AIR QUALITY AND GREENHOUSE GAS 

TECHNICAL REPORT 

Brightline West Cajon Pass High-Speed Rail Project 

October 2022 

Prepared for 

Federal Railroad Administration 

Prepared by 

Ramboll US Consulting, Inc. 
 

 

 

 

 

 

 

 

 

BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL 

Contents 

Abbreviations and Acronyms...........................................................................................................v 

1. Introduction .............................................................................................................................. 1 

2. Project Description ................................................................................................................... 1 

2.1. Background...................................................................................................................... 1 

2.2. Project Area..................................................................................................................... 2 

2.3. Purpose of and Need for the Project .............................................................................. 2 

2.3.1. Purpose ................................................................................................................... 2 

2.3.2. Need........................................................................................................................ 2 

3. Project Baseline and Alternatives............................................................................................. 7 

3.1. Project Baseline............................................................................................................... 7 

3.2. Build Alternative.............................................................................................................. 7 

3.2.1. Section 1 – High Desert........................................................................................... 8 

3.2.2. Section 2 – Cajon Pass............................................................................................. 9 

3.2.3. Section 3 – Greater Los Angeles ........................................................................... 10 

3.2.4. Construction.......................................................................................................... 11 

4. Methodology........................................................................................................................... 11 

4.1. Regulatory Framework.................................................................................................. 11 

4.1.1. Federal Regulations .............................................................................................. 11 

4.1.2. California Regulations ........................................................................................... 17 

4.1.3. National and State Ambient Air Quality Standards .............................................. 24 

4.1.4. Urban Air Toxics .................................................................................................... 25 

4.2. Scope of the Air Quality and Greenhouse Gas Assessment.......................................... 26 

4.3. Pollutants of Potential Concern .................................................................................... 26 

4.4. Study Area ..................................................................................................................... 27 

4.5. Assessments Performed................................................................................................ 27 

4.6. Methods Used ............................................................................................................... 28 

4.6.1. Quantification of Construction Emissions ............................................................ 28 

4.6.2. Operational Emission Evaluation .......................................................................... 35 

4.6.3. General Conformity De Minimis Comparison....................................................... 35 

4.6.4. Localized Carbon Monoxide Impacts.................................................................... 35 

5. Affected Environment............................................................................................................. 36 

5.1. General Discussion of Air Quality Pollutants................................................................. 36 

5.1.1. Criteria Air Pollutants............................................................................................ 36 

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BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL 

5.1.2. Greenhouse Gases ................................................................................................ 38 

5.2. Air Resources by Basin .................................................................................................. 39 

5.2.1. South Coast Air Basin ............................................................................................ 39 

5.2.2. Mojave Desert Air Basin........................................................................................ 40 

5.3. Air Quality Setting ......................................................................................................... 42 

5.3.1. Existing Emissions ................................................................................................. 42 

5.3.2. Ambient Air Monitoring Data ............................................................................... 42 

5.3.3. Climate Data.......................................................................................................... 42 

6. Environmental Consequences and Mitigation........................................................................ 43 

6.1. Build Alternative............................................................................................................ 43 

6.1.1. Construction Effects.............................................................................................. 43 

6.1.2. Operational Effects ............................................................................................... 43 

6.2. General Conformity De Minimis Summary ................................................................... 44 

6.3. No Build Alternative ...................................................................................................... 44 

6.3.1. Construction Effects.............................................................................................. 44 

6.3.2. Operational Effects ............................................................................................... 44 

6.4. Avoidance, Minimization, and/or Mitigation Measures ............................................... 44 

7. References .............................................................................................................................. 47 

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BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL 

