SECTION 4(F) AND 6(F) EVALUATIONS 

Brightline West Cajon Pass High-Speed Rail Project 

October 2022 

Prepared for 

Federal Railroad Administration 

Prepared by 

Circlepoint 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Contents 

Abbreviations and Acronyms ....................................................................................................... iv 

1. Introduction ............................................................................................................................ 7 

1.1. Laws, Regulations, and Orders....................................................................................... 9 

1.1.1. United States Department of Transportation Act (23 U.S.C. 138 and 49 

U.S.C. 303(c) (Section 4[f])..................................................................................... 9 

1.1.2. Section 6(f) of the Land and Water Conservation Fund Act (16 U.S.C. 

460l-8(f) and 36 C.F.R. Part 59.1) of 1965............................................................ 10 

1.1.3. National Historic Preservation Act (54 U.S.C. 300101 et seq.) including 

Section 106 of the National Historic Preservation Act, 54 U.S.C. 306108............ 10 

1.2. Definition of Study Area............................................................................................... 11 

1.2.1. Public Park and Recreation Lands, and Wildlife and Waterfowl Refuges ............ 11 

1.2.2. Historic Properties............................................................................................... 19 

1.3. Section 4(f) Applicability .............................................................................................. 20 

1.4. Section 4(f) Use Definition ........................................................................................... 21 

1.4.1. Permanent Use.................................................................................................... 21 

1.4.2. Temporary Occupancy......................................................................................... 21 

1.4.3. Constructive Use ................................................................................................. 21 

1.4.4. De Minimis Impact............................................................................................... 22 

1.5. Consultation ................................................................................................................ 22 

2. Project Description................................................................................................................ 23 

2.1. Background.................................................................................................................. 23 

2.2. Project Area ................................................................................................................. 23 

2.3. Purpose of and Need for the Project ........................................................................... 23 

2.3.1. Purpose ............................................................................................................... 23 

2.3.1. Need.................................................................................................................... 24 

2.4. Alternatives ................................................................................................................. 30 

2.4.1. No Build Alternative ............................................................................................ 30 

2.4.2. Build Alternative.................................................................................................. 31 

3. Section 4(f) Applicability Analysis.......................................................................................... 34 

3.1. Parks, Recreation Areas, and Wildlife and Waterfowl Refuges.................................... 35 

3.1.1. San Bernardino National Forest........................................................................... 47 

3.1.2. Baldy Mesa OHV Road ......................................................................................... 47 

3.1.3. Pacific Crest National Scenic Trail (PCT)............................................................... 47 

3.1.4. Cleghorn Ridge OHV Road ................................................................................... 48 

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3.1.5. Lower Lytle Creek Divide Road ............................................................................ 49 

3.1.6. Coyote Canyon Park ............................................................................................ 49 

3.1.7. Pacific Electric Trail.............................................................................................. 49 

3.1.8. Day Creek Channel Community Trail ................................................................... 50 

3.2. Cultural Resources ....................................................................................................... 50 

3.2.1. Description of Historic Built Environment and Archaeological Resources ........... 50 

4. Section 4(f) Use Assessment ................................................................................................. 57 

4.1. Parks, Recreation Areas, and Wildlife and Waterfowl Refuges.................................... 57 

4.1.1. San Bernardino National Forest........................................................................... 57 

4.1.2. Baldy Mesa OHV Road ......................................................................................... 58 

4.1.3. Cleghorn Ridge OHV Road ................................................................................... 59 

4.1.4. Lower Lytle Creek Divide Road ............................................................................ 59 

4.1.5. Pacific Crest National Scenic Trail (PCT)............................................................... 60 

4.1.6. Coyote Canyon Park ............................................................................................ 61 

4.1.7. Pacific Electric Trail.............................................................................................. 62 

4.1.8. Day Creek Channel Community Trail ................................................................... 63 

4.2. Cultural Resources ....................................................................................................... 63 

4.2.1. Historic Built Environment Resources ................................................................. 63 

4.2.2. Archaeological Resources.................................................................................... 70 

5. Section 4(f) Avoidance Alternatives ...................................................................................... 97 

6. Section 4(f) Measures to Minimize Harm/Least Harm Analysis ............................................ 97 

7. Section 6(f) Analysis .............................................................................................................. 97 

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Figures 

Figure 1-1. Project Area and Vicinity ............................................................................................................ 8 

Figure 1-2. Section 4(f) Parks and Recreation Resource Study Area – Map 1 of 7 .....................................12 

Figure 1-3. Section 4(f) Parks and Recreation Resource Study Area – Map 2 of 7 .....................................13 

Figure 1-4. Section 4(f) Parks and Recreation Resource Study Area – Map 3 of 7 .....................................14 

Figure 1-5. Section 4(f) Parks and Recreation Resource Study Area – Map 4 of 7 .....................................15 

Figure 1-6. Section 4(f) Parks and Recreation Resource Study Area – Map 5 of 7 .....................................16 

Figure 1-7. Section 4(f) Parks and Recreation Resource Study Area – Map 6 of 7 .....................................17 

Figure 1-8. Section 4(f) Parks and Recreation Resource Study Area – Map 7 of 7 .....................................18 

Figure 3-1. Section 4(f) Parks and Recreation Resources–- Overview........................................................36 

Figure 3-2. Section 4(f) Parks and Recreation Resources – Map 1 of 7 ......................................................37 

Figure 3-3. Section 4(f) Parks and Recreation Resources – Map 2 of 7 ......................................................38 

Figure 3-4. Section 4(f) Parks and Recreation Resources – Map 3 of 7 ......................................................39 

Figure 3-5. Section 4(f) Parks and Recreation Resources – Map 4 of 7 ......................................................40 

Figure 3-6. Section 4(f) Parks and Recreation Resources – Map 5 of 7 ......................................................41 

Figure 3-7. Section 4(f) Parks and Recreation Resources – Map 6 of 7 ......................................................42 

Figure 3-8. Section 4(f) Parks and Recreation Resources – Map 7 of 7 ......................................................43 

Tables 

Table 1. APE Delineation Values .................................................................................................................19 

Table 2. Ridership Forecast: Victor Valley to Rancho Cucamonga: Years 1 – 10 (millions) ........................28 

Table 3. Ridership Forecast: Victor Valley to Rancho Cucamonga: Years 11 – 20 (millions) ......................29 

Table 4. Park, Recreation Area, and Wildlife and Waterfowl Refuge Resources: No Use..........................44 

Table 5. Parks and Recreation Resources Evaluated for Section 4(f) Use ..................................................45 

Table 6. NRHP-Eligible Built Environment Historic Properties Within the APE ..........................................52 

Table 7. Section 4(f) Archaeological Resources within the APE..................................................................53 

Table 8. Section 4(f) Constructive Use Assessment of Built Environment Historic Properties Within the 

APE ..............................................................................................................................................................64 

Table 9. Section 4(f) Constructive Use Assessment of Archaeological Resources Within the APE ............71 

Attachments 

Attachment A: Area of Potential Effects Map and Built Resources Maps 

Attachment B: Additional Resources Considered 

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Abbreviations and Acronyms 

ADT average daily traffic 

APE Area of Potential Effects 

APE-ADI !rea of Potential Effects’ !rea of Direct Impact

APE-AII !rea of Potential Effects’ !rea of Indirect Impact

AT&SF Atchison, Topeka & Santa Fe Railway 

BNSF Burlington Northern and Santa Fe Railway 

ca. circa 

CalSTA California State Transportation Agency 

C.F.R. Code of Federal Regulations 

EA Environmental Assessment 

ESL Environmental Study Limits 

FHWA Federal Highway Administration 

FR Federal Register 

FRA Federal Railroad Administration 

HOV high-occupancy vehicle 

I- Interstate 

kV kilovolt 

LADWP Los Angeles Department of Water and Power 

LOD Limits of Disturbance 

LOS level of service 

LWCF Land and Water Conservation Fund 

MOU memorandum of understanding 

mph miles per hour 

N/A not applicable 

NPS National Park Service 

NEPA National Environmental Policy Act 

NHPA National Historic Preservation Act 

NRHP National Register of Historic Places 

OHV off-highway vehicle 

OWJ officials with jurisdiction 

PCT Pacific Crest Trail 

SCE Southern California Edison 

Section 106 Section 106 of the National Historic Preservation Act 

SHPO State Historic Preservation Officer 

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U.S.C. United States Code 

USDA United States Department of Agriculture 

USDOT United States Department of Transportation 

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1. Introduction 

This report provides the analysis to support the Federal Railroad !dministration’s (FRA) 

compliance with the provisions of 23 United States Code (U.S.C.) 138 and 49 U.S.C. 303.4(f) 

(Section 4[f]), and applicable sections of the Land and Water Conservation Fund (LWCF) Act of 

1965 (Section 6[f]) for the Brightline West Cajon Pass High Speed Rail Project (Project). The 

Project alignment and vicinity are shown on Figure 1-1. 

Under Section 4(f), an operating administration of the U.S. DOT may not approve a project that 

uses protected resources, unless one of the following conditions is met: 

• There is a finding of de minimis impact for use of a resource 

• If there are no prudent or feasible alternatives to such use, and the project includes all 

possible planning to minimize harm to such resources 

Section 4(f) resources are publicly owned lands of a park, recreation area, wildlife, or waterfowl 

refuge; or a historical site of national, state, or local significance that is listed on or eligible for 

listing on the National Register of Historic Places (NRHP) as determined by the federal, state, 

regional, or local officials with jurisdiction (OWJ) over the resource. The State Historic 

Preservation Officer (SHPO) is the OWJ over historic properties. Historic properties, including 

archaeological resources, may be publicly or privately owned. 

A use of a Section 4(f) resource occurs when land from the resource is permanently 

incorporated into a transportation facility; the temporary occupancy of land is adverse in terms 

of Section 4(f)’s preservationist purpose- or there is a constructive use of the resource.

The information contained in this chapter demonstrates the FRA’s compliance with Section 4(f), 

as follows: 

• Describes the statutory requirements associated with Section 4(f) 

• Identifies the resources protected by Section 4(f) in the Environmental Study Limits (ESL) 

• Preliminarily determines whether the Project would result in the use of those resources 

Section 6(f) resources are recreation resources created or improved with funds from the LWCF. 

Whereas Section 4(f) applies only to programs and policies undertaken by the U.S. DOT, Section 

6(f) compliance applies to programs and policies of any federal agency. Land purchased with 

these funds cannot be converted to non-recreational use without coordination with the 

California Department of Parks and Recreation and the U.S. Department of the Interior National 

Park Service (NPS), and mitigation that includes replacement of the quality and quantity of land 

used. Based on a thorough investigation of properties using the NPS LWCF Project List by 

County and Summary Reports website, no LWCF monies were used to acquire or develop any of 

the recreational resources in the Project’s study area. 

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Figure 1-1. Project Area and Vicinity 

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1.1. Laws, Regulations, and Orders 

1.1.1. United States Department of Transportation Act (23 U.S.C. 138 and 49 U.S.C. 303(c) 

(Section 4[f]) 

Projects undertaken by an operating administration of the U.S. DOT or projects that may 

receive federal funding or discretionary approvals from such an operating administration of the 

U.S. DOT must demonstrate compliance with Section 4(f). Section 4(f) protects publicly owned 

parks, recreational areas, and wildlife and waterfowl refuges. Section 4(f) also protects historic 

sites of national, state, or local significance located on public or private land that are listed on 

or eligible for listing on the NRHP. 

FR!’s Section 4(f) implementing regulations are in 23 Code of Federal Regulations (C.F.R.) Part 

774. FR! considers the interpretations provided in the Federal Highway !dministration’s 

(FHWA) Section 4(f) Policy Paper (FHWA 2012) when implementing these regulations. 

FRA may not approve the use of a Section 4(f) property, as described in 49 U.S.C. 303(c), unless 

it determines that there is no feasible and prudent alternative to avoid the use of the property 

and the action includes all possible planning to minimize harm resulting from such use, or the 

project has a de minimis impact consistent with the requirements of 49 U.S.C. 303(d) (see 

Section 1.4.4 for a definition of de minimis impacts). An alternative is not feasible if it cannot be 

built as a matter of sound engineering judgment. In determining whether an alternative is 

prudent, the FRA may consider if the alternative would result in any of the following: 

• The alternative does not meet the Project’s stated Purpose and Need

• The alternative would entail unacceptable safety or operational problems 

• After reasonable mitigation, the alternative would result in severe social, economic, or 

environmental impacts; severe disruption to established communities; severe 

disproportionate impacts on minority or low-income populations; or severe impacts on 

environmental resources protected under other federal statutes 

• The alternative would require additional construction, maintenance, or operational 

costs of an extraordinary magnitude 

• The alternative would pose other unique problems or unusual factors 

• The project would entail multiple factors that, while individually minor, cumulatively 

cause unique problems or impacts of extraordinary magnitude 

If the FRA determines there is both the use of a Section 4(f) property and that there is no 

prudent and feasible alternative to the use of a Section 4(f) resource, the FRA must ensure the 

Project includes all possible planning (including consultation with the OWJ over the property) to 

minimize harm to the property, which includes all reasonable measures to minimize harm or 

mitigate impacts (49 U.S.C. 303(c)(2)). OWJ are defined in 23 C.F.R. 774.17. 

After making a Section 4(f) determination and identifying the reasonable measures to minimize 

harm, if there is more than one alternative that results in the use of a Section 4(f) resource, the 

FRA must also compare the alternatives to determine which alternative has the potential to 

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cause the least overall harm in light of the preservationist purpose of the statute. The least 

overall harm may be determined by balancing the following factors: 

• The ability to mitigate adverse impacts on each Section 4(f) resource (including any 

measures that result in benefits to the resource) 

• The relative severity of the remaining harm—after mitigation—to the protected 

activities, attributes, or features that qualify each Section 4(f) resource for protection 

• The relative significance of each Section 4(f) resource 

• The views of the OWJ over each Section 4(f) resource 

• The degree to which each alternative meets the purpose and need for the project 

• After reasonable mitigation, the magnitude of any adverse impacts on resources not 

protected by Section 4(f) 

• Substantial differences in costs among the alternatives 

FR!’s Section 4(f) implementing regulations at 23 C.F.R. 771.13 identify a number of exceptions 

to the requirement for Section 4(f) approval. Of particular relevance for this Project, if a 

publicly-owned trail, path, bikeway, or sidewalk is primarily used for transportation and is an 

integral part of the local transportation system, the requirements of Section 4(f) would not 

apply since it is not a recreational area. Section 4(f) would apply to a publicly owned, shared 

use path or similar facility (or portion thereof) designated or functioning primarily for 

recreation, unless the OWJ determines that it is not significant for such purpose. 

1.1.2. Section 6(f) of the Land and Water Conservation Fund Act (16 U.S.C. 460l-8(f) and 

36 C.F.R. Part 59.1) of 1965 

State and local governments often obtain grants through the LWCF Act to acquire or make 

improvements to parks and recreation areas. Section 6(f) of the act prohibits the conversion of 

property acquired or developed with these grants to a nonrecreational purpose without the 

approval of the NPS. Section 6(f) directs the NPS to ensure that replacement lands of 

comparable value and function, or monetary compensation (used to enhance the remaining 

land), location, and usefulness are provided as conditions to such conversions. 

