2020 Reevaluation would avoid adverse effects to visual resources:

• Mitigation Measure VIS-1: Rail Features

• Mitigation Measure VIS-2: Victor Valley Station Features

• Mitigation Measure VIS-3: Maintenance Facility Features

• Mitigation Measure VIS-4: Contour Grading

• Mitigation Measure VIS-5: Light and Glare Reduction

• Mitigation Measure VIS-6: Educational Displays

• Mitigation Measure VIS-7: Construction Site Management

• Mitigation Measure VIS-8: Construction Site Lighting

• Mitigation Measure VIS-9: Visual Screening

• Mitigation Measure VIS-10: Freeway Landscaping

5.7 CULTURAL RESOURCES 

This section evaluates whether the Sloan VMF would result in substantial changes to the evaluation of 

effects to archaeological resources and historic built resources discussed in the DesertXpress EIS and 

September 2020 Reevaluation. 

5.7.1 REGULATORY UPDATES

No updates to Federal regulations governing cultural resources have occurred since the September 2020 

Reevaluation that would pertain to the Project. FRA is the lead federal agency for compliance with 

Section 106 of the NHPA for the Project. 
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5.7.2 EFFECTS ANALYSIS

As described in Section 4.7, FRA conducted a detailed analysis of the Project’s potential effects to 

cultural resources, which also informed FRA’s consultation under Section 106 of the NHPA. The Project 

could result in effects to cultural resources by affecting cultural setting (e.g., introducing new visual or 

noise effects) and by physical destruction or alteration. Through consultation, FRA was informed that 

the Project could encounter cultural resources, specifically archeological resources, that are of cultural 

and religious significance to federally recognized tribes. These resources may not be obvious from the 

surface or existing historical records and may require archeological investigation and further 

consultation to identify.

ARCHAEOLOGICAL RESOURCES

The proposed Sloan VMF would be located on BLM land in Nevada. FRA coordinated with BLM to 

determine whether any archeological resources were previously identified within the area of the Sloan 

VMF footprint. FRA completed an archaeological inventory (including intensive pedestrian and 

subsurface survey, records search, and Tribal consultation) of the portion within the current Area of 

Potential Effect (APE) Area of Direct Impact (ADI) (i.e., ROW) and limited observation of the portion 

within the APE Area of Indirect Impact (AII) identified approximately 30 archaeological sites: light lithic 

scatters and historic period refuse dumps similar in nature to those identified at the previously 

considered Dale Evans OMSF site. The archeological inventory of the Sloan VMF included a records 

search and visual observation from a distance of where it overlaps with the current APE-ADI and APE-AII. 

Based on these results, FRA does not expect to encounter any significant archeological resources that 

would be affected by the Sloan VMF.63

BUILT HISTORIC RESOURCES

A built environment review was conducted for the Sloan VMF site, which included analysis of historic US 

Geological Survey maps between 1910 and 1960, historic aerial photographs of the site, and Google 

Earth. The review determined that no historic structures, roads, or trails were identified within the Sloan 

VMF footprint.64

5.7.3 MITIGATION MEASURES

The following mitigation measures established in the DesertXpress EIS and revised in the September 

2020 Reevaluation would avoid, minimize, or resolve adverse effects to cultural resources:

• Mitigation Measure CR-1: Avoidance of Archaeological Resources

• Mitigation Measure CR-2: Evaluation

• Mitigation Measure CR-3: Treatment

• Mitigation Measure CR-4: Monitoring

• Mitigation Measure CR-5: Preconstruction Meeting and Worker Awareness Training

63 FRA will conduct any required archeological investigation and evaluation efforts of this area in accordance with the 2023 PA 

executed for the Project. If FRA determines the Project will result in adverse effects to historic properties, FRA will resolve 

those effects through the procedures established in the 2023 PA.

64 Please see above.
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• Mitigation Measure CR-6: Human Remains and Stop Work Requirement

• Mitigation Measure CR-7: Annual Reporting

• Mitigation Measure CR-8: Quarterly Reporting

5.8 HYDROLOGY AND WATER QUALITY

This section evaluates whether the Sloan VMF would result in substantial changes to the evaluation of 

effects to hydrology and water quality discussed in the DesertXpress EIS and September 2020 

Reevaluation. 

5.8.1 REGULATORY UPDATES

No updates to state or local regulation that pertain to the modified Project’s effects on hydrology and 

water quality have occurred since the September 2020 Reevaluation. The environmental analysis 

conducted in the DesertXpress EIS, the September 2020 Reevaluation, and this Reevaluation evaluates 

effects of hydrology, water quality, drainage patterns, and stormwater runoff to aquatic resources 

throughout the Project area regardless of WOTUS jurisdiction. Therefore, there are no Federal 

regulations that would result in substantial changes to construction or operation of the Project.

5.8.2 EFFECTS ANALYSIS

AQUATIC FEATURES WITHIN THE MODIFIED FOOTPRINT

The DesertXpress EIS and September 2020 Reevaluation identified aquatic resources that would be 

affected by implementation of the Project. The drainage features within the rail alignment evaluated in 

the DesertXpress EIS and September 2020 Reevaluation were classified as “Riverine Ephemeral.”

65

Riverine Ephemeral drainage features were evaluated for potential impacts resulting from 

implementation of Project features, including station sites, ancillary features, TCAs, and the rail 

alignment. Therefore, impacts to these features are not considered a new type of impact resulting from 

the Project modifications.

The Sloan VMF would require 246 acres of permanent footprint and 105 acres of temporary footprint. 

The permanent and temporary Sloan VMF footprint would encounter numerous hydrological features, 

shown in Figure 5-1, which are comprised of ephemeral drainages and ditches. The exact number of 

linear feet impacted and the location of such impacts may vary based on final design and the 

implementation of mitigation measures. Because these drainage features are similar in classification and 

quality to those features previously evaluated, impacts to these features are not considered a new type 

of impact resulting from the Project modifications. The Sloan VMF would not result in substantial 

changes in the evaluation of alteration to existing drainage patterns from construction of the 

DesertXpress EIS or September 2020 Reevaluation.