Figures 

Figure 2-1. Project Area and Vicinity 4 

Figure 4-1. Limit of Disturbance 31 

Figure 5-1. South Coast Air Basin 40 

Figure 5-2. Mojave Desert Air Basin 41 

Tables 

Table 2-1 National and State (California) Ambient Air Quality Standards 

Table 5-1 Summary of Air Quality and Greenhouse Gas Assessments Performed 

Table 5-2 Construction Schedule Assumptions 

Table 5-3 Construction Equipment Mix Assumptions 

Table 5-4 Estimated Material Movement Volumes 

Table 5-5 Demolition Waste Volumes 

Table 5-6 Construction Worker, Vendor, and Hauling Trips Summary 

Table 5-7 SCE Electricity Carbon Intensity Factors 

Table 5-8 Greenhouse Gas Emission Factors for Passenger Cars 

Table 5-9 De Minimis Levels 

Table 6-1 Federal Attainment Status for South Coast Air Basin and Mojave Desert Air Basin 

Table 6-2 Existing Mobile On-Road Emissions for San Bernardino County 

Table 6-3 Local Ambient Air Quality Data near Rancho Cucamonga Passenger Station 

Table 6-4 Local Ambient Air Quality Data near Hesperia Passenger Station 

Table 7-1 Criteria Air Pollutant Emissions for Project Construction in the South Coast Air 

Basin 

Table 7-2 Criteria Air Pollutant Emissions for Project Construction in the Mojave Desert Air 

Basin 

Table 7-3 Operational GHG Emissions in South Coast Air Basin 

Table 7-4 Operational GHG Emissions in Mojave Desert Air Basin 

Table 7-5 Carbon Monoxide Concentrations for 2025 Opening Year 

Table 7-6 Carbon Monoxide Concentrations for 2045 Horizon Year with Mitigation 

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BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL 

Appendices 

Appendix A CalEEMod Model Outputs for Project Construction 

Appendix B Construction Emission Calculations 

Appendix C CO Hotspot Analyses 

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Abbreviations and Acronyms 

AB Assembly Bill 

ACC Advanced Clean Cars 

AQ air quality 

AQMD Air Quality Management District 

AQMP Air Quality Management Plan 

AVAQMD Antelope Valley Air Quality Management District 

BAAQMD Bay Area Air Quality Management District 

CAA Clean Air Act 

CAAQS California Ambient Air Quality Standards 

CAP criteria air pollutant 

CARB California Air Resources Board 

CAT Climate Action Team 

CCAA California Clean Air Act 

CEC California Energy Commission 

CEQA California Environmental Quality Act 

CFR Code of Federal Regulations 

CH4 methane 

CHP California Highway Patrol 

CO carbon monoxide 

CO2 carbon dioxide 

CPUC California Public Utilities Commission 

DOE United States Department of Energy 

EISA Energy Independence and Security Act 

EMFAC California Air Resources Board’s Emission FACtor model 

EO Executive Order 

EV Electric Vehicle 

FR Federal Register 

FHWA Federal Highway Administration 

FRA Federal Railroad Administration 

g gram 

gal gallon 

GHG greenhouse gas 

GWP global warming potential 

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BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL 

HFC hydrofluorocarbon 

HSR High Speed Rail 

I-15 Interstate 15 

IPCC Intergovernmental Panel on Climate Change 

L Liter 

lb pound 

LCFS Low Carbon Fuel Standard 

LOS level of service 

MDAB Mojave Desert Air Basin 

MDAQMD Mojave Desert Air Quality Management District 

MOU memorandum of understanding 

mph miles per hour 

MSAT mobile-source air toxics 

MWh Megawatt hours 

MY model years 

N2O nitrous oxide 

NAAQS National Ambient Air Quality Standards 

NEPA National Environmental Policy Act 

NHTSA National Highway Traffic Safety Administration 

NO nitric oxide 

NO2 nitrogen dioxide 

NOX oxides of nitrogen 

O3 Ozone 

OFFROAD California Air Resources Board’s Emissions Inventory Program model 

OPR Office of Planning and Research 

Pb lead 

PFC perfluorocarbons 

PL Public Law 

PM particulate matter 

PM10 particulate matter less than 10 microns in diameter 

PM2.5 particulate matter less than 2.5 microns in diameter 

ppb parts per billion 

ppm parts per million 

RTP Regional Transportation Plan 

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RTP/SCS Regional Transportation Plan/Sustainable Communities Strategy 