1.1.3. National Historic Preservation Act (54 U.S.C. 300101 et seq.) including Section 106 

of the National Historic Preservation Act, 54 U.S.C. 306108 

The National Historic Preservation Act (NHPA), as amended, establishes the federal 

government’s policy on historic preservation and the programs, including the NRHP, through 

which this policy is implemented. Under the NHPA, significant cultural resources, referred to as 

historic properties, include any prehistoric or historic district, site, building, structure, object, or 

landscape included in, or determined eligible for inclusion in, the NRHP. Historic properties also 

include resources determined to be National Historic Landmarks. National Historic Landmarks 

are nationally significant historic places designated by the Secretary of the Interior because 

they possess exceptional value or quality in illustrating or interpreting U.S. heritage. A property 

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is considered historically significant if it meets one or more of the NRHP criteria and retains 

sufficient historic integrity to convey its significance. 

Section 106 of the NHPA requires that federal agencies identify and assess the effects that their 

actions may have on historic buildings. While Section 106 of the NHPA and Section 4(f) are 

separate laws with different requirements for compliance, the Section 106 process is generally 

the method by which historic buildings are identified that would be subject for consideration 

under Section 4(f). 

1.2. Definition of Study Area 

For the purposes of this evaluation, two terms describing the study area will be used to be 

consistent with standard conventions. When evaluating potential historic and archaeological 

resources, the term Area of Potential Effects (APE) will be used. The APE is defined as the 

geographical area(s) within which an undertaking may cause changes in the character or use of 

historic and archaeological properties. The term ESL is used to discuss potential park, 

recreation, and wildlife and waterfowl refuge resources. 

1.2.1. Public Park and Recreation Lands, and Wildlife and Waterfowl Refuges 

The Section 4(f) ESL for publicly owned parks, recreational facilities, and wildlife and waterfowl 

refuges includes the footprint for the Project, including rail stations, power stations, road 

construction, temporary laydown areas, or other land used temporarily or permanently 

required to implement the Project. 

As a means to address nonphysical impacts (i.e., noise, visual, and air quality), the Section 4(f) 

ESL also includes resources within 1,000 feet from the center of the proposed track alignment, 

plus any areas adjacent to the Project footprint that extend beyond the 1,000-foot buffer. 

Figure 1-2 through Figure 1-8 illustrate the Section 4(f) ESL for parks and recreation resources, 

which includes parks, recreation facilities, school play areas, trails, and wildlife and waterfowl 

refuges. 

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Figure 1-2. Section 4(f) Parks and Recreation Resource Study Area – Map 1 of 7 

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Figure 1-3. Section 4(f) Parks and Recreation Resource Study Area – Map 2 of 7 

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Figure 1-4. Section 4(f) Parks and Recreation Resource Study Area – Map 3 of 7 

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Figure 1-5. Section 4(f) Parks and Recreation Resource Study Area – Map 4 of 7 

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Figure 1-6. Section 4(f) Parks and Recreation Resource Study Area – Map 5 of 7 

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Figure 1-7. Section 4(f) Parks and Recreation Resource Study Area – Map 6 of 7 

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Figure 1-8. Section 4(f) Parks and Recreation Resource Study Area – Map 7 of 7 

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1.2.2. Historic Properties 

The NHPA implementing regulations in 36 C.F.R. Section 800.4(a)(1) require the establishment 

of an APE. The APE is the geographic area or areas within which an undertaking may alter the 

character or use of historic properties, if such properties exist. Therefore, the APE serves as the 

study area for Section 4(f) historic properties that are potentially eligible for listing or are listed 

on the NRHP. 

The APE takes into consideration the potential effects of the Project on both archaeological and 

historic built resources. The APE is defined in consultation with SHPO and the consulting parties 

through the Section 106 process. The APE includes the footprint of the proposed Project 

alignment, facilities, and ancillary features (the Area of Direct Impact, or ADI) and it extends 

beyond the Project’s footprint to account for noise, vibratory and visual effects (the Area of 

Indirect Impact, or AII). The APE includes the Project footprint and any area outside the 

footprint where visual, atmospheric, or audible intrusions may directly alter the character or 

use of a cultural property, as well as any area where a property/resource may be indirectly 

affected by Project-related effects that are farther removed in distance or would occur later in 

time but are still reasonably foreseeable. Historic properties are buildings, structures, objects, 

sites, landscapes, and districts that are 50 years of age or older at the time the cultural 

resources survey was conducted and have been determined eligible for listing in the National 

Register of Historic Places. 

The APE is defined as follows in Table 1 and is shown in Attachment A: 

Table 1. APE Delineation Values 

Project Component APE Delineation 

APE-ADI (alignment, highway 

improvements only, 

interchange modifications) 

Project Limits of Disturbance (LOD): 

• For the 49 miles of alignment within Caltrans I-15 right-of-way, FRA 

expanded the LOD based on the known construction and operations 

footprint from the 30% design plans plus an additional 100-foot buffer not 

to exceed the I-15 right-of-way. 

• In the Cajon Pass, where the I-15 right-of-way is excessively wide, FRA 

expanded the LOD 100 feet from the edge of existing pavement. 

• For the approximate 1-mile of alignment from the I-15 to the Rancho 

Cucamonga station, the LOD is within an existing public, rail, and utility 

right-of-way. 

Urban Alignment One tax lot adjacent to APE-ADI, 200 feet minimum 

Rural 1,500 feet either side of APE-ADI 

Vertical Height of Project 

Components 

65 feet above current grade 

Areas of Religious or Cultural 

Significance to Tribes 

1,500 feet either side of APE-ADI 

Known sites of Religious or 

Cultural Significance to 

Tribes 

Generally, if a known archaeological site is bisected by or immediately adjacent 

to the final APE, the APE was expanded to include the entire historic property. 

Source: HNTB, 2022 

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1.3. Section 4(f) Applicability 

A park or recreation area qualifies for protection under Section 4(f) if it is: (1) publicly owned at 

the time at which the “use” occurs- (2) open to the public- (3) the land has been officially 

designated as a park or recreation area by a federal, state or local agency; (4) the primary 

purpose is consistent with the property’s primary function and how it is intended to be 

managed; and (5) considered significant by the OWJ over the property. This definition of park 

and recreation areas includes school play areas that are open to the public. 

A wildlife or waterfowl refuge qualifies for protection under Section 4(f) if it is: (1) publicly 

owned at the time at which the “use” occurs- (2) the land has been officially designated as a 

wildlife and/or waterfowl refuge area by a federal, state, or local agency; (3) its primary 

designated purpose is consistent with the property’s primary function and how it is intended to 

be managed; and (4) considered significant by the OWJ over the property. 

A historic site eligible for, or listed in, the NRHP is also protected under Section 4(f). Although 

the statutory requirements of Section 106 and Section 4(f) are similar, if a proposed action 

results in an “adverse effect” under Section 106, there will not automatically be a Section 4(f) 

“use.” To determine whether a use of a historic property would occur, FRA would complete a 

separate Section 4(f) analysis and determination, in addition to those completed in compliance 

with the Section 106 process. 

To qualify as a historic property to be eligible for the NRHP, a resource must meet at least one 

of the four NRHP criteria (i.e., Criteria A–D) described below. 

The quality of significance in American history, architecture, archaeology, engineering, and 

culture is present in districts, sites, buildings, structures, and objects that possess integrity of 

location, design, setting, materials, workmanship, feeling, and association and meet one or 

more of the following criteria: 

• Criterion A — Properties that are associated with events that have made a significant 

contribution to the broad patterns of our history 

• Criterion B — Properties that are associated with the lives of persons significant in our 

past 

• Criterion C — Properties that embody distinctive characteristics of a type, period, or 

method of construction; or that represent the work of a master; or that possess highartistic values; or that represent a significant and distinguishable entity whose 

components may lack individual distinction 

• Criterion D — Properties that have yielded, or may be likely to yield, information 

important in prehistory or history 

An archaeological resource that is eligible solely under NRHP Criterion D, as defined above, is 

considered valuable primarily in terms of the data that can be recovered from it. For such 

resources (such as pottery scatters and refuse deposits), Section 4(f) does not apply. 

Conversely, archaeological resources eligible under Criteria A, B, or C, as defined above, may 

have value intrinsic to the resource’s location and may be protected under Section 4(f). 

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1.4. Section 4(f) Use Definition 

1.4.1. Permanent Use 

A permanent use of a Section 4(f) resource occurs when property is permanently incorporated 

into a proposed transportation facility. This might occur because a result of partial or full 

acquisition, permanent easements, or temporary occupancy that exceed limits for a temporary 

occupancy exception as defined below in subsection 1.4.2. 

1.4.2. Temporary Occupancy 

A temporary occupancy of a Section 4(f) resource occurs when a Section 4(f) property is 

required for construction-related activities. Temporary occupancy would be considered use if 

the property is not permanently incorporated into a transportation facility, but the activity is 

considered adverse in terms of the preservationist purposes of the Section 4(f) statute. 

However, a temporary occupancy of property does not constitute a use of a Section 4(f) 

resource when the following conditions are satisfied: 

• The occupancy must be of temporary duration (i.e., shorter than the period of 

construction) and must not involve a change in ownership of the property. 

• The scope of work must be minor, with only minimal changes to the protected resource. 

• There must be no permanent adverse physical impacts on the protected resource or 

temporary or permanent interference with activities or purpose of the resource. 

• The property being used must be fully restored to a condition that is at least as good as 

existed before Project construction. 

• There must be documented agreement of the appropriate OWJ over the resource 

regarding the foregoing requirements. 

1.4.3. Constructive Use 

A constructive use of a Section 4(f) resource occurs when a transportation project does not 

permanently incorporate the property of a protected resource, but the proximity of the project 

results in impacts (e.g., noise, vibration, visual, access, or ecological) after incorporation of 

mitigation that are so severe that the protected activities, features, or attributes that qualify 

the resource for protection under Section 4(f) are substantially impaired. Substantial 

impairment occurs only if the protected activities, features, or attributes of the resource are 

substantially diminished. This determination is made after taking the following steps: 

• Identifying the current activities, features, or attributes of the resource that may be 

sensitive to proximity impacts 

• Analyzing the proximity impacts on the resource 

• Consulting with the appropriate OWJ over the resource 

It is important to note that erecting a structure over a Section 4(f) resource, and thus requiring 

an air lease, does not by itself constitute a use, unless the effect constitutes a constructive use. 

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Further, a noise or visual-related adverse effect under Section 106 of the NHPA to a historic 

property does not in and of itself result in a constructive use. 

1.4.4. De Minimis Impact 

According to 49 U.S.C. 303(d), the following criteria must be met to reach a de minimis impact 

determination: 

• For parks, recreation areas, and wildlife and waterfowl refuges, a de minimis impact 

determination may be made if FRA concludes that the transportation project would not 

adversely affect the activities, features, and attributes qualifying the resource for 

protection under Section 4(f) after mitigation. In addition, to make a de minimis impact 

determination there must be: 

• The OWJ over the property must be informed regarding the intent to make a de minimis impact 

determination, after which, public notice and opportunity for public review and comment must 

be provided. 

• After consideration of comments, if the OWJ over the property concur in writing that the project 

would not adversely affect the activities, features or attributes that make the property eligible 

for Section 4(f) protection, then FRA may finalize the finding of de minimis impact. 

• For a historic site, a de minimis impact determination may be made by FRA if, in 

accordance with the Section 106 process of the NHPA, FRA determines that the 

transportation program or project would have no effect or no adverse effect on historic 

properties, the FRA has received written concurrence from the OWJ over the property 

(e.g., SHPO), and the FRA has taken into account the views of consulting parties to the 

Section 106 process as required by 36 C.F.R. Part 800. 

1.5. Consultation 

Title 49 U.S.C. Section 303(b) requires cooperation and consultation with the Secretary of the 

Interior (and the Secretaries of Housing and Urban Development and Agriculture, if 

appropriate) and with the state in developing transportation plans and programs that include 

measures to maintain or enhance the natural beauty of lands crossed by transportation 

activities or facilities. Section 4(f) also requires consultation with the SHPO and agencies of 

jurisdiction in identifying Section 4(f) properties and assessing impacts on the properties. 

FRA consulted with the SHPO, the Surface Transportation Board, the U.S. Army Corps of 

Engineers, the U.S. Department of the Interior, Bureau of Reclamation, local agencies, 

interested parties, the Native American Heritage Commission, and interested tribes to identify 

and assess impacts on cultural resources in compliance with Section 106. These preliminary 

Section 106 findings are summarized in Section 4.2 and are considered in this report in 

accordance with the requirements of Section 4(f). 

Formal consultation with the USDA Forest Service, U.S. Department of the Interior, Bureau of 

Land Management, City of Fontana, San Bernardino Associated Governments or City of Rancho 

Cucamonga has not yet occurred. FRA will consult with these OWJs prior to release of the Final 

EA. 

22 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

FRA’s preliminary Section 4(f) determinations are presented in this report and the public is 

invited to comment on those preliminary determinations. Final Section 4(f) determinations will 

be made and published as part of the Final EA. 

2. Project Description 

2.1. Background 

Early Project coordination for HSR service from Victor Valley to Rancho Cucamonga began in 

2020, with Brightline West meeting with the San Bernardino County Transportation Authority 

(SBCTA) to examine a connection between Victor Valley and Rancho Cucamonga. This meeting 

resulted in a memorandum of understanding (MOU) that was fully executed in July 2020 

between Brightline West and SBCTA to study the potential of building HSR within the I-15 rightof-way between Victor Valley and Rancho Cucamonga. A separate MOU was executed in 

September 2020 between Brightline West and the Southern California Regional Rail Authority, 

which operates Metrolink, for connection to the existing Metrolink station in Rancho 

Cucamonga. Additionally, the California State Transportation Agency (CalSTA), Caltrans, the 

California High-Speed Rail Authority, and Brightline West have executed an MOU regarding the 

Project. The MOU reflects both the regional and statewide interest and value in the Project, 

including interconnectivity opportunities, and outlines how the parties will work together to 

advance their shared interest in the success of the Project. 

2.2. Project Area 

The proposed rail alignment is located within the median of the I-15 freeway between Victor 

Valley and Rancho Cucamonga, except for the last mile approaching the proposed Rancho 

Cucamonga station. The last mile of the Project, from I-15 to the Rancho Cucamonga station, 

will be constructed following agreements with the City of Rancho Cucamonga and the SBCTA 

for land rights, construction, operations, and maintenance. The Project area is depicted above 

in Figure 1-1. 