65 Riverine Ephemeral features are defined in: Cowardin, L.M., V. Carter, F.C. Golet & E.T. LaRoe. 1979. Classification of 

wetlands and deepwater habitats of the United States. USDI Fish & Wildlife Service, Biological Services Program. FWS/OBS79/31. 103 pp
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Figure 5-1 Sloan VMF Site – Aquatic Resources Delineation Map 
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WATER QUALITY

The DesertXpress EIS and September 2020 Reevaluation identified that construction-period water 

quality effects would result from increased erosion and sedimentation during grading and excavation, as 

well as from accidental spills or improper storage of hazardous materials. Additionally, operational 

water quality effects would result from polluted stormwater runoff generated at the stations and 

maintenance facilities.

Construction and operations activities for the Sloan VMF would occur within a similar scope to those 

anticipated for the previously evaluated maintenance facilities assessed in the DesertXpress EIS and 

September 2020 Reevaluation. Additionally, the Sloan VMF would be located in a similar general area to 

maintenance facilities previously evaluated, adjacent to the I-15 freeway ROW. The DesertXpress EIS 

and September 2020 Reevaluation concluded that Mitigation Measures HYD-1 through HYD-4 would 

minimize adverse effects to hydrological resources during construction and operation; these mitigation 

measures would still apply to the Sloan VMF. Therefore, the Sloan VMF would not result in substantial 

changes in the evaluation of water quality impacts of the DesertXpress EIS or September 2020 

Reevaluation.

ALTERATION OF EXISTING DRAINAGE PATTERNS 

Construction 

The DesertXpress EIS determined that Project construction would potentially alter drainage patterns 

through the exposure of soils susceptible to erosion during earthmoving activities. The September 2020 

Reevaluation determined the September 2020 modifications would require a slightly shorter 

construction period and less earthmoving activity since the overall Project footprint would be reduced. 

The Sloan VMF would require an additional 105 acres of temporary footprint for the modified Project (as 

evaluated in Section 4.0). These newly considered TCAs would be located in the same general area

previously evaluated in the DesertXpress EIS and September 2020 Reevaluation, within 1.5 miles from 

the I-15 freeway corridor. Mitigation Measure HYD-2 would still be applied to reduce impacts on existing 

drainage patterns during construction. Therefore, the Sloan VMF would not result in substantial changes 

in the evaluation of alteration to existing drainage patterns from construction compared with the 

DesertXpress EIS or September 2020 Reevaluation.

Operation

The DesertXpress EIS determined that the alignment and ancillary features would cross numerous 

ephemeral hydrological features between Apple Valley and Las Vegas and could alter drainage patterns 

along the alignment. 

As depicted in Figure 5-1, the Sloan VMF footprint would cross numerous hydrological features, 

introducing approximately 246 acres of permanent footprint. These hydrological features are nonjurisdictional waters not currently subject to the USACE’s permitting regulations. Mitigation Measure 

HYD-5 would be applied to reduce impacts from the Sloan VMF on existing drainage patterns. The Sloan 

VMF would not result in substantial changes in the evaluation of alteration to existing drainage patterns 

from operations compared with the DesertXpress EIS or September 2020 Reevaluation.
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FLOOD FLOW IMPEDIMENT 

Since the September 2020 Reevaluation, the 1 percent annual chance floodplain boundaries have not 

changed.66 The Sloan VMF would not encounter designated 1 percent annual chance flood plains. The 

Sloan VMF would not result in changes in the evaluation of floodplains of the DesertXpress EIS or 

September 2020 Reevaluation.

ADDITIONAL SOURCES OF STORMWATER RUNOFF

Construction

The DesertXpress EIS determined that Project construction could introduce new sources of polluted 

stormwater runoff through the release of construction-related chemicals, especially from TCAs. The 

September 2020 Reevaluation established the reduction of the overall 2020 Project footprint compared 

to the DesertXpress EIS Project footprint would allow for a slightly shorter construction period and a 

reduction in the use of construction-related chemicals. Reduction of the intensity of the construction 

activities during the period would reduce the potential for chemical releases by shortening the amount 

and time chemicals would be stored and used within the construction footprint, resulting in a beneficial 

effect.

While the Sloan VMF would require additional permanent and temporary footprint, the overall modified 

Project footprint would not be significantly larger than the original project footprint or the footprint 

evaluated in the September 2020 Reevaluation, because of footprint reductions in other areas.

Therefore, the intensity of the construction activities, which could affect the potential for chemical 

releases and the amount and time chemicals would be stored and used within the construction 

footprint, would not substantially differ. Mitigation Measures HYD-2, HYD-3, and HYD-4 would still be 

applied to reduce impacts from chemical releases during construction. The Sloan VMF would not result 

in substantial changes in the evaluation of stormwater runoff during construction, compared with the 

DesertXpress EIS or September 2020 Reevaluation.

Operation

The DesertXpress EIS determined that new impervious surfaces at the station and maintenance facilities 

could produce increased stormwater runoff. The Sloan VMF would introduce approximately 27 acres of 

impervious surface at the proposed site. The Sloan VMF would not change the September 2020 

Reevaluation’s conclusions regarding polluted runoff because the quantity of impervious surface areas 

included in the modified Project, including the Sloan VMF, would not substantially differ from the 

surface areas evaluated in the September 2020 Reevaluation or DesertXpress EIS. Therefore, the Sloan 

VMF would not result in substantial changes in the evaluation of stormwater runoff during operations, 

compared with the DesertXpress EIS or September 2020 Reevaluation.

REDUCTION IN GROUNDWATER AVAILABILITY

Mitigation Measure HYD-10, developed in the DesertXpress EIS and revised in the September 2020 

Reevaluation, would still apply to the Project including the Sloan VMF, and would require water supply 

for construction, operation, and maintenance activities be obtained from existing water purveyors 

instead of surface or groundwater resources. Therefore, the Sloan VMF would not result in substantial 

66 California Department of Water Resources. 2022. Best Available Map. https://gis.bam.water.ca.gov/bam/. Accessed: April 

2022; Federal Emergency Management Agency. 2021. FEMA Flood Map Service Center. https://msc.fema.gov/portal/home. 

Accessed: April 2022.
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changes in the evaluation of groundwater availability of the DesertXpress EIS or September 2020 

Reevaluation.