SafeTREC Safe Transportation Research & Education Center 

SB Senate Bill 

SBCTA San Bernardino County Transportation Authority 

SCAB South Coast Air Basin 

SCAG Southern California Association of Governments 

SCAQMD South Coast Air Quality Management District 

SCE Southern California Edison 

SCORE Southern California Optimized Rail Expansion 

SF6 sulfur hexafluoride 

SIP State implementation plan 

SLCP short-lived climate pollutants 

SO2 sulfur dioxide 

SOX oxides of sulfur 

sqft square feet 

SR State Route 

TAC toxic air contaminants 

US United States 

USC United States Code 

USDOT United States Department of Transportation 

USEPA United States Environmental Protection Agency 

VMT vehicle miles traveled 

VOC volatile organic compound 

ZE zero emission 

ZEV zero emission vehicles 

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BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL 

1. Introduction 

DesertXpress Enterprises, LLC (dba “Brightline West”) proposes to construct and operate the 

Cajon Pass High-Speed Rail Project (Project), a 49-mile train system capable of reaching a top 

speed of approximately 140 miles per hour (mph) between Victor Valley and Rancho 

Cucamonga, California. The Project includes two new railway stations—one in Hesperia, and 

one in Rancho Cucamonga. The connecting station in Victor Valley would be constructed as part 

of a separate project that was evaluated in the DesertXpress Final Environmental Impact 

Statement (Final EIS, FRA 2011). 

The Project would be constructed within the Interstate 15 (I-15) right-of-way (ROW) for 48 

miles and on existing transportation corridors for the last mile into the proposed Rancho 

Cucamonga station. The Project would be powered by overhead electric catenary and require 

construction of one new traction power substation (TPSS) in the Hesperia area. The 

maintenance facility that was evaluated with the Brightline West Victor Valley High-Speed Rail 

(HSR) Passenger Project would provide the primary maintenance functions, although layover 

tracks are anticipated at the Rancho Cucamonga station, which could include light maintenance 

capability, such as interior cleaning and daily inspection. 

Trains are expected to operate daily on 45-minute headways between Victor Valley and Rancho 

Cucamonga. The trip between Victor Valley and Rancho Cucamonga would be approximately 

35 minutes. Service would be coordinated with existing and planned Metrolink service at the 

Rancho Cucamonga station to provide a convenient connection between the high-speed rail 

and commuter rail systems. 

The Project would be constructed and operated under a lease agreement with the California 

Department of Transportation (Caltrans) for the use of the I-15 right-of-way and the station at 

Hesperia. Brightline West would secure additional agreements with Caltrans for Right-of-Way 

Use, Design & Construction Oversight and Reimbursement, and Operations & Maintenance, as 

necessary. For the last mile of the project from I-15 to the Rancho Cucamonga Station, there 

will be Agreements with the City of Rancho Cucamonga and the San Bernardino County 

Transportation Authority (SBCTA) for land rights, construction, operations and maintenance. 

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 

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BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL 

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 would work together to 

advance their shared interest in the success of the Project. 

2.2. Project Area 

The Project would construct and operate a 49-mile train system capable of speeds up to 

approximately 140 mph between Victor Valley, California and Rancho Cucamonga, California 

(Project). The Project includes two new railway stations: one in Hesperia, and one in Rancho 

Cucamonga, and will connect to another Brightline West station in Victor Valley. The proposed 

rail alignment would be 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 Project area is depicted in Figure 2-1. 

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 

would provide a convenient, efficient, and environmentally sustainable alternative to 

automobile travel on the highly congested I-15 freeway. The Project would add capacity to the 

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

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

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

Cucamonga for Project users would be approximately 30 percent faster during normal 

conditions and at least twice as fast during congestion peak periods. The Project would reduce 

automobile vehicle miles traveled (VMT), resulting in a corresponding reduction in greenhouse 

gas (GHG) and air quality 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. 