2.3. Purpose of and Need for the Project 

2.3.1. Purpose 

The purpose of the Project is to provide reliable and safe passenger rail transportation between 

the Los Angeles metropolitan region and the High Desert of San Bernardino County. The Project 

will provide a convenient, efficient, and environmentally sustainable alternative to automobile 

travel on the highly congested I-15 freeway. The Project will add capacity to the overall 

transportation system by introducing a new HSR service from Victor Valley to Rancho 

Cucamonga. The Project will reduce travel time, improve reliability, and increase the mobility 

options for travel between metropolitan regions. Travel time from Victor Valley to Rancho 

Cucamonga for HSR passengers will be approximately 30 percent faster than an automobile 

during normal conditions and at least twice as fast during periods of peak congestion. The 

DRAFT SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 23 
 

BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Project will reduce vehicle miles traveled (VMT), resulting in a corresponding reduction in 

greenhouse gas (GHG) emissions and criteria pollutant emissions. 

2.3.1.1. Multi-Modal Use of the I-15 Corridor 

Operation of the Project would significantly increase the capacity of I-15 as a multi-modal 

corridor in Southern California. This increase in capacity would benefit freeway operations by 

providing an alternative to automobile travel that would reduce travel time. This shift of people 

from automobile to train travel along the I-15 corridor would reduce the need for programmed 

and/or planned freeway improvement and widening projects 

2.3.1. Need 

The Project is needed to address transportation capacity, congestion, limited travel mode 

choices, safety, and reduce GHG emissions. 

Travel demand analysis completed on behalf of the Project forecasts 49.1 million one-way trips 

between Southern California and Las Vegas in 2025, with approximately 85 percent of travelers 

making the trip by automobile. Most of these trips use the capacity constrained Cajon Pass 

segment of I-15. Further, the freeway system leading into I-15 from points west, east, and 

south, including Interstate (I-) 10, State Route (SR-) 210, I-215 and SR-60 have similar delays and 

capacity constraints. The Project would address this demand, by providing a transportation 

alternative to vehicle travel, and it would allow access to the Brightline West service from the 

Greater Los Angeles and the Riverside-San Bernardino-Ontario Metropolitan areas, as well as 

points beyond, with a connection to the Metrolink system in Rancho Cucamonga. 

The Project will also support federal and state policies focused on addressing climate change by 

reducing VMT and associated GHG emissions. 

2.3.1.1. Capacity Constraints 

I 15 through the Cajon Pass is one of the most congested segments of I 15, with no alternative 

routes that provide comparable direct road travel capability because of the mountainous 

topography. Through the Cajon Pass, I-15 supports daily workforce commuters, recreational 

travel, and regional and interstate freight and goods movement. According to the traffic study 

prepared for the I-15 Corridor Project Initial Study/Environmental Assessment (Caltrans and 

SBCTA, 2018), unreliability in travel time along segments of I-15 and surrounding roadways is 

due to roadway capacity constraints, frequent accidents, and various factors that cause 

unanticipated congestion. Travelers using the Project will no longer need to drive through the 

most congested parts of the corridor on Cajon Pass for interstate or commuter trips, thereby 

avoiding idling and inefficient stop-and-go traffic conditions. 

By 2045, travel speeds are expected to decrease on all but one segment of I-15 between the 

San Bernardino Valley and the Apple Valley in the AM (morning) peak period, and travel speeds 

on most segments will also decrease—some by more than 10 mph—in the PM (afternoon) peak 

period (SCAG 2020). Based on the Project Report for the I-15 Corridor Study (addition of 

express lanes), traffic volumes on I-15 between I-10 and SR-210 are expected to increase 

between 31 to 38 percent from 2014 to 2045. The Project Report states the existing level of 

24 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

service (LOS) is acceptable in most locations, but that there are bottlenecks in each direction of 

travel that degrade traffic operation, especially between Baseline Road and SR-210. Since the 

express lane project is increasing capacity by adding express lanes, the traffic volumes are 

projected to increase by an additional 27 percent. The Project Report further mentions that 

although the express lane project will improve conditions in the general-purpose lanes in many 

segments, it will cause the segment between I-10 and Fourth Street to worsen in the PM peak 

hour (both directions).1 

1 The term “general purpose lane” refers to highway lanes that do not have a restricted use such as express lanes or carpool lanes. 

In the AM peak hour, the segment between Arrow Route and Fourth 

Street will worsen in the southbound direction. The segment between Baseline Road and SR 

210 will continue to operate at over capacity conditions in all scenarios. 

S!G’s Connect SoCal Goods Movement Technical Report identifies I-15 as part of the U.S. 

Department of Transportation’s (USDOT) Primary Highway Freight Network and among the 

network segments that carry the highest volumes of truck traffic in the region. It also identifies 

the entirety of Cajon Pass as a truck bottleneck, with over 15,000 annual vehicle hours of delay. 

As documented above, given the attractiveness of the origins and destinations, the 

transportation capacity constraints on I-15 as described in current and predicted average daily 

traffic (ADT) and LOS limit reasonable highway access between Rancho Cucamonga, Hesperia, 

and Victor Valley. 

I-10 is the primary commuter corridor from San Bernardino County and the San Gabriel Valley 

to Los Angeles. Based on the Final Environmental Impact Report (FEIR) by Caltrans in 2012 for I 

10 high-occupancy vehicle (HOV) lanes from Puente Avenue to SR-57/SR-71, the westbound 

direction of I-10 experiences recurrent congestion in the AM peak hour and eastbound 

direction experiences recurrent congestion in the PM peak hour. Additionally, most of I-10 

operates at capacity in both the AM and PM peak hour with spillbacks at the SR-57/SR-71 

interchange and I-605 interchange. In addition, due to short spacing between interchanges, 

there is insufficient weaving distance leading to much lower speeds in the right lanes of the 

freeway. The Final EIR also indicated that even with the HOV lanes, the forecast volumes (year 

2035) are generally going to result in continued recurrent congestion (Caltrans 2012). 

Due to heavy congestion, both SBCTA and LA Los Angeles Metro are currently converting HOV 

lanes on the I-10, on which operations are degraded according to Federal standards to HighOccupancy Toll/Express Lanes (priced lanes). In addition, LA Los Angeles Metro and Metrolink 

are also coordinating to extend service on the Gold Line to Azusa and eventually to Montclair in 

San Bernardino County. The Brightline service would provide an option that addresses longer 

distance trips that would otherwise burden the peak travel periods on I-10 and other roadways. 

2.3.1.2. Travel Demand 

The anticipated substantial increases in population, housing, and employment in San 

Bernardino County will result in greater demand for transportation facilities and services, 

including increased travel demand that will result in congestion on roadways if capacity does 

not keep up with the demand. The proposed Hesperia Station would provide a convenient 

connection between High Desert communities and the more urbanized San Bernardino Valley 

DRAFT SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 25 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

and Metropolitan Los Angeles. The High Desert provides lower cost housing options for 

Southern California residents, while the Rancho Cucamonga/Ontario area around Ontario 

International Airport has become a significant employment center. 

SCAG forecasts, in its 2020-2045 Regional Transportation Plan/Sustainable Communities 

Strategy (RTP/SCS), that the population of San Bernardino County will grow to 2,815,000 by 

2045, a 29 percent increase from the US ensus ureau’s 2018 population estimate of 

2,180,085, and that the number of households will grow to 875,000, a 39 percent increase over 

the 2018 household estimate of 630,633 (US Census Bureau 2020). Additionally, the 2020-2045 

RTP/SCS forecasts employment in San Bernardino County will increase to 1,064,000 by 2045, a 

72 percent increase from the US ensus ureau’s estimate of 617,828 in 2018.

While the proposed Victor Valley station site will be located at the convergence of all the 

highways en route to Las Vegas for Southern California travelers, the Rancho Cucamonga 

station will be closer to major population centers in Southern California. Compared to the 

Victor Valley station, the proposed HSR station in Rancho Cucamonga, located about 45 miles 

east of Downtown Los Angeles, will provide both drivers and Metrolink riders more direct 

access to Southern alifornia’s densely populated centers- 87 percent of the total 49.1 million 

potential market for trips between Las Vegas and Southern California (equivalent to 

42.7 million of the one-way, in-scope trips in 2025) live within 75 miles of the location of the 

proposed Rancho Cucamonga station. 

The proposed station in Rancho Cucamonga, with a Metrolink connection to Los Angeles, will 

further meet the forecasted demand of the 49.1 million one-way trips between Las Vegas and 

Southern California estimated in 2025. Similarly, the proposed Hesperia station will serve 

commuters to Greater Los Angeles from the major corridors in Victor Valley because of its 

location at the convergence of US Highway 395 (US-395) and I-15, so it would serve commuters 

to Greater Los Angeles from the major corridors in the Victor Valley. 

The Project will also support S!G’s onnect Soal Passenger Rail Technical Report, which 

identifies closing connectivity gaps as a major strategy to increase mobility and improve 

sustainability. The Project will facilitate transit connections and will allow residents of the 

Greater Los Angeles and Riverside-San Bernardino-Ontario Metropolitan areas to travel 

exclusively by mass transit and passenger rail to and from the High Desert of San Bernardino 

and connect to the Brightline West station at Victor Valley for a connection to Las Vegas. From 

the Rancho Cucamonga station, Southern California residents can take the Metrolink San 

Bernardino line to Los Angeles Union Station and connect to the Los Angeles Metro rail, 

regional bus systems, Amtrak, or Metrolink to Los Angeles Union Station to connect via the 

Metrolink San Bernardino Line. Residents could also take the planned West Valley Connector 

Bus Rapid Transit service that will operate between the Pomona station on the Metrolink 

Riverside Line in eastern Los Angeles County and the Rancho Cucamonga station. While still in 

early planning and design stages, the planned Tunnel to Ontario International Airport project 

may provide an additional connection from the Rancho Cucamonga station to the Ontario 

International Airport. 

Additionally, SBT! and S!G’s 2015 !dvanced Regional Rail Integrated Vision – East (ARRIVE 

Corridor) plan proposes strategies for transitioning the Metrolink San Bernardino Line, which 

26 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
 

BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

will serve the Rancho Cucamonga station, from a traditional commuter rail line to one that 

promotes transit-oriented development. Improvements to Metrolink, its transit connections, 

and additional development of the station areas with transit-supportive uses at greater 

densities and intensities will encourage the development of walkable areas that provide 

mobility options in the region. The Project will further the goals of the ARRIVE Corridor plan by 

increasing the activity centers that can be accessed by Southern alifornia’s rail network.

Additionally, the Southern California Optimized Rail Expansion program is intended to increase 

speeds, reliability, and capacity on Metrolink lines including the San Gabriel Subdivision serving 

the Rancho Cucamonga station. 

In 2010, the San Bernardino Associated Governments (the predecessor agency to SBCTA) 

completed the Victor Valley Long Distance Commuter Needs Assessment, which identified a 

phased set of commuter improvement projects. Those projects ranged from expanded park and 

ride facilities to an express bus service linking the Victor Valley area of the High Desert to the 

Rancho Cucamonga Metrolink station. The Joshua Street Park & Ride is approximately 0.25 mile 

west of the proposed Hesperia station adjacent to US-395. Such commuter-focused planned 

improvements highlight the need for travel options that reduce the number of single occupancy 

automobiles on I-15 in San Bernardino County, particularly through the Cajon Pass. 

FHW!’s Southern alifornia Regional Freight Study (USDOT, 2020) identifies I-15 among the 

highest truck volume corridors in the Western United States and as a major corridor providing 

access to the interior of the United States for goods arriving at the ports of the Los Angeles 

region. altrans’ 2015 Interregional Transportation Strategic Plan identifies I-15 as a high 

priority corridor, among six nationally identified “orridors of the Future,” and a “a vital link 

between Mexico, Southern alifornia, and locations to the north and east of the region.” I-15 

also connects Southern California and the southwestern United States to the San Joaquin 

Valley’s agricultural goods via SR-58. By providing passenger rail capacity in the corridor, the 

Project will help protect freeway capacity for freight by removing passenger vehicles from the 

roadway network. 

2.3.1.3. Ridership 

Forecasted ridership for the Project is based on the 2020 Brightline West Cajon Pass Project -

Ridership and Revenue Forecasts Report prepared by Steer (referred to hereafter as the Steer 

Report), 2

2 This analysis was prepared for Brightline West in December 2019 and June 2020 by Steer. The reports contain ridership information to 

support the environmental analysis and also contain confidential Brightline West business information. FRA has reviewed the ridership 

methodology in the reports and confirmed it is based on reliable methods; and has accepted the analysis. For more information on ridership, 

refer to the Transportation Technical Report, included as Attachment K to this EA. 

the findings of which are summarized in the Brightline West Cajon Pass Project 

Operating Memo (2022; included as Attachment A). Operating conditions analyzed in this EA 

assume that the Project and the separate, but interconnected DesertXpress High-Speed 

Passenger Train Project (DesertXpress Project) will operate simultaneously. Therefore, this 

section discusses ridership forecasts for passengers travelling from Las Vegas to Rancho 

Cucamonga and to stations in between. Ridership forecasts are summarized in Table 2 and 

Table 3. 

DRAFT SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 27 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Table 2. Ridership Forecast: Victor Valley to Rancho Cucamonga: Years 1 – 10 (millions) 

Years 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 

Las Vegas -Southern California Total 

Travel Demand (one-way) 49.1 49.8 50.0 51.3 52.0 52.8 53.5 54.2 54.9 55.6 

Forecasted Induced Ridership1 

1

: Forecasted Induced Ridership is ridership that has been realized, or "generated", by improvements made to transportation infrastructure. 

(oneway) .69 1.1 1.3 1.2 1.2 1.3 1.2 1.3 1.4 1.3 

Forecasted Captured Ridership 6.9 9.2 9.7 9.8 9.9 10.1 10.1 10.3 10.5 10.5 

Capacity 8.9 8.9 8.9 11.2 11.2 11.2 13.4 13.4 13.4 13.4 

Annual LV-RC Ridership (excl. Victor 

Valley station) 4.1 4.9 4.9 6.0 6.0 6.1 6.8 6.9 6.9 7.0 

Annual Las Vegas-Victor ValleyRancho Cucamonga Ridership 5.6 6.4 6.5 7.5 7.6 7.6 8.3 8.4 8.5 8.5 

Annual Hesperia-Rancho Cucamonga 

Ridership .38 .43 .45 .51 .52 .53 .58 .59 .6 .61 

Total Annual Ridership 6.0 6.8 6.9 8.0 8.1 8.1 8.9 9.0 9.1 9.2 

Source: Brightline West 2022 

28 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Table 3. Ridership Forecast: Victor Valley to Rancho Cucamonga: Years 11 – 20 (millions) 

Years 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 

Las Vegas -Southern California Total 

Travel Demand (one-way) 56.4 57.1 57.9 58.7 59.4 60.2 60.9 61.6 62.4 63.1 

Forecasted Induced Ridership1 

1

: Forecasted Induced Ridership is ridership that has been realized, or "generated", by improvements made to transportation infrastructure. 