WATERS OF THE UNITED STATES

The Sloan VMF is located within 1.5 miles from the I-15 freeway corridor and would encounter 

ephemeral streams (see Figure 5-1). These hydrological features are non-jurisdictional waters not 

currently subject to the USACE’s permitting regulations. Mitigation Measure HYD-5 would still apply to 

reduce hydraulic impacts where the Sloan VMF would encounter ephemeral drainages. Therefore, the 

Sloan VMF would not result in substantial changes in the evaluation of WOTUS impacts as disclosed in 

the DesertXpress EIS or September 2020 Reevaluation.

5.8.3 MITIGATION MEASURES

The following mitigation measures established in the DesertXpress EIS and revised in the September 

2020 Reevaluation would avoid adverse effects to hydrology and water quality:

▪ Mitigation Measure HYD-1: Incorporate Site-Specific Water Treatment Devices

▪ Mitigation Measure HYD-2: Implement Construction-Related Best Management Practices

▪ Mitigation Measure HYD-3: Comply with the National Pollutant Discharge Elimination System 

(NPDES) Construction General Permit

▪ Mitigation Measure HYD-4: Implement Spill Prevention, Control, and Countermeasure Plan

▪ Mitigation Measure HYD-5: Proper Design of Drainage Systems

▪ Mitigation Measure HYD-6: Reduce Encroachment into the 100-Year Floodplain.

▪ Mitigation Measure HYD-7: No Storage of Construction Equipment or Materials within the 100-Year 

Floodplain

▪ Mitigation Measure HYD-9: Minimize Impacts of Temporary Construction Areas on Water Resources

▪ Mitigation Measure HYD-10: Minimize Impacts on Water Availability

▪ Mitigation Measure BIO-1: Conduct Mandatory Environmental Awareness Training Program

▪ Mitigation Measure BIO-3: Conduct Construction Monitoring

• Mitigation Measure BIO-5: Confine Construction Equipment to a Designated Work Zone (Including 

Access Roads) at Each Project Site

5.9 GEOLOGY AND SOILS

This section evaluates whether the Sloan VMF would result in substantial changes to the evaluation of 

effects to geology and soils discussed in the DesertXpress EIS and September 2020 Reevaluation.

5.9.1 REGULATORY UPDATES

FEDERAL AND STATE

No updates to state or local regulation that pertain to the modified Project’s effects on geology and soils

have occurred since the September 2020 Reevaluation.
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5.9.2 EFFECTS ANALYSIS

SURFACE FAULT RUPTURE AND GROUND SHAKING 

As previously evaluated in the DesertXpress EIS, potential rupture of faults that cross the study area 

would manifest in relative displacement of ground across the fault surface. Typically, since the active 

faults crossing the alignment are strike-slip faults, the displacement would be anticipated in a horizontal 

direction, but some vertical component of offset may occur. Fault rupture damage could include offset

damage to portions of at-grade rail lines where they cross the fault rupture; damage to structural 

elements of the rail line such as aerial guideways or bridges that are placed across a fault rupture; or 

damage to facilities built across a fault rupture. However, faults in the Las Vegas Valley, including where 

the Sloan VMF would be located, are indicated as active on the geologic maps reviewed, but the activity 

is attributed to subsidence, and not tectonic activity, and the potential for surface rupture due to an 

earthquake is considered low. Additionally, Mitigation Measures GEO-1 and GEO-2 would apply to the 

Sloan VMF reduce impacts from seismic hazards. Thus, the Sloan VMF would not result in substantial 

changes in the evaluation of surface fault rupture and ground shaking impacts of the DesertXpress EIS or 

September 2020 Reevaluation.

LIQUEFACTION, SETTLEMENT, CORROSIVE SOILS, EXPANSIVE SOILS, LANDSLIDES, AND SHALLOW 

GROUNDWATER

The modified Project includes new permanent footprint for the Sloan VMF. However, the modified 

Project would not change the conclusions regarding soil hazards because these areas of new footprint 

would be near areas previously analyzed in the DesertXpress EIS and September 2020 Reevaluation, 

encountering similar soil and groundwater conditions. Additionally, Mitigation Measures GEO-3, GEO-5, 

GEO-6, GEO-7, and GEO-10 would apply to the Sloan VMF to address the need for site-specific 

evaluation of soil and groundwater conditions. Thus, the Sloan VMF would not result in substantial 

changes in the evaluation of liquefaction, settlement, corrosive soil, expansive soil, landslide, or shallow 

groundwater impacts of the DesertXpress EIS or September 2020 Reevaluation.

DAM INUNDATION

Inundation has the potential to occur due to dam failure. The Sloan VMF would not be located in an area 

with the potential for dam inundation.

GROUND FISSURES 

The DesertXpress EIS identified the Las Vegas area, including the Sloan VMF site, as susceptible to 

ground fissures. However, Mitigation Measure GEO-12 would still be applied to reduce the impact of 

ground fissures, and the Sloan VMF would not result in substantial changes in the evaluation of ground 

fissure impacts of the DesertXpress EIS or September 2020 Reevaluation.

CALICHE/HARD ROCK EXCAVATION 

The DesertXpress EIS identified Quaternary alluvium in the desert of southern Nevada contains 

scattered layers of caliche will likely be encountered during construction of the Project. The Sloan VMF 

would not change the DesertXpress EIS conclusions regarding caliche and hard rock excavation because 

the Project would remain of a similar scope and geographic location. Thus, the Sloan VMF would not 

result in substantial changes in the evaluation of caliche and hard rock excavation impacts of the 

DesertXpress EIS or September 2020 Reevaluation.
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5.9.3 MITIGATION MEASURES 

The following mitigation measures established in the DesertXpress EIS and revised in the September 

2020 Reevaluation would avoid adverse geology and soils effects. 

▪ Mitigation Measure GEO-1: Surface Fault Rupture

▪ Mitigation Measure GEO-2: Ground Shaking

▪ Mitigation Measure GEO-3: Liquefaction

▪ Mitigation Measure GEO-4: Dam Inundation

▪ Mitigation Measure GEO-5: Settlement

▪ Mitigation Measure GEO-6: Corrosive Soils

▪ Mitigation Measure GEO-7: Expansive Soils

▪ Mitigation Measure GEO-8: Landslides

▪ Mitigation Measure GEO-9: Caliche/Hard Rock Excavation

▪ Mitigation Measure GEO-10: Shallow Groundwater

▪ Mitigation Measure GEO-12: Ground Fissures

5.10 PALEONTOLOGICAL RESOURCES 

This section evaluates whether the Sloan VMF would result in substantial changes to the evaluation of 

effects to paleontological resources discussed in the DesertXpress EIS and September 2020 

Reevaluation.