2.3.2. Need 

The Project is needed to address transportation capacity deficiencies, major points of 

congestion, limited travel mode choices, safety deficiencies, 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 Cajon Pass segment of the I-15, 

which is capacity-constrained. Further, the freeway system leading into the I-15 from points 

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BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL 

west, east, and south, including I-10, State Route 210 (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 would also support federal and state policies focused on climate change and the 

need to reduce VMT and associated GHG emissions. 

2.3.2.1. 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 

caused by roadway capacity constraints, frequent accidents, and various factors that cause 

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

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

thereby avoiding driving next to many large freight trucks, 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 Apple Valley in the AM peak period, and travel speeds on most 

segments would also decrease—some by more than 10 mph—in the PM 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 in the range of 31 to 

38 percent from 2014 to 2045. The Project Report states the existing 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. Because 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 would improve conditions in the general purpose lanes in many segments, it would 

cause the segment between the I-10 and Fourth Street to worsen in the PM peak hour (both 

directions). In the AM peak hour, the segment between Arrow Route and Fourth Street would 

worsen in the southbound direction. The segment between Baseline Road and SR-210 would 

continue to operate at over capacity conditions in all scenarios. 

SCAG’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 the Cajon Pass as a truck bottleneck, with over 15,000 annual vehicle hours of 

delay. 

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Figure 2-1 Project Area and Vicinity 

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BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL 

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. 

2.3.2.2. 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 convenient 

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

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 U.S. Census Bureau’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 (U.S. 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 Census Bureau’s estimate of 617,828 in 2018.

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

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

station would 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, would provide more direct access to the densely populated 

centers in Southern California for both drivers and Metrolink riders; 87 percent of the 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, would 

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 would be 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 would also support SCAG’s Connect SoCal Passenger Rail Technical Report, which

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

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

Greater Los Angeles and the 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 BLW station at Victor Valley for a connection to Las Vegas. Southern 

California residents could take the Los Angeles Metro rail, regional bus systems, Amtrak, or 

Metrolink to Los Angeles Union Station to connect via the Metrolink San Bernardino Line to the 

Rancho Cucamonga station. Residents could also take the planned West Valley Connector Bus 

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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 (ONT) project 

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

International Airport. 

Additionally, SBCTA and SCAG’s 2015 Advanced Regional Rail Integrated Vision – East (ARRIVE 

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

would 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 formation of areas that are walkable and that 

provide mobility options in the region. The Project would further the goals of the ARRIVE 

Corridor plan by increasing the activity centers that can be accessed by Southern California’s 

rail network. Additionally, the Southern California Optimized Rail Expansion (SCORE) program is 

intended to increase speeds, reliability, and capacity on Metrolink lines including on the San 

Gabriel Subdivision which serves 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 next to the Project’s 

proposed station in Hesperia. 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. 

FHWA’s Southern California Regional Freight Study (USDOT 2020) identifies I-15 as a major 

interstate highway corridor that provides access to the interior of the United States for goods 

arriving at the ports of the Los Angeles region and ranks it among the highest truck volume 

corridors in the western United States. Caltrans’ 2015 Interregional Transportation Strategic 

Plan identifies I-15 as a high priority corridor, among six nationally identified “Corridors of the 

Future,” and a “vital link between Mexico, Southern California, 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 would help maintain freeway capacity for truck freight use by 

removing passenger vehicles from the roadway network. 

2.3.2.3. Safety 

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

with diversion of vehicle trips to HSR. On a national level, comparing miles traveled via 

commercial aircraft, train, and automobiles on highways, auto travel on highways has by far the 

highest rate of passenger fatalities per mile traveled. 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 2016, the Bureau of Transportation Statistics’ National 

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

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BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL 

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

rail. HSR is one of the safest forms of travel. 