(oneway) 1.4 1.4 1.4 1.4 1.5 1.4 1.5 1.5 1.5 1.5 

Forecasted Captured Ridership 11.4 11.6 11.6 11.8 11.9 12.1 12.2 12.4 12.5 12.7 

Capacity 26.9 26.9 26.9 26.9 26.9 26.9 26.9 26.9 26.9 26.9 

Annual LV-RC Ridership (excl. Victor 

Valley station) 7.7 7.8 7.8 8.0 8.1 8.2 8.3 8.4 8.5 8.6 

Annual Las Vegas-Victor ValleyRancho Cucamonga Ridership 10.6 10.7 10.8 10.9 11.0 11.0 11.2 11.3 11.4 11.5 

Annual Hesperia-Rancho Cucamonga 

Ridership .69 .72 .74 .76 .77 .77 .78 .78 .79 .79 

Total Annual Ridership 11.3 11.4 11.5 11.7 11.8 11.8 12.0 12.1 12.2 12.3 

Source: Brightline West 2022 

DRAFT SECTION 4(F) AND 6(F) EVALUATIONS, SEPTEMBER 2022 29 
 

BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

As shown in Table 2 and Table 3, the Project is expected to capture approximately 14 percent of 

the Las Vegas – Southern California travel demand beginning in 2025 (i.e., the opening year). 

This capture rate will increase to 20 percent by Year 11. Induced ridership is expected to 

steadily increase from 693,937 in Year 1 to 1.4 million by 2035. By 2044, the Project is expected 

to have 12.3 million one-way trips annually. The subset of travelers who will only travel 

between Rancho Cucamonga and Hesperia will represent approximately 6 percent of the total 

annual ridership. Ridership between Victor Valley and Rancho Cucamonga is expected to be 

negligible; the majority of riders are expected to continue from Rancho Cucamonga and 

Hesperia to Las Vegas. 

2.3.1.4. Safety 

Alternatives to automobile travel would provide improved safety conditions on the I-15 corridor 

with diversion of vehicle trips to HSR. In 2019, the average rate of passenger fatalities from 

highway travel was more than 75 times the comparable rate for travel by air, and 34 times the 

comparable rate by rail. For the year 2016, the ureau of Transportation Statistics’ National 

Transportation Statistics (USDOT 2018) reported a rate of passenger fatalities per 100 million 

passenger miles traveled by highway nearly 10 times greater than the rates for travel by air or 

rail. HSR in a dedicated, grade-separated corridor such as is planned by Brightline West, is one 

of the safest forms of travel in the world. For example, the Japanese Shinkansen HSR system 

has been in existence for 50 years, has carried over 10 billion passengers, and has not 

experienced a single passenger fatality of injury on board die to derailments or collisions (JR 

Central, 2020).. 

The California Office of Traffic Safety ranks San Bernardino County as the 16th worst, out of 58 

counties, for total fatal and injury crashes in 2018 (the most recent year of data available). 

!ccording to the University of alifornia, erkeley, and SafeTRE’s Transportation Injury

Mapping System, there were 819 collisions with one or more deaths or injuries along the I-15 in 

San Bernardino County in 2019. Of these, nearly one quarter (199) occurred within the 12 miles 

of the Cajon Pass, despite the Pass accounting for only 6.5 percent of the length of the I-15 in 

the county. 

A study by the I-15 Mobility Alliance found that the segment of the I-15 from the I-215 in San 

Bernardino to the I-40 in Barstow had a fatality rate 0.009 per million VMT, well above the 

alliance’s performance goal of 0.003 fatalities per million (CH2M 2017). By connecting Victor 

Valley to Rancho Cucamonga, the Project will allow more travelers to stay off the most 

dangerous segments of the I-15. 

2.4. Alternatives 

2.4.1. No Build Alternative 

The No Build Alternative will involve no action to create a passenger HSR system in the median 

and immediately alongside the I-15 freeway between Victor Valley and Rancho Cucamonga. The 

I-15 corridor will remain operational without improving the major points of congestion or 

transportation capacity deficiencies along the highway. Other planned improvements on the I30 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

15 include altrans’ I-15 Interchange Reconstruction Project, which consists of improvements 

to the D Street, E Street, Stoddard Wells Road, and Mojave River Bridge interchanges with I-15 

to improve traffic safety, operational characteristics, and aesthetics, and the I-15 Pavement 

Rehabilitation Project, which is intended to improve the safety performance and smoothness of 

the roadway. Neither of these projects would increase capacity on I-15. The No Build 

Alternative will not result in temporary or permanent impacts to resources in the affected 

environment as no project related activities or construction will occur. As discussed below in 

Section 4.1.1.2 and Section 4.1.2.1, travelers between Victor Valley and Rancho Cucamonga will 

continue to use passenger cars for travel. Due to anticipated population increases, travel 

demand along the I-15 will increase, along with VMT and associated criteria air pollutants, 

TACs, and GHG emissions from passenger vehicles. 

2.4.2. Build Alternative 

The Build Alternative (i.e., the Project) consists of a proposed HSR passenger railway with 

associated infrastructure, including two new proposed passenger stations. Nearly all of the 

Project will be built within the I-15 right-of-way. Near the proposed southern terminus station 

in Rancho Cucamonga, approximately one mile of the rail alignment will be in city street, 

railroad, or utility rights-of-way. 

The proposed rail alignment will be located within the median of the I-15 freeway between 

Victor Valley and Rancho Cucamonga except at the approach to the proposed Rancho 

Cucamonga station. The rail alignment will be predominantly at-grade (the same elevation as 

the existing freeway), with select segments of the alignment on aerial structures or in a trench 

to allow for grade separations (including four BNSF Railway3 

3 The BNSF Railway Company adopted its official name based on the initials of its original name, Burlington Northern and Santa Fe Railway, in 

January 2005. 

railroad crossings and three Union 

Pacific railroad crossings) and to provide a safe incline for train operation. The rail alignment 

will be predominantly single-track, with limited double-track segments in Victor Valley (2.6 

miles, including 0.9 miles constructed as part of the approved DesertXpress Project), Hesperia 

(5.5 miles), and Rancho Cucamonga (2 miles). This will allow for 45-minute headways in the 

opening year between Victor Valley and Rancho Cucamonga. These headways along with the 

ability to couple trains (double passenger capacity), will address projected ridership needs for 

the foreseeable future. 

For analytical purposes, the Build Alternative is described in sections. Sections were developed 

to reflect similarly developed areas with similar environmental sensitivity. The sections include: 

▪ Section 1: High Desert - From the Victor Valley station, continuing south along the I-15, to 

the I-15/Oak Hill Road interchange in Hesperia 

▪ Section 2: Cajon Pass - From the Oak Hill Road interchange continuing south along the I-15, 

through the Cajon Pass, to the I-15/Kenwood Avenue interchange 

▪ Section 3: Greater Los Angeles - From the I-15/Kenwood Avenue interchange in San 

Bernardino continuing south along the I-15, through the existing Metrolink Station in 

Rancho Cucamonga to Haven Avenue 

SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 31 
 

BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

2.4.2.1. Section 1 – High Desert 

The proposed rail alignment will connect to the DesertXpress Project alignment approximately 

one mile south of the Victor Valley station in Apple Valley. From this point, the alignment will 

continue south within the I-15 median. The rail alignment throughout Section 1 will be 

predominantly single track, but the rail alignment will be double-track north of Stoddard Wells 

Road to the northern terminus of the alignment as it approaches the train platforms of the 

Victor Valley station. The Project will add a new structure within the median of the existing I-15 

bridge near the CEMEX facility in Victorville. 

Brightline West will build new Southbound on and off ramps and a bridge at South Stoddard 

Wells Road to replace similar existing facilities further south.4 

4 These improvements will be consistent with altrans’ planned I-15 Interchange Reconstruction (D Street, E Street, Stoddard Wells Road, and 

Mojave River Bridge) project, which was originally analyzed under an Initial Study / Environmental Assessment in 2008. 

This will require modifications of 

the I-15 up to and including the Mojave River crossing. 

At the Mojave River, a new rail bridge will be constructed within the median of I-15. The 

existing I-15 bridge will be widened to accommodate the rail line. The alignment will continue 

at grade in the I-15 median with minor roadway widenings for the remainder of Segment 1. This 

portion of the alignment will interface with the following interchanges: Stoddard Wells Road 

North, Stoddard Wells Road South, D Street/E Street, Mojave Drive, Roy Rogers Drive/Hook 

Road, Palmdale Road, La Mesa Road/Nisqualli Road, Bear Valley Road, Main Street/Phelan 

Road, Joshua Street, US-395, Ranchero Road, and Oak Hill Road. 

A new traction power substation will be constructed to support the Project along the I-15, 

between Mesa Street and Mojave Street. The area is mostly undeveloped other than existing 

overhead power lines and utility access. 

Hesperia Station 

Section 1 includes a new passenger station in Hesperia, at the I-15/Joshua Street interchange. 

This station will serve daily travelers between the High Desert of San Bernardino County and 

the Los Angeles Basin. This will be a limited service for select southbound AM and northbound 

PM weekday train coaches. The northbound on-ramp to Joshua Street will be realigned closer 

to the freeway and station parking will be added on the north side of Joshua Street. Parking will 

be accessed at the location of the existing northbound ramp intersection. To accommodate the 

rail alignment, the existing US-395 northbound connector and the existing Joshua Street bridge 

will be replaced within the existing right-of-way. The Joshua Street bridge will be reconstructed 

at a higher elevation, requiring the raising of the I-15 ramps and Mariposa Road. The passenger 

platform will be located within the I-15 median with direct access from the reconstructed 

Joshua Street bridge at the southern end of the double-track segment in Hesperia. The Project 

design includes adequate parking areas to accommodate parking demand. 

32 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
 

BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Design Elements 

Segment 1 of the Project includes the following design elements. 

• Reconstructions/Interchange Modifications: Widening portions of the I-15 freeway and 

modifications to interchanges at Stoddard Wells Road southbound on- and off-ramp, D 

Street/E Street, Mojave Drive, Roy Rogers Drive/Hook Road, Palmdale Road, La Mesa 

Road/Nisqualli Road, Bear Valley Road, Main Street/Phelan Road, Joshua Street, US-395, 

Ranchero Road, and Oak Hill Road. 

• New Traction Power Substation: Construction of a new traction power substation along 

the I-15 between Mesa Street and Mojave Street. 

• Station area: Hesperia station platform, pedestrian bridge, station access/infrastructure, 

surface parking lot accommodating approximately 360 vehicles, bus pick up/drop off 

areas, Kiss and Ride. 

2.4.2.2. Section 2 – Cajon Pass 

Beginning at the Oak Hill Road interchange traveling south, the alignment will run on the west 

side of the I-15 northbound lanes at-grade and within the existing I-15 right-of-way. In this area, 

the I-15 runs through the San Bernardino National Forest for approximately 12 miles. The rail 

alignment throughout Section 2 will be entirely single track. The Project will require 

replacement of California Highway Patrol (CHP) emergency crossovers where the new guideway 

will block existing crossovers. Four new crossovers will be placed to take advantage of existing 

CHP access between the separated I-15 alignments in the following locations: 

• West of Forestry Road crossing the northbound lanes. 

• Approximately 1.25 miles in the southbound direction along the I-15 from the crossover 

near Forestry Road, across the northbound lanes. 

• West of the Baldy Mesa (Trestles) off-highway vehicles Staging Area, across the 

northbound lanes. 

• West of Perdew Canyon and approximately 1.25 miles north of Mathews Ranch Road, 

across both the north and southbound lanes. 

The alignment will remain at grade throughout Segment 2. Where the I-15 northbound and 

southbound lanes reconnect at the foot of Cajon Pass, the rail alignment will be within the I-15 

median. This will require widening portions of the I-15 freeway and minor realignment of ramps 

at the I-15/SR-138 interchange. 

Design Elements 

Segment 2 of the Project includes the following design elements: 

• Reconstructions/Interchange Modifications: Widening portions of the I-15 freeway 

including several miles of retained fill, and realignment of ramps at the I-15/SR-138 

interchange. 

• Other facilities: CHP emergency crossovers 

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2.4.2.3. Section 3 – Greater Los Angeles 

Beginning at the Kenwood Avenue interchange, the proposed rail alignment will continue atgrade in the I-15 median. At the I-15/I-215 interchange, the alignment will continue between 

the divided I-15 freeway at the same elevation as the freeway including the Devore interchange 

viaduct, curving to the southwest parallel to freeway. The rail alignment will require the I-15 

freeway and interchange ramp modifications at Baseline Avenue, SR-210, Beech Avenue, 

Duncan Canyon Road, Sierra Avenue, and Glen Helen Parkway. 

The rail alignment will transition to an aerial alignment over the I-15 southbound lanes south of 

Church Street and cross at Foothill Boulevard. It will continue along the west side of the I-15 

freeway on an elevated alignment to enter the San Gabriel Subdivision and Eighth Street 

corridor. The alignment will transition onto an aerial structure and will turn west, running 

parallel to and partially within the existing rail corridor and partially within the Eighth Street 

right-of-way before entering the existing Rancho Cucamonga Metrolink station area on an 

elevated structure. The rail alignment will maintain a single-track configuration prior to exiting 

the freeway median south of Church Street, where the alignment will transition to a double 

track configuration for the remaining distance to the Rancho Cucamonga station. At the Rancho 

Cucamonga station, an elevated station with a center platform and tracks on either side will be 

constructed parallel to and above the existing eastbound Metrolink platform, extending over 

Milliken Avenue. A new parking structure is proposed at Rancho Cucamonga station and will 

replace existing surface parking to accommodate increased parking demand. The Project design 

includes adequate parking areas to accommodate parking demand in the opening year. 

Design Elements 

Segment 3 of the Project includes the following design elements. 

• Bridges/Viaducts: Viaduct of approximately 3.5 miles to cross the I-15 southbound lanes 

and along existing rail corridor near Rancho Cucamonga station. 

• Reconstructions/Interchange Modifications: The I-15 freeway and interchange ramp 

modifications at SR-210, Beech Avenue, Duncan Canyon Road, and Glen Helen Parkway. 

• Station: Dedicated Brightline station adjacent to the existing Rancho Cucamonga 

Metrolink station with vertical circulation down to the platform, shared access with 

existing Metrolink station, a shared parking structure for vehicles, and a bus plaza. 

3. Section 4(f) Applicability Analysis 

This section identifies the park, recreation, open space, and wildlife and waterfowl refuge 

properties that meet the minimum criteria for protection as Section 4(f) resources. These 

resources are shown on 

Figure 3-1 through Figure 3-8. This section further identifies built historic and archaeological 

resources that qualify for protection under Section 4(f). 

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3.1. Parks, Recreation Areas, and Wildlife and Waterfowl Refuges 

Data collection to identify potential Section 4(f) resources consisted of a review of the 

recreational resources, plans, and policies, consultation with officials with jurisdiction over 

resources and the use of geographic information system data banks. 