5.10.1 REGULATORY UPDATES 

FEDERAL AND STATE

No updates to state or local regulation that pertain to the modified Project’s effects on paleontological 

resources have occurred since the September 2020 Reevaluation.

5.10.2 EFFECTS ANALYSIS

The scale and severity of impacts from the Sloan VMF would be minor. While the Sloan VMF would 

introduce Project footprint not considered in the DesertXpress EIS or September 2020 Reevaluation, this

new footprint would be relatively minimal and would be constructed over previously evaluated geologic 

units. Additionally, Mitigation Measures CR-7 through CR-13 would still apply to minimize impacts on 

paleontological resources from the Project. Thus, the Project modifications would not result in 

substantial changes in the evaluation of paleontological impacts of the DesertXpress EIS or September 

2022 Reevaluation.

5.10.3 MITIGATION MEASURES 

The following mitigation measures established in the DesertXpress EIS and revised in the September 

2020 Reevaluation would avoid adverse effects to paleontological resources:

▪ Mitigation Measure CR-7: Annual Reporting

▪ Mitigation Measure CR-8: Quarterly Reporting

▪ Mitigation Measure CR-9: Further Evaluation of Geologic Units

▪ Mitigation Measure CR-10: Preconstruction Meeting and Worker Awareness Training

▪ Mitigation Measure CR-11: Paleontological Monitoring
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▪ Mitigation Measure CR-12: Stop Work Requirement

▪ Mitigation Measure CR-13: Fossil Recovery and Curation

5.11 HAZARDOUS MATERIALS

This section evaluates whether the Sloan VMF would result in substantial changes to the evaluation of 

effects to hazardous materials discussed in the DesertXpress EIS and September 2020 Reevaluation.

5.11.1 REGULATORY UPDATES

FEDERAL

No updates to federal or state regulations that pertain to the modified Project’s effects on hazardous 

materials have occurred since the September 2020 Reevaluation.

5.11.2 EFFECTS ANALYSIS

SITES OF ENVIRONMENTAL CONCERN

The Sloan VMF may encounter new sites of environmental concern. However, the sites would be 

unlikely to result in new types or higher quantities of hazardous material effects that were not evaluated 

in the DesertXpress EIS or September 2020 Reevaluation. The DesertXpress EIS also developed 

Mitigation Measures HAZ-2 and HAZ-4 to reduce potential hazardous material impacts associated with 

contamination encountered during Project construction and would apply to construction of the Sloan 

VMF. Thus, the Sloan VMF would not result in substantial changes in the evaluation of sites of 

environmental concern impacts of the DesertXpress EIS or September 2020 Reevaluation.

UNIDENTIFIED HAZARDOUS MATERIALS

The DesertXpress EIS determined that the Project could encounter previously unidentified hazardous 

materials during construction. The Sloan VMF would not change the DesertXpress EIS conclusions 

regarding unidentified hazardous materials because it would be constructed in similar locations as 

analyzed in the DesertXpress EIS and September 2020 Reevaluation. Additionally, since the modified 

Project footprint has not changed substantially, the scale, location, and severity of impacts from 

unidentified hazardous materials would be similar to those previously identified in the DesertXpress EIS 

and September 2020 Reevaluation. Furthermore, Mitigation Measures HAZ-3 and HAZ-4 would still be 

applied to address risks associated with unidentified hazardous materials. Thus, the Sloan VMF would 

not result in substantial changes in the evaluation of unidentified hazardous material impacts of the 

DesertXpress EIS or September 2020 Reevaluation.

BUILDINGS CONSTRUCTED BEFORE 1980

The Sloan VMF site is currently undeveloped, and therefore demolition would not be required.

Therefore, there would be no risk of exposure of the public and/or the environment to hazardous 

materials, such as lead based paint and asbestos containing materials. The Sloan VMF would not result 

in substantial changes in the evaluation of impacts from buildings constructed before 1980 of the 

DesertXpress EIS or September 2020 Reevaluation.

NATURALLY OCCURRING ASBESTOS AND ERIONITE 

NOA and erionite are naturally occurring hazardous materials with the potential to occur in the Project 

vicinity that were not considered in the DesertXpress EIS but were evaluated in the September 2020 
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Reevaluation. NDOT informed FRA that the presence of NOA could be found in certain rock types 

present in Nevada, given NDOT’s knowledge of projects that have occurred since the DesertXpress EIS. 

The September 2020 Reevaluation assessed two sections of the September 2020 Project alignment 

overlaying rock types with potential to contain NOA and erionite. The first section was at the south end 

of Ivanpah Valley south of Jean, which exhibited a low-to-moderate risk for NOA, and the second section 

was located approximately three miles north of Jean, which exhibits a moderate-to-high risk for erionite. 

Based on these findings, NOA and erionite were determined to be unlikely to occur within the 

September 2020 Project footprint. The Sloan VMF site is located approximately 9 miles north from the 

nearest location of rock types potentially containing NOA and erionite, and thus would not occur near

these previously evaluated areas. As such, the Sloan VMF is not anticipated to encounter NOA and 

erionite. Thus, the Sloan VMF would not result in substantial changes in the evaluation of NOA and 

erionite of the September 2020 Reevaluation.

5.11.3 MITIGATION MEASURES 

The following mitigation measures identified in the DesertXpress EIS would avoid adverse hazardous 

material effects:

▪ Mitigation Measure HAZ-1: Structures Built Prior to 1980

▪ Mitigation Measure HAZ-2: Contaminated Soil and/or Groundwater

▪ Mitigation Measure HAZ-3: Previously Unidentified Hazardous Materials

▪ Mitigation Measure HAZ-4: Hazardous Material Disposal

▪ Mitigation Measure HAZ-5: Operationally Generated Hazardous Materials

5.12 AIR QUALITY AND GLOBAL CLIMATE CHANGE

This section evaluates whether the Sloan VMF would result in substantial changes to the evaluation of 

effects on air quality and global climate change discussed in the DesertXpress EIS and September 2020 

Reevaluation. As previously established in the September 2020 Reevaluation, the September 2020 

Project modifications resulted in fewer criteria pollutants and greenhouse gas (GHG) emissions during 

construction and operation compared to the evaluation of air quality and global climate change 

disclosed in the DesertXpress EIS due to reductions in proposed construction activities and the overall 

Project footprint.