The California Office of Traffic Safety ranks San Bernardino County 16th-worst out of 

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

According to the University of California, Berkeley, and SafeTREC’s Transportation Injury 

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

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

Cajon Pass, although the Cajon Pass accounts for only 6.5 percent of the length of I-15 in the 

county. 

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

Bernardino to 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. By connecting the Victor Valley to 

Rancho Cucamonga, the Project would allow more travelers to stay off segments of I-15. 

3. Project Baseline and Alternatives 

3.1. Project Baseline 

The AQ analyses performed for any project under NEPA are based on the changes (i.e., 

increments) in project-related emissions and air quality relative to a baseline condition. The 

definition of baseline under NEPA for this Project is discussed below: 

• The NEPA Baseline represents conditions in the ‘build-out’ year of the Project. In this 

case, the No Build Alternative in the year 2025 will represent the NEPA baseline. 

Under the No Build Alternative, none of the Project features would be constructed. The No 

Build Alternative provides a baseline against which to compare the Build Alternative. The 

existing transportation facilities within the Project area would remain unchanged except for 

planned and programmed improvements under other projects, such as projects listed in state 

and local plans. 

3.2. Build Alternative 

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

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

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

Rancho Cucamonga, approximately 1 mile of the rail alignment would be in city street, railroad, 

or utility rights-of-way. 

The proposed rail alignment would 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 would be predominately 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 4 BNSF and 3 UP railroad crossings) and to provide a 

safe incline for train operation. The rail alignment would be predominantly single­track, with 

limited double-track segments in Victor Valley (2.6 miles, including 0.9 miles constructed as part 

of the DesertXpress High-Speed Passenger Train Project), Hesperia (5.5 miles), and Rancho 

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Cucamonga (2 miles). This would allow for 45-minute headways in the opening year between 

Victor Valley and Rancho Cucamonga and 22.5-minute headways by year 11. These headways, 

along with the ability to couple trains (double passenger capacity), would address projected 

ridership needs for the foreseeable future. 

For analytical purposes, the Build Alternative is described in three 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 I-15, to 

the I-15/Oak Hill Road interchange in Hesperia 

• Section 2: Cajon Pass – from the I-15/Oak Hill Road interchange, continuing south along 

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 I-15, through the existing Metrolink station in 

Rancho Cucamonga to Haven Avenue 

3.2.1. Section 1 – High Desert 

The proposed rail alignment would connect to the DesertXpress High Speed Train alignment 

approximately one mile south of the Victor Valley station in Apple Valley. The Victor Valley 

station was proposed by the DesertXpress High Speed Train Project (DesertXpress Project) and 

approved in 2011 and modified by the re-evaluation in 2020. From this point, the alignment 

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

predominantly single track; however, the rail alignment would 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 would include a new structure over the 

existing CEMEX railroad bridge. Based on future discussion with CEMEX, the existing railroad 

bridge may be reconstructed as part of the DesertXpress project, in which case the alignment 

would run at-grade in the median under the railroad bridge. 

Brightline West will build a new Southbound on ramp and bridge at South Stoddard Wells Road 

to replace similar existing facilities further south.1 This in-turn requires modifications of 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-15.2 The 

existing I-15 bridge would be widened to accommodate the rail line. The alignment would then 

continue at grade in the I-15 median with minor roadway widenings for the remainder of 

Segment 1. This portion of the alignment would 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. 

1 These improvements would be consistent with Caltrans’ planned Interstate 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. 

2 Air quality modeling was conducted based on a prior version of the alignment that ran to the east of the I-15 right-of-way before crossing into 

the median. However, project changes to move the Project into the median would not affect the analysis. 