All parks, recreation, and wildlife refuges that may qualify for Section 4(f) protection (as defined 

in Section 1.3) are shown on 

Figure 3-1 through Figure 3-8 and corresponding map identification numbers. Table 4 

summarizes Section 4(f) resources that would not incur Section 4(f) use, based on their distance 

from the proposed alignment, intervening development or topography, and their current 

setting. Therefore, the resources summarized in Table 4 are not discussed further in this 

section. Those resources that are in close enough proximity to the Project to potentially incur a 

use or proximity impact are listed in Table 5 and described in detail below. Section 4(f) 

resources are presented in north to south order. 

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Figure 3-1. Section 4(f) Parks and Recreation Resources–- Overview 

36 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
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Figure 3-2. Section 4(f) Parks and Recreation Resources – Map 1 of 7 

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Figure 3-3. Section 4(f) Parks and Recreation Resources – Map 2 of 7 

38 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
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Figure 3-4. Section 4(f) Parks and Recreation Resources – Map 3 of 7 

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Figure 3-5. Section 4(f) Parks and Recreation Resources – Map 4 of 7 

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Figure 3-6. Section 4(f) Parks and Recreation Resources – Map 5 of 7 

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Figure 3-7. Section 4(f) Parks and Recreation Resources – Map 6 of 7 

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Figure 3-8. Section 4(f) Parks and Recreation Resources – Map 7 of 7 

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Table 4. Park, Recreation Area, and Wildlife and Waterfowl Refuge Resources: No Use 

Property 

Name and 

Map ID 

Official with 

Jurisdiction Description 

Approximate Distance 

from Alignment 

Centerline/ 

Station 

Section 4(f) Use Analysis 

Avalon Park 

(1) 

City of 

Victorville 

Location: 16338 Avalon Ave, 

Victorville, CA 92395 

Size: 4.5 acres 

Features: Basketball court, picnic 

area, playground, 

rollerblading/roller skating area 

800 feet This resource is a publicly owned recreational amenity. 

However, the park is sufficiently distant from the Project 

such that no use would occur. There are existing intervening 

residential uses and roads between the park and the Project. 

No part of Avalon Park would be included in the temporary 

impact area for the Project. No temporary construction 

easements would be required from this facility. No 

permanent acquisition of property from Avalon Park would 

occur. Access to the resource would be uninterrupted. The 

existing features and attributes of the park would remain 

intact and would not be disrupted by operation of the 

Project. 

Glen Helen 

Regional 

Park (7) 

County of 

San 

Bernardino 

Location: adjacent to the Cajon 

Pass 

Size: 627 acres 

Features: Amphitheater, 

swimming complex, fishing, 

walking/hiking 

560 feet This resource is a publicly owned recreational amenity. 

There are sloping hills separating the park from the Project. 

Due to the elevation differences and topographical barriers 

between the park and the Project, no use would occur. 

No part of Glen Helen Regional Park would be included in 

the temporary impact area for the Project. No temporary 

construction easements would be required from this facility. 

No permanent acquisition of property from Glen Helen 

Regional Park would occur. Access to the resource would be 

uninterrupted. The existing features and attributes of the 

park would remain intact and would not be disrupted by 

operation of the Project. 

Perdew 

Elementary 

School (10) 

Etiwanda 

School 

District 

Location: 13051 Miller Ave 

Etiwanda, CA 91739 

Size: 10 acres 

Features: recreational field, 

basketball courts, playground 

840 feet This resource is publicly owned and may provide public 

access to outdoor recreational amenities. However, the 

school is sufficiently distant from the Project such that no use 

would occur. There are existing intervening residential uses 

and roads between the school and the Project. 

No part of Perdew Elementary School would be included in 

the temporary impact area for the Project. No temporary 

44 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
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Property 

Name and 

Map ID 

Official with 

Jurisdiction Description 

Approximate Distance 

from Alignment 

Centerline/ 

Station 

Section 4(f) Use Analysis 

construction easements would be required from this facility. 

No permanent acquisition of property from Perdew 

Elementary School would occur. Access to the resource 

would be uninterrupted. The existing features and attributes 

of the park would remain intact and would not be disrupted 

by operation of the Project. 

Source: Circlepoint 2022. 

Table 5. Parks and Recreation Resources Evaluated for Section 4(f) Use 

Property Name and Map 

ID Official with Jurisdiction Description 

Approximate Distance from 

Alignment Centerline/ 

Station 

San Bernardino National 

Forest (2) 

United States Department 

of Agriculture Forest Service 

(USDA Forest Service) 

Location: Big Bear, CA 92314 

Size: 452,370 acres 

Features: National recreational resource 

Various; typical 200 feet 

Baldy Mesa OHV Road (3) USDA Forest Service 

Location: runs from the Baldy Mesa (Trestles) OHV Staging 

Area to the Desert Front OHV Road 3N24 which heads west to 

Baldy Mesa in the west Cajon valley 

Size: N/A 

Features: Forest service road with recreational access 

0 feet 

Pacific Crest National 

Scenic Trail (PCT) (4) USDA Forest Service 

Location: South of Cajon Junction 

Size: 2,650 miles 

Features: Regional trail 

0 feet 

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Property Name and Map 

ID Official with Jurisdiction Description 

Approximate Distance from 

Alignment Centerline/ 

Station 

Cleghorn Ridge OHV Road 

(5) USDA Forest Service 

Location: runs from the Cleghorn off-ramp on Interstate 15 in 

Cajon Pass over Cleghorn ridge to end at State Highway 138 

Size: 15.2 miles 

Features: Forest service road with recreational access 

450 feet 

Lower Lytle Creek Divide 

Road (6) USDA Forest Service 

Location: Within San Bernardino National Forest 

Size: N/A 

Features: Forest service road with recreational access 

400 feet 

Coyote Canyon Park (8) City of Fontana 

Location: 5065 Coyote Canyon Rd, Fontana, CA 92336 

Size: 15 acres 

Features: Park 

140 feet 

Pacific Electric Trail (9) San Bernardino Associated 

Governments 

Location: 7161 N Heritage Circle Fontana, CA 

begins in downtown Claremont and ends in downtown Rialto 

Size: 21 miles 

Features: Trail 

0 feet 

Day Creek Channel 

Community Trail (11) City of Rancho Cucamonga 

Location: Along Day Creek Blvd 

From Day Creek Park to Adults Sports Park 

Size: 7 miles 

Features: Forest service road with recreational access 

200 feet 

Source: Circlepoint: 2022 

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3.1.1. San Bernardino National Forest 

3.1.1.1. Size and Location 

The San Bernardino National Forest is a 452,370-acre park located in Big Bear, California and 

shown on Figure 3-3 through Figure 3-6. The Project alignment is located adjacent to the west 

portion of the San Bernardino National Forest and the existing I-15 right-of-way bisects the 

forest at various intersections between Duncan Canyon and Cajon Pass. From north to south, 

the Project alignment would pass through the I-15 corridor adjacent to the San Bernardino 

National Forest at various points for 12.2 miles. 

3.1.1.2. Ownership 

This resource is owned and maintained by the United States Department of Agriculture Forest 

Service (USDA Forest Service). 

3.1.1.3. Usage 

The San Bernardino National Forest is a national recreational resource. Activities that occur 

within the national park include recreational hiking trails, picnic areas, campgrounds, and other 

outdoor recreational sports. Within the ELS, the Forest is generally undeveloped and does not 

have picnic areas, campgrounds, trailheads, or outdoor sporting areas. There are two offroad 

vehicle roads and two trails that overlap the Forest within the ESL. These resources are listed 

individually below. 

3.1.2. Baldy Mesa OHV Road 

3.1.2.1. Size and Location 

Baldy Mesa OHV Road runs from the Baldy Mesa OHV Staging Area to the Desert Front OHV 

Road which heads west to Baldy Mesa in West Cajon Valley and is shown on Figure 3-3. 

3.1.2.2. Ownership 

This resource is owned and maintained by the USDA Forest Service. 

3.1.2.3. Usage 

This is forest service road with recreational access. Baldy Mesa OHV Road heading south 

towards SR 138 from the Baldy Mesa OHV Staging Area is open to street-legal vehicles only. All 

roads heading east from the staging area are restricted to street legal vehicles. 

3.1.3. Pacific Crest National Scenic Trail (PCT) 

3.1.3.1. Size and Location 

The Pacific Crest Trail (PCT) is a series of ridgeline trails that extend approximately 2,650 miles 

along the Sierra Nevada and Cascade Mountain Ranges, from Mexico through California 

(including Los Angeles and Kern Counties), Oregon, and Washington to Canada. Approximately 

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420 feet of the national trail is within the Project ESL, just south of the Cajon Junction. The PCT 

is shown on Figure 3-3 and Figure 3-4. 

3.1.3.2. Ownership 

Over its entire distance, the PCT passes through lands owned and managed by a range of 

federal, state, and county agencies; Native American Tribes; and private parties. Overall 

responsibility for managing the PCT lies with the USFS Pacific Southwest Region. In immediate 

areas where the Project alignment crosses the trail, the PCT is on lands owned or managed by 

the U.S. Department of the Interior, Bureau of Land Management, various conservation 

agencies/authorities, and private parties. 

3.1.3.3. Usage 

The PCT is used for recreational activities, including long-distance hiking and equestrian uses. 

The trail is a designated National Scenic Trail and is open for use by hikers and equestrians, but 

not bicyclists or motorized vehicles. The PCT is the westernmost and second-longest 

component of the nearly 8,000-mile-long Triple Crown of Hiking (the PCT, the Appalachian Trail, 

and the Continental Divide Trail). In addition, the trail is part of the 6,875-mile Great Western 

Loop trail system (including the PCT, Pacific Northwest Trail, Continental Divide Trail, Grand 

Enchantment Trail, and Arizona Trail). It is estimated that thousands of recreational users travel 

the PCT annually, with some traveling only short distances and some traveling the entire length 

of the trail. 

Within the ESL, the PCT crosses underneath I-15 via an existing underpass and provides a 

connection to the rest of the trail. In this area, the existing setting of the PCT is not a quiet or 

natural setting due to the existing I-15 transportation corridor. 

3.1.4. Cleghorn Ridge OHV Road 

3.1.4.1. Size and Location 

Cleghorn Ridge off-highway vehicle (OHV) Road is a 5.2-mile Green Sticker Route open to all 

OHV vehicles and is shown on 

Figure 3-4. This route runs from the Cleghorn off-ramp on I-15 in Cajon Pass over Cleghorn 

Ridge and ending at SR 138. Expansive views of the desert are available on the way up Cleghorn 

Ridge, with views of Lake Silverwood appearing at the top. 

3.1.4.2. Ownership 

This resource is owned and maintained by the USDA Forest Service. 

3.1.4.3. Usage 

This resource is an OHV Road open to all OHV vehicles. The forest road with recreational access 

is open to the public and is often used for off-road driving and scenic driving. 

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3.1.5. Lower Lytle Creek Divide Road 

3.1.5.1. Size and Location 

Lower Lytle Creek Divide is hiking trail approximately 8.3 miles long and is shown on 

Figure 3-5 and Figure 3-6. This resource is closest to the Project alignment at its eastern end 

and ends approximately 400 feet away from the Project centerline. 

3.1.5.2. Ownership 

This resource is owned and maintained by the USDA Forest Service. 

3.1.5.3. Usage 

This resource is an out-and-back trail in the San Bernardino National Forest. Activities on the 

trail include hiking and mountain biking. 

3.1.6. Coyote Canyon Park 

3.1.6.1. Size and Location 

Coyote Canyon Park is a 15-acre recreational park located at 5065 Coyote Canyon Road in 

Fontana and is shown on Figure 3-7. 

3.1.6.2. Ownership 

This resource is owned and maintained by the City of Fontana. 

3.1.6.3. Usage 

Coyote Canyon Park is a local recreational park. The park includes day-use facilities such as a 

three baseball/softball fields, a playground, barbeque areas, picnic shelters, trails, snack bar 

and restrooms. 

3.1.7. Pacific Electric Trail 

3.1.7.1. Size and Location 

The Pacific Electric Trail is an approximately 21-mile regional bike trail, beginning in downtown 

Claremont and ending in downtown Rialto. The Trail is shown on Figure 3-8. 

3.1.7.2. Ownership 

This resource is owned and maintained by the San Bernardino Associated Governments. 

3.1.7.3. Usage 

The Pacific Electric Trail is used for recreational activities. The I-15 lanes pass perpendicular 

above the Pacific Electric Trail using an existing overpass, approximately 0.3 mile north of the I15/Baseline Avenue interchange. Approximately 0.1-mile of this paved bike trail is within the 

Project ESL. 

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3.1.8. Day Creek Channel Community Trail 

3.1.8.1. Size and Location 

Day Creek Channel Community Trail is a 7-mile trail located in Fontana California, and is shown 

on Figure 3-8 The trail is located towards the south end of the Project in Section 3 and ends in 

Rancho Cucamonga. 

3.1.8.2. Ownership 

This resource is owned and maintained by the City of Rancho Cucamonga. 

3.1.8.3. Usage 

Day Creek Channel Community Trail is a recreational trail used for activities such as biking 

walking and running. This trail is open to the public from half an hour before sunrise to half 

hour after sunset. 

3.2. Cultural Resources 

The following analysis is based on the Historic Built Environment Technical Report and 

Archaeological Inventory and Eligibility Technical Report prepared by FRA. 

3.2.1. Description of Historic Built Environment and Archaeological Resources 

3.2.1.1. Historic Built Environment Resources 

Within the APE, FRA identified 64 properties that meet the definition of an NRHP-eligible 

historic property. These include previously identified and newly identified historic properties of 

the built environment. To date, of the 64 previously recorded historic age, built environment 

resources surveyed by analysts, FRA has identified 12 built environment resources that are 

either partially or entirely within the Project’s !PE and are considered eligible for listing in the 

NRHP. Those 13 properties consist of four sets of power transmission lines; the Atchison, 

Topeka & Santa Fe (AT&SF) Railroad; one railroad-related bridge; two culverts; the California 

Aqueduct East Branch; National Old Trails Highway/Route 66; one residence; and a cement 

plant. The 13 properties previously determined to be eligible for the NRHP are listed in Table 1. 

I-15 is exempt from Section 106, and the remaining 51 previously recorded built environment 

resources are considered not eligible for listing in the NRHP. 

The 13 properties are listed in Table 6. All of the listed resources are present within the APEAII; there are no known NRHP-eligible built environment historic properties within the APE-ADI. 

3.2.1.2. Archaeological Resources 

Through archaeological inventory and Tribal consultation, FRA has formally determined that 23 

archaeological resources within the APE are eligible for NRHP. FRA assumes that the remaining 

56 archaeological sites are eligible under criterion D for the purposes of this undertaking. Table 

7 presents all 79 NRHP-eligible archaeological resources which include lithic scatters, temporary 

campsites, historically-documented village locations, historic period refuse deposits and home 

sites, railroad debris, water-conveyance systems, one prehistoric archaeological district, and 

50 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
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one landform of tribal cultural significance. Of the 23 formal determinations by FRA, 19 are 

contributing elements to the Crowder Canyon Archaeological District (P-36-029772) which itself 

has been listed previously, two are historically-documented Native American settlements, and 

one is a culturally significant landform. 