5.12.1 REGULATORY UPDATES

No updates to Federal, California state, or local regulations that pertain to the modified Project’s effects 

on energy have occurred since the September 2020 Reevaluation. The only relevant regulatory update 

since September 2020 is the passing of Nevada Senate Bill 448 in June 2021. This law advances the 

energy portfolio requirements for the state of Nevada, requiring utilities to forecast a path to achieve an 

80 percent reduction in carbon dioxide emissions from 2005 levels by 2030, facilitating Nevada’s goal to 

reach 100 percent renewable electricity generation by 2050.67 This regulatory update would not result in 

substantial changes in the evaluation of effects to air quality and global climate change disclosed in the 

September 2020 Reevaluation.

67 Nevada Legislature. 2021. SB448. https://www.leg.state.nv.us/App/NELIS/REL/81st2021/Bill/8201/Text. Accessed April 2022.
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5.12.2 EFFECTS ANALYSIS

CONSTRUCTION 

Emissions associated with the Sloan VMF would be temporary and would cease when construction 

activities are complete. Since the emissions intensity of equipment and trucks varies by year and trend 

down over time due to fleet turnover (i.e., emission factors for construction equipment were higher in 

2020 than current emissions expected in 2022), it is expected that emissions from individual pieces of 

off-road equipment, passenger vehicles, and trucks would be cleaner and emit fewer criteria pollutants 

and GHGs during construction of the modified Project. Additionally, continuous updates to Federal and 

state plans, policies, regulations, and Eos are still being introduced that clarify new, or expand upon 

previous air quality and GHG emission reduction goals, such as Nevada Senate Bill 448 (see Section 

5.12.1). The benefits of these regulations and policies to the emissions generated during Sloan VMF 

construction would be realized throughout the construction period. Additionally, Mitigation Measures 

AQ-1, AQ-3, and AQ-5 would still apply to reduce construction air quality effects from the Sloan VMF. 

Thus, the Sloan VMF would not result in substantial changes in the evaluation of construction-period air 

quality and GHG emission impacts of the DesertXpress EIS or September 2020 Reevaluation.

OPERATION 

Energy Demand Emissions

The Sloan VMF would be utilized for storing and mobilizing trains for daily operations. The anticipated 

annual electricity demand for the modified Project, including the Sloan VMF, is not anticipated to 

change significantly from what was evaluated in the September 2020 Reevaluation, since the buildout 

level of operations and train activity would not differ substantially. Therefore, the Sloan VMF would not 

result in substantial changes in the evaluation of operational air quality or GHG emission impacts of the 

DesertXpress EIS or September 2020 Reevaluation.

Carbon Monoxide Concentrations

The Sloan VMF will be a permanent workplace for approximately 100 employees related to the

maintenance of the Brightline West train fleet. The September 2020 Reevaluation established that the 

modified Project would not result in operational CO hotspot formation conditions at the station sites. It 

is reasonable to assume the proposed stations would result in relatively more traffic congestion and CO 

emissions at nearby roadways and intersections from potential passengers driving to access the 

passenger stations, when compared with the Sloan VMF from permanent employees driving to work.

Therefore, it is not anticipated the Sloan VMF would result in substantial changes in the evaluation of CO 

emission impacts of the DesertXpress EIS or September 2020 Reevaluation.

5.12.3 MITIGATION MEASURES

5.13 NOISE AND VIBRATION

This section evaluates whether the Sloan VMF would result in substantial changes to the evaluation of 

effects to noise and vibration sensitive receptors discussed in the DesertXpress EIS and September 2020 

Reevaluation.
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5.13.1 REGULATORY UPDATES

FEDERAL AND STATE

No updates to federal or state regulations that pertain to the modified Project’s effects on noise and 

vibration quality have occurred since the September 2020 Reevaluation.

5.13.2 EFFECTS ANALYSIS

CONSTRUCTION NOISE 

The Sloan VMF would require 105 acres of temporary south of Sloan near Segment 6, but would not 

impact sensitive receivers as there are none located within 400 feet of the Sloan VMF footprint, the 

maximum distance in which construction activities could result in noise effects, as disclosed in the 

September 2020 Reevaluation. Construction techniques have not changed, and TCAs would be restored 

and vacated upon completion of construction. Additionally, Mitigation Measure NV-10 would still apply 

to minimize construction noise effects from the Project to sensitive receivers. The Project modifications 

would not result in substantial changes in the evaluation of construction noise impacts of the 

DesertXpress EIS or September 2020 Reevaluation.

CONSTRUCTION VIBRATION 

The Sloan VMF require 105 acres of temporary footprint south of Sloan near Segment 6 but would not 

impact sensitive receivers as there are none located within 50 feet from the geometric center of the 

worksite. Construction techniques have not changed, and TCAs would be restored and vacated upon 

completion of construction. Additionally, Mitigation Measure NV-10 would still apply to minimize 

construction vibration effects from the Project to sensitive receivers. The Project modifications would 

not result in substantial changes in the evaluation of construction noise impacts of the DesertXpress EIS

or September 2020 Reevaluation.

HIGH-SPEED RAIL NOISE

There are no sensitive receivers within 180 feet (the noise contour for undeveloped areas established in 

the DesertXpress EIS) from the Sloan VMF. Additionally, Mitigation Measures NV-1, NV-3, and NV-4 

would still apply to minimize potential noise effects from high-speed rail operations. Thus, the Project 

modifications would not result in substantial changes in the evaluation of operational noise impacts of

the DesertXpress EIS or September 2020 Reevaluation.

TRAFFIC NOISE

The Sloan VMF would employ approximately 100 workers and as such, would not introduce enough cars 

as to generate a substantial amount of noise associated with traffic. Therefore, the Project modifications 

would not result in substantial changes in the evaluation of traffic noise impacts of the DesertXpress EIS

or September 2020 Reevaluation.