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A new substation would be constructed to support the Project along I-15, between Mesa Street 

and Mojave Street. The area is currently largely 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 would serve daily travelers between the High Desert of San Bernardino County and 

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

northbound PM weekday on selected Brightline train coaches. The northbound on-ramp to 

Joshua Street would be realigned closer to the freeway, and station parking would be on the 

north side of Joshua Street. Parking would 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 would be replaced. The Joshua 

Street bridge would be reconstructed at a higher elevation, requiring raising of the I-15 ramps 

and Mariposa Road. The passenger platform would be located within the I-15 median, with 

direct access from the reconstructed Joshua Street bridge at the southern end of the doubletrack segment in Hesperia. The Project design includes adequate parking areas to 

accommodate parking demand in the opening year. 

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 off-ramp, D Street/E 

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

Road, Bear Valley Road, Main Street/Phelan Road, US-395, Ranchero Road, Oak Hill 

Road and Joshua Street 

• Station Area: Hesperia station platform, station access/infrastructure, surface parking 

lot accommodating approximately 360 vehicles, bus pick up/drop off areas, Kiss and 

Ride 

3.2.2. Section 2 – Cajon Pass 

Beginning at the I-15/Oak Hill Road interchange and traveling south, the alignment would 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 would be entirely single-track. The Project 

would require replacement of California Highway Patrol (CHP) emergency crossovers where the 

new guideway would block existing crossovers. Four new crossover locations would be placed 

to take advantage of existing CHP access between the separated I-15 alignments at the 

following locations 

• West of Forestry Road crossing the northbound lanes. 

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

near Forestry Road, across the northbound lanes. 

• West of the Baldy Mesa (Trestles) OHV Staging Area, across the northbound lanes. 

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

across both the north and southbound lanes. 

The alignment would remain at grade throughout Segment 2. 

Where I-15 northbound and southbound lanes reconnect at the foot of the Cajon Pass, the rail 

alignment would be within the I-15 median. This would 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. 

• Bridges/Viaducts: None 

• 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 

3.2.3. Section 3 – Greater Los Angeles 

Beginning at the Kenwood Avenue interchange, the proposed rail alignment would continue at 

grade in the I-15 median. At the I-15/I-215 interchange, the alignment would 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 would require 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 would transition to an aerial alignment and elevate over the I-15 southbound 

lanes south of Church Street and cross at Foothill Boulevard. It would 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 would transition onto an aerial structure and would 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 would maintain a single-track configuration 

prior to the existing the freeway median south of Church Street, where it would transition to a 

double­track 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 

would be constructed parallel to and above the existing eastbound Metrolink platform, 

extending over Milliken Avenue. . A new parking structure is proposed a Rancho Cucamonga 

station, and would 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 I-15 southbound lanes and 

along existing rail corridor near Rancho Cucamonga station 

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• Reconstructions/Interchange Modifications: 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 share parking structure for vehicles, and a bus plaza 

3.2.4. Construction 

In general, construction activities would consist of clearing, grading, excavation, placing fill, 

stockpiling materials, constructing bridges and walls, installing drainage, installing sub-ballast 

and subgrade, placing and anchoring railroad ties, placing ballast material, and tamping ballast, 

constructing stations, substations, mobilization and demobilization. Construction equipment 

would likely include dump trucks, excavators, loaders, cranes, water trucks, backhoes, scrapers, 

rollers, ballast tampers, concrete trucks, and drill rigs. 

For new and reconstructed overpasses and bridges, construction activities would include 

clearing, grubbing, demolition of existing structures, excavation and drilling for foundations, 

concrete pouring, formwork and rebar placement for foundations, falsework installation, 

construction of bridge decking, placement of ballast and ties, mobilization and demobilization. 

Most construction activities would occur on Caltrans right-of-way. Some, for the rail stations 

and power substations, would occur on public property owned by the City of Rancho 

Cucamonga, SBCTA, or State of California. Temporary construction areas, or TCAs, are 

properties that would be temporarily utilized for construction staging and storage. The Project 

would require TCAs along the alignment between Victor Valley and Rancho Cucamonga. 

4. Methodology 

4.1. Regulatory Framework 

Statutes, regulations, plans, and policies have been adopted that address air quality issues. The 

Project alignment and station areas are subject to air quality regulations developed and 

implemented at the federal and state levels. Those regulations, plans, and policies that are 

relevant to the Project are discussed below. 