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Table 6. NRHP-Eligible Built Environment Historic Properties Within the APE 

Primary 

Number 

Resource Name and Address 

(as applicable) Location Year Built NRHP Status NRHP Criteria 

P-36-008857 Southern California Edison (SCE) Lugo-Mira Loma No. 1 500 kV 

Transmission Line 

N/A 1968–1969 Eligible A, C 

P-36-010315 Southern California Edison (SCE) Boulder Dam–San Bernardino 132 

kV Hoover Dam Transmission Linea 

N/A 1930–1937 Eligible A, C 

P-36-007694 Los Angeles Department of Water and Power (LADWP) Boulder 

Dam to Los Angeles Transmission Lines 

N/A 1933–1940 Eligible A, C 

P-36-010316 Southern California Edison (SCE) Kramer –Victorville Transmission 

Lines 

N/A 1933–1940 Listed A, C 

P-36-006793 AT&SF Railroad N/A ca. 1915 Eligible A,C 

P-36-007295 AT&SF Railroad Bridge over Baldy Mesa Road N/A 1931 Eligible A,C 

P-36-012319 BNSF Railroad Culvert BNSF-4 N/A 1930 Eligible C 

P-36-022664 WSA PF 08 Culvert N/A 1932 Eligible C 

P-36-021351 California Aqueduct East Branch N/A ca. 1960 Eligible A, C 

P-36-002910 National Old Trails Highway; also Route 66 N/A ca. 1920–1970 Eligible A 

P-36-014997 Cour-Tilden House Rancho 

Cucamonga 

ca. 1914 Eligible C 

P-36-006318 Southwestern Portland Cement Company, Victorville Plant Victorville 1916 Eligible A 

Pending United States Postal Service, Etiwanda Station, Rancho 

Cucamonga, 7615 Etiwanda Ave, Rancho Cucamonga, CA 91739 

Rancho 

Cucamonga 

ca. 1960-1966 Eligible C 

Source: HNTB 2022 

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Table 7. Section 4(f) Archaeological Resources within the APE 

Primary Number Description NRHP Status NRHP Criteria 

P-36-000113 

Historic component 

HPRD/ 

Foundations 

Assumed Eligible 

N/A 

P-36-000114 

Historic component 

HPRD/ 

Homestead 

Assumed Eligible 

N/A 

P-36-000122 

Historic component HPRD Assumed Eligible D 

P-36-000421 

Historic component 

Water Conveyance Assumed Eligible D 

P-36-000425 

Historic component 

HPRD Previously Determined Eligible, Criterion A, D A, D 

P-36-004275 Toll Road Assumed Eligible N/A 

P-36-003803 HPRD/ 

Homestead Assumed Eligible D 

P-36-006318 HPRD Assumed Eligible N/A 

P-36-006701 Mining Assumed Eligible D 

P-36-007095 HPRD Assumed Eligible N/A 

P-36-007294 Railroad Debris Assumed Eligible D 

P-36-007761 HPRD Assumed Eligible D 

P-36-008128 HPRD/ 

Landscaping Assumed Eligible D 

P-36-008129 HPRD Assumed Eligible D 

P-36-008130 HPRD Assumed Eligible D 

P-36-008131 HPRD Assumed Eligible D 

P-36-008133 Water 

Conveyance 

Assumed Eligible D 

P-36-009566 HPRD Assumed Eligible D 

P-36-010920 HPRD Assumed Eligible N/A 

P-36-011425 HPRD/ 

Foundations 

Assumed Eligible D 

P-36-011678 Homestead Assumed Eligible N/A 

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Primary Number Description NRHP Status NRHP Criteria 

P-36-012056 HPRD/ 

Foundations 

Assumed Eligible D 

P-36-012650 Mining Assumed Eligible N/A 

P-36-012651 Mining Assumed Eligible N/A 

P-36-012655 Power Lines Assumed Eligible N/A 

P-36-012657 HPRD Assumed Eligible N/A 

P-36-012739 Foundations Assumed Eligible D 

P-36-012838 HPRD/ 

Foundations/ Features 

Assumed Eligible D 

P-36-013300 HPRD Assumed Eligible D 

P-36-013881 Railroad Debris Assumed Eligible D 

P-36-014507 HPRD Assumed Eligible N/A 

P-36-014508 HPRD Assumed Eligible D 

P-36-018058 Historic Camp Eligible, Criterion A, D A, D 

P-36-020173 Farm Assumed Eligible N/A 

P-36-020969 HPRD Assumed Eligible D 

P-36-021286 HPRD Assumed Eligible D 

P-36-021287 HPRD Assumed Eligible D 

P-36-021288 HPRD Assumed Eligible D 

P-36-021300 HPRD Assumed Eligible D 

P-36-021556 HPRD Assumed Eligible D 

P-36-021557 Water Conveyance Assumed Eligible D 

P-36-021565 HPRD Assumed Eligible D 

P-36-022663 HPRD Assumed Eligible N/A 

P-36-023468 HPRD Assumed Eligible D 

P-36-023470 HPRD Assumed Eligible D 

P-36-024573 Road Assumed Eligible D 

P-36-024574 Railroad debris Assumed Eligible D 

P-36-024579 Road Assumed Eligible D 

P-36-024580 Road Assumed Eligible D 

P-36-027084 Foundations Assumed Eligible D 

P-36-027085 Water Conveyance Assumed Eligible D 

P-36-032877 HPRD Assumed Eligible D 

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Primary Number Description NRHP Status NRHP Criteria 

Crowder Canyon 

Archaeological District 

(P-36-029772) 

Prehistoric Archaeological District Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

P-36-000113 Prehistoric Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

P-36-000114 Prehistoric Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

P-36-000115 Prehistoric Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

P-36-000122 Prehistoric Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

P-36-000421 Prehistoric Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

P-36-000713 Prehistoric Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

P-36-003770 Prehistoric Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

P-36-003771 Prehistoric Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

P-36-003772 Prehistoric Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

P-36-003773 Prehistoric Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

P-36-003774 Prehistoric Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

P-36-003775 Prehistoric Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

P-36-005821 Prehistoric Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

P-36-005822 Prehistoric Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

P-36-005824 Prehistoric Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

P-36-005825 Prehistoric Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

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Primary Number Description NRHP Status NRHP Criteria 

P-36-008858 Prehistoric Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

P-36-031655 Prehistoric Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

P-36-032880 Prehistoric Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

P-36-000425 prehistoric 

component 

Habitation Previously Determined Eligible, Criterion D; Determined 

Eligible Criterion A by FRA A, D 

P-36-001397 Bedrock Milling Assumed Eligible D 

P-36-002207 Lithic Scatter Assumed Eligible D 

P-36-002208 Lithic Scatter Assumed Eligible D 

P-36-002302 Stone Feature Assumed Eligible D 

P-36-003680 Lithic Scatter/ Bedrock Milling Assumed Eligible D 

P-36-004265 Lithic Scatter/ Thermal Feature Assumed Eligible D 

P-36-005063 Lithic Scatter Assumed Eligible D 

P-36-006315 Lithic Scatter Assumed Eligible D 

P-36-013882 Thermal Feature Assumed Eligible D 

P-36-033607 Bedrock Milling Assumed Eligible D 

BW22-MH-001 

(oyote’s Nose) Cultural Landform Eligible A 

Source: Dudek 2022 

56 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
 

 

 

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4. Section 4(f) Use Assessment 

The evaluation of potential use of Section 4(f) resources below includes the application of 

Mitigation Measures that are included for the Project and are listed in the Draft EA. Use 

determinations examine the net effect on a resource after the application of Project- or 

resource-specific mitigation measures. 

In addition to the resource descriptions in Sections 3.1 and 3.2 and Table 4 and Table 5, the 

resources listed in Attachment B were evaluated for Section 4(f) applicability. These resources 

were determined not to be subject to Section 4(f) requirements for the reasons described in 

Attachment B and are not discussed further in this report. 

4.1. Parks, Recreation Areas, and Wildlife and Waterfowl Refuges 

Use assessments for the park, recreation, and wildlife and waterfowl refuge resources are 

discussed in this section. The following Section 4(f) findings are preliminary and final use 

determinations will be made after consultation with Section 4(f) officials with jurisdiction and a 

formal public review period that begins with the publication of the Draft EA. Final use 

determinations will be published in the Final EA. 

Each resource is first evaluated for permanent use. If a permanent use is determined to occur, 

an evaluation of whether or not the use would be de minimis is completed. If no permanent use 

is found, an analysis is conducted to evaluate for temporary occupancy. If there is no temporary 

occupancy, an analysis of constructive use is completed. 

4.1.1. San Bernardino National Forest 

4.1.1.1. Permanent Use 

The Project alignment would be adjacent to San Bernardino National Forest lands at various 

points between Duncan Canyon and Cajon Pass. No acquisition of forest land is required, as the 

Project will be built within the I-15 right-of-way in areas adjacent to the Forest. Therefore, 

implementation of the Project would not result in changes in the character of this recreational 

resource or reduce its capacity or value from direct or permanent use. No permanent use of the 

San Bernardino National Forest will occur. 

4.1.1.2. Temporary Use 

Project construction would not require temporary staging or storage of materials in the Forest, 

or otherwise encroach upon Forest land. Therefore, construction of the Project would not 

result in a temporary use of the San Bernardino National Forest. 

4.1.1.3. Constructive Use 

None of the areas of the Forest adjacent to the Project alignment include specific recreation 

amenities such as a campground, trail, or picnic area. The existing setting of the Forest within 

the study area is one disrupted by the existing I-15 transportation corridor. The visual 

environment of the I-15 corridor as viewed from the Forest would remain substantially the 

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same with implementation of the Project, and views from the Forest of I-15 are not a protected 

feature or attribute that qualifies the Forest for Section 4(f) protection. The proximity of the 

Project would not result in impacts that are so severe that the protected activities, features, or 

attributes that qualify the resource for protection under Section 4(f) are substantially impaired. 

Therefore, the Project would not result in a constructive use of this resource. 

4.1.2. Baldy Mesa OHV Road 

4.1.2.1. Permanent Use 

No acquisition of this resource is required. The Project will be built within the I-15 right-of-way, 

which intersects with this road under existing conditions. The OHV Road passes under I-15 and 

has an existing maintenance agreement/easement in place to allow Caltrans access to the 

overpass structure. This would not change or be expanded with implementation of the Project. 

Therefore, implementation of the Project would not result in changes in the character of this 

recreational resource or reduce its capacity or value from direct or permanent use. No 

permanent use of the Baldy Mesa OHV Road will occur. 

4.1.2.2. Temporary Use 

The resource crosses through the temporary impact area of the Project approximately 1.5 miles 

north of the I-15 and State Highway 138 intersection. Project construction would not require 

temporary staging or storage of materials in the Road. Temporary staging or storage of 

materials may be required adjacent to the Road. However, activities would not happen within 

the Road and would not impact the normal operation of this resource. Connectivity along this 

road would be maintained during Project construction with the implementation of appropriate 

detours or phased construction. There are no anticipated permanent adverse physical effects or 

other interference with the activities or purpose of the resource. Therefore, construction of the 

Project would not result in a temporary use of the Baldy Mesa OHV Road. 

4.1.2.3. Constructive Use 

The existing setting of the Road within the study area is one disrupted by the existing I-15 

transportation corridor. As described in the Draft EA, the Project would not substantially 

increase existing noise or vibration levels and is anticipated to improve air quality. The visual 

environment of the I-15 corridor as viewed from the Road would remain substantially the same 

with implementation of the Project, and views from the Road of I-15 are not a protected 

feature or attribute that qualifies the Road for Section 4(f) protection. Further, the primary use 

and enjoyment of the Road as a recreation resource relies on the use of offroad motor vehicles, 

an activity that is loud by nature. The proximity of the Project would not result in impacts that 

are so severe that the protected activities, features, or attributes that qualify the resource for 

protection under Section 4(f) are substantially impaired. Therefore, the Project would not result 

in a constructive use of this resource. 

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4.1.3. Cleghorn Ridge OHV Road 

4.1.3.1. Permanent Use 

No acquisition of this resource is required. The Project will be built within the I-15 right-of-way, 

while the road ends at the east side of the I-15/Cajon Boulevard interchange (outside the 

permanent impact area). Therefore, implementation of the Project would not result in changes 

in the character of this recreational resource or reduce its capacity or value from direct or 

permanent use. No permanent use of the Cleghorn Ridge OHV Road will occur. 

4.1.3.2. Temporary Use 

The resource crosses through the temporary impact area of the Project for a short distance on 

the west end of the resource, at I-15 exit 129, as shown in 

Figure 3-4. Project construction would not require temporary staging or storage of materials in 

the Road. Temporary staging or storage of materials may be required adjacent to the Road. 

However, activities would not happen within the Road and would not impact the normal 

operation of this resource. Connectivity along this road would be maintained during Project 

construction with the implementation of appropriate detours or phased construction. There are 

no anticipated permanent adverse physical effects or other interference with the activities or 

purpose of the resource.. Therefore, construction of the Project would not result in a 

temporary use of the Cleghorn Ridge OHV Road. 

4.1.3.3. Constructive Use 

The existing setting of the Road within the study area is one disrupted by the existing I-15 

transportation corridor. As described in the Draft EA, the Project would not substantially 

increase existing noise or vibration levels and is anticipated to improve air quality. The visual 

environment of the I-15 corridor as viewed from the Road would remain substantially the same 

with implementation of the Project, and views from the Road of I-15 are not a protected 

feature or attribute that qualifies the Road for Section 4(f) protection. Further, the primary use 

and enjoyment of the Road as a recreation resource relies on the use of offroad motor vehicles, 

an activity that is loud by nature. The proximity of the Project would not result in impacts that 

are so severe that the protected activities, features, or attributes that qualify the resource for 

protection under Section 4(f) are substantially impaired. Therefore, the Project would not result 

in a constructive use of this resource. 

4.1.4. Lower Lytle Creek Divide Road 

4.1.4.1. Permanent Use 

No acquisition of this resource is required. The Project will be built within the I-15 right-of-way, 

while the road ends outside of the I-15 right-of-way on the west side of the I-15 south of the I15/I-215 interchange. The Road is outside the permanent and temporary impact area. 

Therefore, implementation of the Project would not result in changes in the character of this 

recreational resource or reduce its capacity or value from direct or permanent use. No 

permanent use of Lower Lytle Creek Divide Road will occur. 

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4.1.4.2. Temporary Use 

The Road is not within the temporary impact area, as shown in Figure 3-6. Therefore, 

construction of the Project would not result in a temporary use of Lower Lytle Creek Divide 

Road. 