OPERATIONAL VIBRATION 

The Sloan VMF would not result in new vibration impacts since these modifications would not be in 

close proximity to existing sensitive receivers. Thus, the Project modifications would not result in 

substantial changes in the magnitude of operational vibration impacts of the DesertXpress EIS or 

September 2020 Reevaluation.
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5.13.3 MITIGATION MEASURES

The following mitigation measures established in the DesertXpress EIS and revised in the September 

2020 Reevaluation would avoid adverse effects from noise and vibration: 

▪ Mitigation Measure NV-1: Noise Barriers

▪ Mitigation Measure NV-3: Building Sound Insulation

▪ Mitigation Measure NV-4: Property Acquisitions or Easements

▪ Mitigation Measure NV-10: Construction Noise and Vibration Measures

5.14 ENERGY 

This section evaluates whether the Sloan VMF would result in substantial changes to the evaluation of 

effects from construction-related energy consumption, operational energy consumption, and peakperiod electricity demand discussed in the DesertXpress EIS and September 2020 Reevaluation. As 

previously established in the September 2020 Reevaluation, the September 2020 Project modifications 

did not result in substantial changes to the evaluation of energy impacts disclosed in the DesertXpress 

EIS.

5.14.1 REGULATORY UPDATES

No updates to Federal, California state, or local regulations that pertain to the modified Project’s effects 

on energy, including the Sloan VMF, have occurred since the September 2020 Reevaluation. The only 

relevant regulatory update since September 2020 is the passing of Nevada Senate Bill 448 in June 2021. 

This law advances the energy portfolio requirements for the state of Nevada, requiring utilities to 

forecast a path to achieve an 80 percent reduction in carbon dioxide emissions from 2005 levels by 

2030, facilitating Nevada's goal to reach 100 percent renewable electricity generation by 2050.68

Regional transition from fossil fuels could result in a slightly lower proportional energy savings resulting 

from the Project; however, this would not result in substantial changes in the evaluation of energy 

impacts of the DesertXpress EIS or September 2020 Reevaluation.

5.14.2 EFFECTS ANALYSIS

CONSTRUCTION-RELATED ENERGY CONSUMPTION

It is reasonable to assume that the Sloan VMF would require less construction-related energy 

consumption than the proposed stations, as the total permanent footprint of the facility and UPRR 

connection would be 246 acres, and the permanent footprint required for the stations is approximately 

409 acres (Victor Valley Station and Warm Springs Station are approximately 300 acres and 109 acres, 

respectively). As disclosed in the September 2020 Reevaluation, of the approximately 2.4 million 

MMBTU required for construction, approximately 0.16 million MBTU, or 6.5 percent of the total 

construction-related energy expenditure for the modified Project would be required for station

construction. Thus, it is not anticipated that the Sloan VMF would substantially increase the total 

anticipated energy consumption for constructing the modified Project and would not result in 

substantial changes in the evaluation of energy impacts from construction compared with the 

DesertXpress EIS or September 2020 Reevaluation.

68 Nevada Legislature. 2021. SB448. https://www.leg.state.nv.us/App/NELIS/REL/81st2021/Bill/8201/Text. Accessed April 2022.
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OPERATIONAL ENERGY CONSUMPTION 

Operational energy consumption compares the Project’s anticipated energy usage against the energy 

uses of other transportation modes along the Project corridor (e.g., automobiles). This evaluation 

calculates the reduction in VMT that would occur with implementation of the Project. The September 

2020 Reevaluation established the Project is anticipated to result in a net reduction of approximately 

502 million-mile VMT annually. Estimates regarding annual ridership diverted from automobiles during 

the build out year have not changed under the Project modifications, and the modified Project, including 

the Sloan VMF, would still divert a substantial amount of automobiles to rail within the I-15 freeway 

corridor. The Sloan VMF would not result in substantial changes in the evaluation of operational energy 

consumption of the DesertXpress EIS or September 2020 Reevaluation.

PEAK-PERIOD ELECTRICITY DEMAND 

It is assumed the Sloan VMF would not result in significant changes to operational energy use for the 

modified Project, since the length of the alignment and ridership projections which would represent the 

significant majority of operational energy use would remain consistent with the September 2020 

Project. Thus, it is anticipated that the previously assumed maximum hourly peak energy demand of 

44.2 MW from the September 2020 Reevaluation would not significantly change. Assuming all energy 

required for the Project is drawn from Nevada, the Project would utilize approximately 0.09 percent of 

the total regional energy demand. Thus, the modified Project would not adversely impact regional 

energy supply. Thus, the Sloan VMF would not result in substantial changes in the evaluation of peakperiod electricity demand impacts of the DesertXpress EIS or September 2020 Reevaluation.

5.14.3 MITIGATION MEASURES

The DesertXpress EIS and September 2020 Reevaluation both determined mitigation measures would 

not be necessary because the Project would result in an overall reduction in total energy consumption. 

As the modified Project, including the Sloan VMF, would still result in an overall reduction in total energy 

consumption, no mitigation measures would be applied.

5.15 BIOLOGICAL RESOURCES

This section assesses evaluates whether the Sloan VMF would result in substantial changes to the 

evaluation of effects to biological resources discussed in the DesertXpress EIS and September 2020 

Reevaluation. Refer to Attachment C, Biological Resources Technical Report, for further discussion of 

effects to biological resources in proximity to the modified Project, including the Sloan VMF.

5.15.1 REGULATORY UPDATES

Following shortly after the September 2020 Reevaluation, on May 6, 2021, the USFWS provided 

concurrence that re-initiation of formal consultation was unnecessary because none of the proposed 

changes met the re-initiation criteria at 50 CFR 402.16. The USFWS also acknowledged that Southern 

California Edison would apply to BLM for separate authorization for the construction of the two 

electrical substations and transmission lines that would supply power to the rail line. In addition, the 

USFWS issued revised desert tortoise protective measures for the Project’s Biological Opinion (FWS-SB20B0244-21TA0969) based on the modified Project 2020 footprint evaluated in the September 2020 

Reevaluation. These revised protective measures were incorporated into the September 2020 

Reevaluation. Re-initiation of formal consultation under Section 7 was unnecessary because impacts on 
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species listed as threatened or endangered and critical habitat were substantially reduced, and no new 

impacts would occur as a result of the Project modifications that were not previously addressed in the 

Biological Opinion issued for the Project.