4.1.4.3. Constructive Use 

The existing setting of the Road within the study area is one disrupted by the existing I-15 

transportation corridor. As described in the Draft EA, the Project would not substantially 

increase existing noise or vibration levels and is anticipated to improve air quality. The visual 

environment of the I-15 corridor as viewed from the Road would remain substantially the same 

with implementation of the Project, and views from the Road of I-15 are not a protected 

feature or attribute that qualifies the Road for Section 4(f) protection. Users would have a 

similar experience along the Road as they do under existing conditions, with a similar noise and 

visual environment. The proximity of the Project would not result in impacts that are so severe 

that the protected activities, features, or attributes that qualify the resource for protection 

under Section 4(f) are substantially impaired. Therefore, the Project would not result in a 

constructive use of this resource. 

4.1.5. Pacific Crest National Scenic Trail (PCT) 

4.1.5.1. Permanent Use 

No acquisition of this resource is required. The Project footprint overlaps a section of the 

existing PCT approximately 275 feet south of the California Highway Patrol (CHP) Cajon 

Platform Scales. The PCT crosses under the Project alignment via an existing underpass, and no 

realignment of the PCT is required. The PCT has an existing maintenance agreement/easement 

in place to allow Caltrans access to the overpass structure. This would not change or be 

expanded with implementation of the Project. Therefore, implementation of the Project would 

not result in changes in the character of this recreational resource or reduce its capacity or 

value from direct or permanent use. No permanent use of the PCT will occur. 

4.1.5.2. Temporary Use 

The resource crosses through the temporary impact area of the Project approximately .5 miles 

north of I-15 exit 129, as shown in 

Figure 3-4. Project construction would not require temporary staging or storage of materials in 

the Trail. Temporary staging or storage of materials may be required adjacent to the Trail. 

However, activities would not happen within the Trail and would not impact the normal 

operation of this resource. Connectivity along the Trail would be maintained during Project 

construction. Connectivity to the larger, regional, and international Trails would be maintained 

during Project construction. There are no anticipated permanent adverse physical effects or 

other interference with the activities or purpose of the resource. Therefore, construction of the 

Project would not result in a temporary use of the PCT. 

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4.1.5.3. Constructive Use 

The existing setting of the PCT within the study area is one disrupted by the existing I-15 

transportation corridor. As described in the Draft EA, the Project would not substantially 

increase existing noise or vibration levels and is anticipated to improve air quality. The visual 

environment of the I-15 corridor as viewed from the PCT would remain substantially the same 

with implementation of the Project, and views from the PCT of I-15 are not a protected feature 

or attribute that qualifies the PCT for Section 4(f) protection. Users would have a similar 

experience along the Trail as they do under existing conditions, with a similar noise and visual 

environment. The proximity of the Project would not result in impacts that are so severe that 

the protected activities, features, or attributes that qualify the resource for protection under 

Section 4(f) are substantially impaired. Therefore, the Project would not result in a constructive 

use of this resource. 

4.1.6. Coyote Canyon Park 

4.1.6.1. Permanent Use 

No acquisition of this resource is required. The Project will be built within the I-15 right-of-way, 

while the Park ends adjacent to the I-15/Duncan Canyon Road interchange (outside the 

permanent and temporary impact area). The Project would require I-15 freeway and 

interchange ramp modifications at Duncan Canyon Road near Coyote Canyon Park. No 

acquisition of Coyote Canyon Park would be necessary to accommodate these ramp 

modifications. Therefore, implementation of the Project would not result in changes in the 

character of this recreational resource or reduce its capacity or value from direct or permanent 

use. No permanent use of Coyote Canyon Park will occur. 

4.1.6.2. Temporary Use 

The Park is not within the temporary impact area, as shown in Figure 3-7. Access to the Park is 

currently available through Coyote Canyon Road and would not be affected during Project 

construction Therefore, construction of the Project would not result in a temporary use of 

Coyote Canyon Park. 

4.1.6.3. Constructive Use 

The existing setting of the Park is one disrupted by the existing I-15 transportation corridor 

including the Duncan Canyon interchange. As described in the Draft EA, the Project would not 

substantially increase existing noise or vibration levels and is anticipated to improve air quality. 

The visual environment of the I-15 corridor as viewed from the Park would remain substantially 

the same with implementation of the Project, and views from the Park of I-15 are not a 

protected feature or attribute that qualifies the Park for Section 4(f) protection. Users would 

have a similar experience as they do under existing conditions, with a similar noise and visual 

environment. The proximity of the Project would not result in impacts that are so severe that 

the protected activities, features, or attributes that qualify the resource for protection under 

Section 4(f) are substantially impaired. Therefore, the Project would not result in a constructive 

use of this resource. 

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4.1.7. Pacific Electric Trail 

4.1.7.1. Permanent Use 

No acquisition of this resource is required. The Project footprint overlaps a section of the 

existing Trail approximately 0.3 mile north of the I-15/Baseline Avenue interchange. While the 

Pacific Electric’s entire length is 21 miles, approximately 0.1 mile of this paved bike trail is 

within the Project ESL. The Trail crosses under the Project alignment via an existing underpass, 

and no realignment of the Trail is required. The Trail has an existing maintenance 

agreement/easement in place to allow Caltrans access to the overpass structure. This would 

not change or be expanded with implementation of the Project. Therefore, implementation of 

the Project would not result in changes in the character of this recreational resource or reduce 

its capacity or value from direct or permanent use. No permanent use of the Pacific Electric 

Trail will occur. 

4.1.7.2. Temporary Use 

The resource crosses through the temporary impact area of the Project approximately 0.3 mile 

north of the I-15/Baseline Avenue interchange, as shown in Figure 3-8. Project construction 

would not require temporary staging or storage of materials in the Trail. Temporary staging or 

storage of materials may be required adjacent to the Trail. However, activities would not 

happen within the Trail and would not impact the normal operation of this resource. 

Connectivity along the Trail would be maintained during Project construction. Connectivity to 

the larger, regional, and international Trails would be maintained during Project construction. 

There are no anticipated permanent adverse physical effects or other interference with the 

activities or purpose of the resource. Therefore, construction of the Project would not result in 

a temporary use of the Pacific Electric Trail. 

4.1.7.3. Constructive Use 

The existing setting of the Trail within the study area is one disrupted by the existing I-15 

transportation corridor. As described in the Draft EA, the Project would not substantially 

increase existing noise or vibration levels and is anticipated to improve air quality. The visual 

environment of the I-15 corridor as viewed from the Trail would remain substantially the same 

with implementation of the Project, and views from the Trail of I-15 are not a protected feature 

or attribute that qualifies this resource for Section 4(f) protection. Users would have a similar 

experience along the Trail as they do under existing conditions, with a similar noise and visual 

environment. The proximity of the Project would not result in impacts that are so severe that 

the protected activities, features, or attributes that qualify the resource for protection under 

Section 4(f) are substantially impaired. Therefore, the Project would not result in a constructive 

use of this resource. 

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4.1.8. Day Creek Channel Community Trail 

4.1.8.1. Permanent Use 

No acquisition of this resource is required. The Project will be built within the I-15 right-of-way, 

while the Trail is outside of the I-15 right-of-way on the west side I-15. The Trail is outside the 

permanent and temporary impact area: the Project alignment would run adjacent to 0.2 mile of 

the existing Day Creek Channel Community Trail in the City of Rancho Cucamonga, near Day 

Creek Boulevard and behind the parking lot associated with commercial uses south of Foothill 

Boulevard. No realignment of the Trail is required, and existing fencing separates I-15 from the 

Trail. No permanent use of the Day Creek Channel Community Trail will occur. 

4.1.8.2. Temporary Use 

This resource is not within the Project’s temporary impact area, as shown in Figure 3-8. 

Therefore, construction of the Project would not result in a temporary use of Day Creek 

Channel Community Trail. 

4.1.8.3. Constructive Use 

The existing setting of the Trail within the study area is one disrupted by the existing I-15 

transportation corridor. As described in the Draft EA, the Project would not substantially 

increase existing noise or vibration levels and is anticipated to improve air quality. The visual 

environment of the I-15 corridor as viewed from the Trail would remain substantially the same 

with implementation of the Project, and views from the Trail of I-15 are not a protected feature 

or attribute that qualifies this resource for Section 4(f) protection. Users would have a similar 

experience along the Trail as they do under existing conditions, with a similar noise and visual 

environment. The proximity of the Project would not result in impacts that are so severe that 

the protected activities, features, or attributes that qualify the resource for protection under 

Section 4(f) are substantially impaired. Although trail users may notice increases in noise and 

dust levels during construction, it would not affect existing recreational activities, features, or 

attributes of the community trail. Trail connectivity along Day Creek Boulevard would be always 

maintained during Project construction. Therefore, the Project would not result in a 

constructive use of this resource. 

4.2. Cultural Resources 

The following analysis is based on the Historic Built Environment Technical Report and 

Archaeological Inventory and Eligibility Technical Report prepared by FRA. 

Concurrently with the preparation of the Draft EA, FRA initiated consultation under Section 106 

of the NHPA. FRA is the Lead Federal agency for compliance with Section 106 of the NHPA for 

the Project. 

4.2.1. Historic Built Environment Resources 

Table 8 below provides an evaluation of built environment historic resources protected by 

Section 4(f). As a part of Section 106 consultation, FRA has preliminarily determined that no 

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adverse effects to built environment historic resources would occur as a result of the project. 

All of the listed properties are present within the APE-AII; there are no known NRHP-eligible 

built environment historic properties within the APE-ADI, and no adverse effects caused by 

physical impacts have been identified. Therefore, there is no potential for a Section 4(f) use 

through permanent incorporation or temporary occupancy for any historic resource. This 

evaluation focuses on the potential for constructive use of historic built environment resources 

based on whether proximity impact(s) would substantially impair the features or attributes that 

contribute to the eligibility of the historic site. 

Compliance with Section 4(f) requires FRA to carry out a reasonable level of effort to identify 

historic properties prior to issuing a Section 4(f) approval. The reasonableness of the level of 

effort depends upon the anticipated effects of the project and nature of likely historic resources 

present in the affected project area. Accordingly, the reasonable level of effort varies from 

project to project. In the case of this Project, FRA has conducted site surveys and prepared an 

historic built environment inventory and eligibility report along with a draft finding of effect for 

the Project. Consultation with the SHPO is ongoing. 

Table 8. Section 4(f) Constructive Use Assessment of Built 

Environment Historic Properties Within the APE 

Resource Name and Address 

(as applicable) 

NRHP 

Criteria 

Preliminary 

Section 106 

Finding 

Preliminary Section 4(f) Determination 

SCE Lugo-Mira Loma No. 1 

500 kV Transmission Line 

A, C No Adverse Effect Visual effects: minor permanent visual and 

setting effects 

Physical effects: none 

Noise and Vibration effects: temporary noise 

and vibration during construction 

This linear resource crosses overhead within the 

APE in multiple locations in Sections 2 and 3 of 

the Project. Given 1) the length of this resource 

(over 100 miles) and the relatively narrow 

segments of the resource that cross overhead 

within the APE (3000 feet or less), and 2) the 

existing setting in these areas of an existing 

transportation corridor and associated 

infrastructure, the visual changes to the setting 

resulting from the addition of a new 

transportation mode (rail) would not 

substantially change the setting. The Project 

would not affect this resource’s NRHP eligibility 

or otherwise substantially impair the attributes 

of this historic property. No constructive use 

would occur. 

SCE Boulder Dam–San 

Bernardino 132 kV Hoover 

Dam Transmission Linea 

A, C No Adverse Effect Visual effects: minor permanent visual and 

setting effect 

Physical effects: none 

Noise and Vibration effects: temporary noise or 

vibration during construction 

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Resource Name and Address 

(as applicable) 

NRHP 

Criteria 

Preliminary 

Section 106 

Finding 

Preliminary Section 4(f) Determination 

This resource crosses the APE for a distance of 

approximately 2 miles, north of Victorville in the 

vicinity of the Quarry Road overcrossing in 

Section 1 and for a distance of approximately 

2,500 feet in Hesperia (Section 1). Projectrelated construction would cause temporary 

noise and vibration effects. Changes to the 

setting (Project located in median of the 

interstate, at grade and elevated) would be in an 

area where the dominant contributing feature is 

the desert landscape. Changes to the desert 

landscape would not occur, therefore these 

features would not be changed. The Project 

would not affect this resource’s NRHP eligibility 

or otherwise substantially impair the attributes 

of this historic property. No constructive use 

would occur. 

Los Angeles Department of 

Water and Power (LADWP) 

Boulder Dam to Los Angeles 

Transmission Lines 

A, C No Adverse Effect Visual effects: minor permanent visual and 

setting effects 

Physical effects: none 

Noise and Vibration effects: temporary noise or 

vibration during construction 

No permanent noise or vibration impacts would 

occur to this resource, as the towers of the 

subject transmission line corridor are more than 

500 feet from the proposed alignment. The 

Project would not affect this resource’s NRHP 

eligibility or otherwise substantially impair the 

attributes of this historic property. No 

constructive use would occur. 

Southern California Edison 

SCE Kramer –Victorville 

Transmission Lines 

A, C No Adverse Effect Visual effects: minor permanent visual and 

setting effects 

Physical effects: none 

Noise and Vibration effects: temporary noise 

and vibration during construction 

This linear resource crosses overhead within the 

APE at one location in Hesperia (Section 1) for a 

distance of 2,500 feet. Given the length of this 

resource (approximately 100 miles), effects from 

minor changes to the visual setting would be 

minimal. The Project would not alter physical 

features within the setting where it crosses the 

APE, where the setting is a low-density 

residential development, the interstate (noncontributing) and multiple transmission line 

corridors. Introduction of the Project within the 

median of I-15 is not considered visually 

intrusive and would not affect the subject 

property's ability to convey its significance under 

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Resource Name and Address 

(as applicable) 

NRHP 

Criteria 

Preliminary 

Section 106 

Finding 

Preliminary Section 4(f) Determination 

NRHP Criteria A and C. The Project would not 

affect this resource’s NRHP eligibility or 

otherwise substantially impair the attributes of 

this historic property. No constructive use would 

occur. 

Atchison Topeka & Santa Fe 

(AT&SF) Railroad 

A, C No Adverse Effect Visual effects: temporary visual and setting 

effects during construction 

Physical effects: none 

Noise and Vibration effects: none anticipated, 

given the resource is an active freight rail 

corridor 

The alignment would add new crossings over or 

under the historic property at multiple locations 

within the existing footprint of I 15. The Project’s

alignment – both median-running, at-grade 

(most Project locations) and elevated, siderunning (in the Rancho Cucamonga vicinity) –

would not result in the alteration of the physical 

features or the setting that convey the 

significance of this resource. These features 

include the materials, alignment (engineering), 

and the rural desert and mountain pass setting 

elements. With construction of the Project, this 

resource would continue to convey its 

significance under Criteria A and C. The Project 

would not affect this resource’s NRHP eligibility 

or otherwise substantially impair the attributes 

of this historic property. No constructive use 

would occur. 

Railroad Bridge over Baldy 

Mesa Road 

A,C No Adverse Effect Visual effects: none 

Physical effects: none 

Noise and Vibration effects: temporary noise or 

vibration. 