5.15.2 EFFECTS ANALYSIS

INTRODUCTION OR SPREAD OF INVASIVE, NON-NATIVE WEED SPECIES INTO NATURAL VEGETATION 

COMMUNITIES

The effects related to the introduction and spread of invasive, non-native weed species would still apply 

to the Sloan VMF footprint. The implementation of Mitigation Measure BIO 4 (avoid dispersal) from the 

DesertXpress EIS would reduce or mitigate adverse effects from noxious weeds, and the Sloan VMF 

would not result in substantial changes in the evaluation of invasive, non-native weed species impacts of 

the DesertXpress EIS or September 2020 Reevaluation.

LOSS OF OR DAMAGE TO NATIVE VEGETATION COMMUNITIES

The effects related to the loss of or damage to native vegetation communities, as described in the 

DesertXpress DEIS, apply to the Sloan VMF. Based on the vegetation mapping, the Sloan VMF would 

permanently convert approximately 237.6 acres and temporarily affect approximately 104.0 acres of 

native vegetation communities. The presence of native vegetation communities which overlap with the 

Sloan VMF temporary and permanent footprint are depicted in Figure 5-2 below. Mitigation Measures 

BIO-5 (confine equipment), BIO-6 (revegetation), BIO-7 (retain topsoil), BIO-8 (restore topography), BIO9 (erosion control), and BIO-18 (Nevada compensatory mitigation) from the DesertXpress EIS would be 

implemented to avoid, minimize or mitigate adverse effects from loss of or damage to native vegetation 

communities. The Sloan VMF would not result in substantial changes in the evaluation of native 

vegetation community impacts of the DesertXpress EIS or September 2020 Reevaluation.
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Figure 5-2 Sloan VMF Site – Vegetation Communities Map
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SENSITIVE VEGETATION COMMUNITIES

There were no sensitive vegetation communities identified within the Sloan VMF footprint. Therefore, 

the Sloan VMF is anticipated to affect sensitive vegetation communities.

POTENTIAL EFFECTS ON SPECIAL-STATUS PLANT POPULATIONS

Penstemon bicolor ssp. roseus was not observed during the focused plant surveys at the Sloan VMF site. 

Based on input from the BLM District botanist and the botanists who performed the rare plant survey, 

no plant species with Federal (USFWS and BLM) status were observed or have the potential to occur 

within the Sloan VMF site. As such, effects on USFWS and BLM special-status plant populations are not 

expected. Estimates and/or direct counts of all cacti and yucca species within the Sloan VMF footprint 

were recorded, depicted in Table 6.3 2 of Attachment C.

The implementation of Mitigation Measures BIO-5 (confine equipment), BIO-14 (avoid known 

populations), and BIO-15 (mitigation) from the DesertXpress EIS would be implemented to reduce or 

mitigate adverse effects on sensitive plant populations.

POTENTIAL EFFECTS ON SPECIAL STATUS WILDLIFE

The Sloan VMF site is located west of the I-15 freeway ROW on undeveloped land, which provides 

habitat for special-status wildlife.

Desert Tortoise and Desert Tortoise Habitat

The effects related to construction and operational activities on desert tortoise individuals and desert 

tortoise habitat, as described in Section 3.14.2.3 of the DesertXpress DEIS, still apply to the modified 

Project 2022 footprint (Sloan VMF). 

A desert tortoise individual was observed during the focused rare plant surveys within Sloan VMF

footprint. Based on the vegetation mapping, the Sloan VMF footprint would permanently convert 

approximately 238 acres and temporarily affect approximately 104 acres of desert tortoise habitat. 

Implementation of Mitigation Measures BIO-1 (worker education program), BIO-2 (pre-construction 

surveys and fencing), BIO-3 (monitoring), BIO-5 (confine equipment), BIO-15 (prepare translocation 

plan), BIO-16 (final monitoring plan), BIO-18 (Nevada compensatory mitigation), and BIO-19 (exclusion 

fencing and culverts) from the DesertXpress EIS, as well as additional minimization and compensatory 

mitigation measures included in the new BO (Chapter 8), would reduce or mitigate adverse effects on 

desert tortoise and desert tortoise habitat. Thus, the Sloan VMF would not result in substantial changes 

in the evaluation of desert tortoise and desert tortoise habitat impacts of the DesertXpress EIS or 

September 2020 Reevaluation.

Nesting Raptors and Migratory Birds

Effects related to construction and operational activities on nesting raptors and migratory birds, as 

described in the DesertXpress EIS, would apply to the Sloan VMF site. Based on the vegetation mapping, 

the Sloan VMF footprint would permanently convert approximately 238 acres and temporarily affect 

approximately 104 acres of suitable nesting habitat. Mitigation Measures BIO-1 (worker education 

program), BIO-2 (pre-construction surveys and fencing), BIO 3 (monitoring), and BIO-5 (confine 

equipment) would be implemented to reduce or mitigate adverse effects on nesting raptors and 

migratory birds. Additionally, regulations under the Migratory Bird Treaty Act and the Bald and Golden 

Eagle Protection Act would apply to minimize the modified Project footprint effects on nesting raptors 
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and migratory birds. Thus, the Sloan VMF would not result in substantial changes in the evaluation of 

nesting raptors and migratory bird impacts of the DesertXpress EIS or September 2020 Reevaluation.

BLM Southern Nevada Sensitive Species

The entire Sloan VMF footprint occurs on BLM-administered public lands. As such, the 2017 Final BLM 

Southern Nevada special-status species lists were reviewed, and the special-status species were 

reviewed for their potential to occur within the Project area. The effects related to construction and 

operational activities on the BLM-sensitive species, as described in the DesertXpress EIS, would apply to 

the Sloan VMF footprint. These species include bats, reptiles such as banded Gila monster, desert 

horned lizard, desert iguana, Great Basin collard lizard, long-nosed leopard lizard, desert tortoise, 

chuckwalla, sidewinder, shovel-nosed snake, and a number of birds and raptors. Based on the 

vegetation mapping, the Sloan VMF footprint would permanently convert approximately 238 acres and 

temporarily affect approximately 104 acres of suitable habitat. Mitigation Measures BIO-1 (worker 

education program), BIO-2 (pre-construction surveys and fencing), BIO-3 (monitoring), and BIO-5 

(confine equipment) would be implemented to avoid direct mortality of these species. Thus, the Sloan 

VMF would not result in substantial changes in the evaluation of BLM Southern Nevada sensitive species 

impacts of the DesertXpress EIS or September 2020 Reevaluation.