This railroad bridge is located east of I‐15 

between Cajon Junction and Alray, in Segment 2 

of the Project. This resource is east of the 

southbound lanes of I‐15, and the proposed rail 

alignment is in the median, at grade. Introducing 

another railroad-related visual element in the 

vicinity of this bridge would not change the 

physical features within the subject property's 

setting; it is located approximately 1000 feet 

east of the I-15 corridor. The Project would not 

affect this resource’s NRHP eligibility or 

otherwise substantially impair the attributes of 

this historic property. No constructive use would 

occur. 

66 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
 

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Resource Name and Address 

(as applicable) 

NRHP 

Criteria 

Preliminary 

Section 106 

Finding 

Preliminary Section 4(f) Determination 

Burlington Northern Santa Fe 

(BNSF) Railroad Culvert BNSF4 

A No Adverse Effect Visual effects: minor permanent visual and 

setting effects 

Physical effects: none 

Noise and Vibration effects: temporary noise or 

vibration 

This historic culvert is approximately 1,000 feet 

east of the northbound I 15 travel lanes in 

Section 2 (median-running alignment in Cajon 

Pass). Introducing the median-running alignment 

over 1,000 feet from the culvert does not have 

the potential to alter the culvert's historic 

character-defining features in any meaningful 

way. The Project would not affect this resource’s 

NRHP eligibility or otherwise substantially impair 

the attributes of this historic property. No 

constructive use would occur. 

WSA-PF-08 Culvert A No Adverse Effect Visual effects: none 

Physical effects: none 

Noise and Vibration effects: temporary noise 

and vibration during construction 

This historic culvert crosses under I 15 in Section 

2 of the Project. It is also part of the I 15 right-ofway, which is exempt from Section 106 as part of 

the Interstate Highway Exemption. Introducing 

the median-running alignment in the exempt I 

15 right-of-way does not have the potential to 

alter the culvert's historic character-defining 

features in any meaningful way. The Project 

would not affect this resource’s NRHP eligibility 

or otherwise substantially impair the attributes 

of this historic property. No constructive use 

would occur. 

California Aqueduct East 

Branch 

A, C No Adverse Effect Visual effects: minor permanent setting effect 

Physical effects: none 

Noise and Vibration effects: temporary noise 

and vibration during project construction 

The Project would add a bridge spanning the 

aqueduct; the bridge would be between two 

existing I 15 culvert/bridges. Given 1) the overall 

length of the aqueduct (444 miles), 2) the short 

bridge span between the I 15 bridges, and 3) the 

existing setting of a major transportation 

corridor (I-15), the effects are not considered 

adverse. The setting of the aqueduct contains 

bridges spanning across it and these are 

considered to be ubiquitous features of the 

setting. Introduction of an additional span 

between two existing bridges is not considered 

visually intrusive or incompatible. The aqueduct 

SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 67 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Resource Name and Address 

(as applicable) 

NRHP 

Criteria 

Preliminary 

Section 106 

Finding 

Preliminary Section 4(f) Determination 

is not a resource that would be affected by 

noise. The Project would not affect this 

resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this historic 

property. No constructive use would occur. 

National Old Trails Highway; 

also Route 66 

A No Adverse Effect Visual effects: minor visual and setting effect 

Physical effects: none 

Noise and Vibration effects: temporary noise 

and vibration during construction 

The Project would not introduce an incompatible 

visual or audible element to the setting of the 

contributing section of Route 66 in Cajon Pass, as 

an active transportation corridor (with interstate 

and railroads) already exists in the resource’s 

immediate setting. The alignment would cross 

the historic property at multiple locations of the 

resource that do not retain integrity and 

therefore are non-contributing segments of the 

subject property. The Project would not affect 

this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this historic 

property. No constructive use would occur. 

Cour-Tilden House C No Adverse Effect Visual effects: moderate visual and setting 

effects 

Physical effects: none 

Noise and Vibration effects: temporary noise or 

vibration during project construction. 

This residence is 300 feet west of the I 15 

corridor at the periphery of the APE in Section 3 

of the Project. The rail alignment would be 

elevated on the west side of I 15 and would be 

visible and audible from the rear of the 

residence. Introducing the elevated rail 

alignment to the setting would not diminish the 

integrity of setting such that it would no longer 

be able to convey its significance. The existing 

setting includes an active (elevated) 

transportation corridor (I 15); the Project would 

not introduce an incompatible visual or audible 

element to the setting because an active 

transportation corridor already exists in the 

resource’s immediate setting. The Project would 

not affect this resource’s NRHP eligibility or

otherwise substantially impair the attributes of 

this historic property. No constructive use would 

occur. 

Southwestern Portland 

Cement Company, Victorville 

Plant 

A No Adverse Effect Visual effects: minor permanent visual and 

setting effects 

68 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
 

 

BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Resource Name and Address 

(as applicable) 

NRHP 

Criteria 

Preliminary 

Section 106 

Finding 

Preliminary Section 4(f) Determination 

Physical effects: none Noise 

and Vibration effects: none 

This resource is 1300 feet west of I 15 in Section 

1 of the Project (Victorville). The rail alignment 

would be elevated on a bridge on the west side 

of the existing I 15 (Mojave River) Southbound 

bridge. Introduction of a new bridge next to 

existing interstate bridges would not change the 

character of the setting of the subject property, 

given its distance removed. the new bridge 

would not be an intrusive visual or audible 

element as there are already bridges in the 

setting at some distance removed. No new 

audible elements would result in noise or 

vibration above previously existing levels at this 

distance in an industrial context. No constructive 

use would occur. 

United States Postal Service, 

Etiwanda Station, Rancho 

Cucamonga 

C No Adverse Effect Visual effects: minor temporary and moderate 

permanent setting effects 

Physical effects: none 

Noise and vibration effects: temporary noise or 

vibration during project construction. 

The subject property is 300 feet west of the I 15 

corridor in Section 3 of the Project. The rail 

alignment would be elevated along the west side 

of I 15 and would be visible from the rear of the 

post office building, as the interstate crosses 

over surface streets at this location. Introducing 

the elevated rail alignment to the setting would 

not diminish the integrity of setting such that it 

would no longer be able to convey its 

significance; the existing setting includes an 

elevated, active transportation corridor (I 15) in 

the viewshed. Introduction of a new structure 

between the existing I 15 overpass bridges and 

the subject property would not be out of 

character in this urban setting. The Project 

would not introduce an incompatible visual or 

audible element to the setting. Noise and 

vibration studies for the Project indicate that it 

would not result in vibration or noise effects to 

the resource during construction or operations 

above previously existing levels. The Project 

would not affect this resource’s NRHP eligibility 

or otherwise substantially impair the attributes 

of this historic property. No constructive use 

would occur. 

Source: HNTB 2022 

SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 69 
4.2.2. Archaeological Resources 

BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Table 9 below provides an evaluation of archaeological resources protected by Section 4(f). As a 

part of Section 106 consultation, FRA has preliminarily determined that no adverse effects to 

archaeological resources would occur as a result of the project. All of the listed properties are 

present within the APE-AII; there are no known NRHP-eligible archaeological resources within 

the APE-ADI, and no adverse effects have been identified. Therefore, there is no potential for a 

Section 4(f) use through permanent incorporation or temporary occupancy for any 

archaeological resource. This evaluation focuses on the potential for constructive use of 

archaeological resources based on whether proximity impact(s) would substantially impair the 

features or attributes that contribute to the eligibility of the archaeological site. 

70 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Table 9. Section 4(f) Constructive Use Assessment of Archaeological Resources Within the APE 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

P-36-000113 

(Historic 

component)t 

HPRD/ 

Foundations 

N/A No Adverse Effect 

N/A 

P-36-000114 

(Historic 

component)t 

HPRD/ 

Homestead 

N/A No Adverse Effect 

N/A 

P-36-000122 

(Historic 

component)t 

HPRD D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-000421 

(Historic 

component)t 

Water 

Conveyance 

D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 71 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

P-36-000425 

(Historic 

component)t 

HPRD A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-004275 Toll Road N/A No Adverse Effect N/A 

P-36-003803 HPRD/ 

Homestead 

D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-006318 HPRD N/A No Adverse Effect N/A 

P-36-006701 Mining D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

72 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-007095 HPRD N/A No Adverse Effect N/A 

P-36-007294 Railroad 

Debris 

D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-007761 HPRD D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-008128 HPRD/ 

Landscaping 

D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 73 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-008129 HPRD D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-008130 HPRD D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-008131 HPRD D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

74 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-008133 Water 

Conveyance 

D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-009566 HPRD D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-010920 HPRD N/A No Adverse Effect N/A 

SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 75 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

P-36-011425 HPRD/ 

Foundations 

D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-011678 Homestead N/A No Adverse Effect N/A 

P-36-012056 HPRD/ 

Foundations 

D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-012650 Mining N/A No Adverse Effect N/A 

P-36-012651 Mining N/A No Adverse Effect N/A 

P-36-012655 Power Lines N/A No Adverse Effect N/A 

P-36-012657 HPRD N/A No Adverse Effect N/A 

P-36-012739 Foundations D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

76 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-012838 HPRD/ 

Foundations/ 

Features 

D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-013300 HPRD D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-013881 Railroad 

Debris 

D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 77 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-014507 HPRD N/A No Adverse Effect N/A 

P-36-014508 HPRD D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-018058 Historic camp 

(aka Sycamore 

Grove) for 

early Mormon 

pioneers in 

the San 

Bernardino 

area. Also 

likely site of 

the "Lost 

Rancheria of 

Cajon Pass" 

A, D No Adverse Effect Visual effects: Visual intrusions would not diminish the qualities that contribute to 

NRHP eligibility. The project would not impact this resource’s contribution to the 

road pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archaeological resource. No constructive 

use would occur. 

P-36-020173 Farm N/A No Adverse Effect N/A 

78 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

P-36-020969 HPRD D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-021286 HPRD D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-021287 HPRD D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 79 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-021288 HPRD D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-021300 HPRD D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-021556 HPRD D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

80 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-021557 Water 

Conveyance 

D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-021565 HPRD D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-022663 HPRD N/A No Adverse Effect N/A 

P-36-023468 HPRD D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 81 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-023470 HPRD D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-024573 Road D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-024574 Railroad 

debris 

D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

82 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-024579 Road D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-024580 Road D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 83 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

P-36-027084 Foundations D No Adverse Effect • Criterion A—Properties that are associated with events that 

have made a significant contribution to the broad patterns of 

our history 

• Criterion D—Properties that have yielded, or may be likely to 

yield, information important in prehistory or history 

P-36-027085 Water 

Conveyance 

D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-032877 HPRD D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-029772 Crowder 

Canyon 

A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

84 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

Archaeological 

district (CCAD) 

pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: District is sufficiently distant from limits of disturbance that no 

effects or no adverse effects will occur from the displacement of archaeological 

materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-000113 Contributing 

Element to 

CCAD 

A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-000114 Contributing 

Element to 

CCAD 

A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 85 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-000115 Contributing 

Element to 

CCAD 

A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-000122 Contributing 

Element to 

CCAD 

A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-000421 Contributing 

Element to 

CCAD 

A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

pattern of history. The resource would still provide information important to 

prehistory or history. 

86 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-000713 Contributing 

Element to 

CCAD 

A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-003770 Contributing 

Element to 

CCAD 

A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 87 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

P-36-003771 Contributing 

Element to 

CCAD 

A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-003772 Contributing 

Element to 

CCAD 

A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-003773 Contributing 

Element to 

CCAD 

A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

88 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-003774 Contributing 

Element to 

CCAD 

A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-003775 Contributing 

Element to 

CCAD 

A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-005821 Contributing 

Element to 

CCAD 

A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 89 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-005822 Contributing 

Element to 

CCAD 

A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-005824 Contributing 

Element to 

CCAD 

A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

90 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-005825 Contributing 

Element to 

CCAD 

A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-008858 Contributing 

Element to 

CCAD 

A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-031655 Contributing 

Element to 

CCAD 

A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

pattern of history. The resource would still provide information important to 

prehistory or history. 

SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 91 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-032880 Contributing 

Element to 

CCAD 

A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-000425 

(prehistoric 

component) 

Habitation A, D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The project would not impact this resources contribution to the road 

pattern of history. The resource would still provide information important to 

prehistory or history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

92 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

P-36-001397 Bedrock 

Milling 

D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-002207 Lithic Scatter D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-002208 Lithic Scatter D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 93 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-002302 Stone Feature D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-003680 Lithic Scatter/ 

Bedrock 

Milling 

D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-004265 Lithic Scatter/ 

Thermal 

Feature 

D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

94 SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL PROJECT 

Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-005063 Lithic Scatter D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-006315 Lithic Scatter D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-013882 Thermal 

Feature 

D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

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Primary 

Number Description NRHP Criteria 

Preliminary Section 

106 Finding NRHP Effects Determination 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

P-36-033607 Bedrock 

Milling 

D No Adverse Effect Visual effects: The resource would still be fully visible upon completion of the 

project. Visual intrusions would not diminish the qualities that contribute to NRHP 

eligibility. The resource would still provide information important to prehistory or 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials. 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

BW22-MH001 

(oyote’s

Nose) 

Culturally 

significant 

landform 

identified 

during tribal 

consultation 

A No Adverse Effect Visual effects: The resource would still be visible upon completion of the project. 

Visual intrusions would not diminish the qualities that contribute to NRHP eligibility. 

The project would not impact this resources contribution to the road pattern of 

history. 

Physical effects: Site is sufficiently distant from limits of disturbance that no effects 

or no adverse effects will occur from the displacement of archaeological materials 

Noise and Vibration effects: Construction and operation vibrations and noise levels 

are below existing limits for the I-15 freeway and will have no adverse effect to this 

resource. 

The Project would not affect this resource’s NRHP eligibility or otherwise 

substantially impair the attributes of this archeological resource. No constructive 

use would occur. 

Source: Dudek 2022 

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5. Section 4(f) Avoidance Alternatives 

At this time, FRA has not identified a potential use of any resource protected under Section 4(f). 

Therefore, the Project as designed avoids a use of 4(f) resources and no avoidance alternatives 

are required. 

6. Section 4(f) Measures to Minimize Harm/Least Harm Analysis 

At this time, FRA has not identified a potential use of any resource protected under Section 4(f). 

Therefore, the Project as designed and with application of avoidance, minimization, and 

mitigation measures discussed in the Draft EA, no use would occur. Additional measures to 

minimize harm are not warranted, nor required, in order to avoid a Section 4(f) use. 

7. Section 6(f) Analysis 

No Section 6(f) resources have been identified within the ESL. Some larger resources such as 

the PCT were partially acquired through Section 6(f) funds, and FRA continues to research 

whether the small segments of these resources within the ESL were purchased with these 

funds. However, as demonstrated above, the Project would not result in the conversion of any 

recreational property to a non-recreational purpose. Therefore, there is no potential for use of 

a Section 6(f) resource. 

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Attachment A 

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SECTION 4(F) AND 6(F) EVALUATIONS, OCTOBER 2022 101