Burrowing Owl

Burrowing owls are a BLM sensitive species. Effects related to construction and operational activities on 

burrowing owl, as described in the DesertXpress EIS, would apply to the Sloan VMF footprint. Based on 

the vegetation mapping, the Sloan VMF footprint would permanently convert approximately 246 acres 

and temporarily affect approximately 104 acres of suitable nesting habitat. Mitigation Measures BIO-1 

(worker education program), BIO-2 (pre-construction surveys and fencing), BIO-3 (monitoring), BIO-5 

(confine equipment), and BIO-21 (avoid or passively relocate owls) would be implemented to minimize 

or avoid potential loss or disturbance of burrowing owls. Thus, the Sloan VMF would not result in 

substantial changes in the evaluation of burrowing owl impacts of the DesertXpress EIS or September 

2020 Reevaluation.

Wildlife Movement

The effects related to construction and operational activities on wildlife movement, as described in the 

DesertXpress EIS, would apply to the Sloan VMF footprint. The Sloan VMF is located adjacent to the I-15 

freeway corridor, which serves as a major barrier for wildlife movement. Habitat fragmentation or 

isolation as a result of the Sloan VMF is not anticipated. Existing culverts and wildlife crossing locations 

under the I-15 freeway corridor would remain in place. The implementation of Mitigation Measures

BIO-3 (monitoring) and BIO-19 (exclusion fencing, culverts, and wildlife crossings) from the DesertXpress 

EIS, as well as minimization and mitigation measures outlined in the BO, would be implemented to 

reduce or mitigate adverse effects on wildlife movement. Thus, the Sloan VMF would not result in 

substantial changes in the evaluation of wildlife movement impacts of the DesertXpress EIS or 

September 2020 Reevaluation.

POTENTIAL EFFECTS ON SPECIAL MANAGEMENT LANDS

The Sloan VMF would not affect either USFWS-designated critical habitat or BLM ACEC. The entirety of 

the Sloan VMF facility occurs on BLM-administered public lands.
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5.15.3 MITIGATION MEASURES

FRA updated the mitigation measures provided in the 2011 Biological Opinion for the Project, and 

described in the September 2020 Reevaluation, after consultation with the USFWS. USFWS

recommended updates to the mitigation measures to reflect translocation plan strategy requirements, 

as well as a culvert assessment for the Sloan VMF site. FRA sent a concurrence letter to USFWS on 

August 11, 2023, and received USFWS concurrence on the revised mitigation measures on September 1, 

2023 (see Attachment B).

The mitigation measures developed in the DesertXpress EIS and revised since the September 2020 

Reevaluation would mitigate for and avoid adverse effects to biological resources. Refer to Attachment 

D, Mitigation Measure Summary, for the full list and descriptions of mitigation measures, which includes 

desert tortoise conservation measures, terms and conditions of the BO specific to desert tortoise, and 

general biological resource mitigation measures.

5.16 CUMULATIVE IMPACTS 

The evaluation of cumulative impacts for this Reevaluation considered impacts from the Project 

modifications, including the Sloan VMF, in combination with current, planned, and reasonably 

foreseeable projects in the Project vicinity. Overall, the modified Project’s contributions, including the 

Sloan VMF, to cumulative impacts would be unchanged or reduced because of the modified Project’s 

reduced footprint and location within the I-15 freeway ROW. Review of present and reasonably 

foreseeable projects within the Project vicinity did not identify new planned or programmed projects 

within or adjacent to the modified Project footprint that would substantially affect the cumulative 

impacts conclusions or assessment conducted in the DesertXpress EIS or September 2020 Reevaluation. 

Furthermore, the mitigation measures developed in the DesertXpress EIS and revised in the September 

2020 Reevaluation to reduce Project impacts would still apply to the modified Project, including the 

Sloan VMF, to reduce contributions to cumulative effects. Thus, the type and magnitude of impacts 

resulting from the Project modifications, including the Sloan VMF, would be comparable to those 

identified in the DesertXpress EIS and September 2020 Reevaluation.

6.0 Changes in Mitigation Measures

FRA has revised the mitigation measures included in the 2011 DesertXpress EIS to clarify roles and 

responsibilities, remove measures where impacts will be avoided, and incorporate recommendations 

from consultation. The mitigation measures are listed in Attachment D. 

7.0 Conclusion

This Reevaluation assessed the Project modifications against the proposed action described in the 

DesertXpress FEIS, ROD and FRA’s prior re-evaluation in September 2020. FRA concludes that the 

Project modifications would result in reduced overall impact from the Project, and would not result in 

significant environmental impacts that were not evaluated in the 2011 DesertXpress EIS. In addition, 

FRA did not identify any new information or circumstances relevant to Project’s environmental effects 

that would result in new significant impacts that were not evaluated in the 2011 DesertXpress EIS. FRA 

considered any changes to the affected environment, regulatory setting, and Project effects since FRA’s 

September 2020 Reevaluation and determined that the conclusions of the DesertXpress FEIS and ROD 

remain valid. 
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Through consultation under Section 106 of the NHPA, FRA determined the Project would result in 

adverse effects to historic properties and executed a Programmatic Agreement (PA) to prescribe a 

process for resolving adverse effects. Compliance with the terms of the PA satisfies FRA’s responsibilities 

under Section 106. Based on the assessment of effects to historic properties, FRA determined the 

Project would result in the use of archeological districts and sites. FRA evaluated the use of historic 

properties under Section 4(f) of the DOT Act and determined there was no feasible and prudent 

alternative to avoid the use of the Section 4(f) resource and that the Project included all possible 

planning to minimize harm. In addition, in compliance with Section 7 of the ESA, FRA informally 

consulted with the USFWS on the Project modifications. In consultation with FRA, USFWS recommended 

revisions to the mitigation measures, which are included in the revised Biological Opinion for the 

Project. On September 1, 2023, USFWS concurred that re-initiation of formal consultation under Section 

7 was not required for the Project.

Based on this information, FRA concludes that supplemental environmental analysis is not necessary for 

the proposed Project modifications. 
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