4.1.1. Federal Regulations 

Air quality is regulated at the federal level under the Clean Air Act (CAA) of 19703 and the Final 

Conformity Rule.4 The Clean Air Act Amendments of 19905 direct the USEPA to implement 

environmental policies and regulations that will ensure better air quality. According to Section 

176(c) of the Clean Air Act Amendments: “No federal agency may approve, accept, or fund any 

transportation plan, program, or project unless such plan, program or project has been found 

to conform to any applicable SIP in effect under this act.” Section 176(c) defines conformity as 

follows: conformity to an implementation plan’s purpose of eliminating or reducing the severity 

3 42 United States Code (USC) §7401 et seq. 1970. 

4 40 Code of Federal Regulations (CFR) Parts 51 and 93. 

5 Public Law (PL) 101-549, 1990. 

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and number of violations of the NAAQS and achieving expeditious attainment of such 

standards; such activities will not cause any of the following occurrences: 

• Cause or contribute to any new violation of any NAAQS in any area, 

• Increase the frequency or severity of any existing violation of any NAAQS in any area, or 

• Delay timely attainment of any NAAQS or any required interim emissions reductions or 

other milestones in any area. 

The federal CAA requires states to submit a SIP for areas designated as nonattainment for 

federal air quality standards. The SIP, which is reviewed and approved by USEPA, must 

demonstrate how the federal standards will be achieved. Failing to submit a plan or secure 

approval could lead to denial of federal funding and permits. In cases where the SIP is 

submitted by the state but fails to demonstrate achievement of the standards, USEPA is 

directed to prepare a federal implementation plan. 

4.1.1.1. Transportation Conformity Rule 

The concept of transportation conformity was introduced in the 1977 federal CAA, which 

includes a provision to ensure that federal transportation investments conform to the SIP for 

meeting the NAAQS.6 Conformity requirements were made substantially more rigorous in the 

federal CAA amendments of 1990, and the transportation conformity regulation that details 

implementation of the conformity requirements was first issued in November 1993, though the 

requirements have been amended many times. The amendments to the Transportation 

Conformity Rule are found at Title 40 Code of Federal Regulations (CFR) parts 51 and 93).7 

Since federal funding would not be used to construct or operate the Project, the Project would 

not be subject to transportation conformity requirements. Instead, the Project would be 

subject to general conformity requirements, which are described below. The General 

Conformity Rule applies to all federal actions except programs and projects requiring funding or 

approval from the United States Department of Transportation (USDOT), the Federal Highway 

Administration, the Federal Transit Administration, or a Metropolitan Planning Organization. In 

lieu of a general conformity analysis, these latter types of programs and projects must comply 

with the Transportation Conformity Rule promulgated by the USDOT on November 24, 1993 (58 

FR 62197). 

4.1.1.2. General Conformity Rule 

The General Conformity Rule was promulgated in 1993 in Volume 58 of the Federal Register 

(FR) page 63214 (58 FR 63214) to implement the conformity provision of Title I, section 

176(c)(1) of the federal Clean Air Act.

8 The General Conformity Regulations were revised by 

USEPA in March 2010 to improve the process federal entities use to demonstrate that their 

actions will not contribute to a violation of a national air quality standard.9 Section 176(c)(1) 

requires that the federal government not engage, support, or provide financial assistance for 

6 United States Environmental Protection Agency (USEPA). 1993. Transportation Conformity Regulations. 

7 40 CFR Parts 51 and 93. 

8 USEPA. 1993. General Conformity Regulations. 

9 USEPA. 2010. Revisions to the General Conformity Regulations. 

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licensing or permitting, or approving any activity not conforming to an approved CAA 

implementation plan. 

The General Conformity Rule is codified in Title 40 CFR Part 51, Subpart W and Part 93, Subpart 

B, Determining Conformity of General Federal Actions to State or Federal Implementation 

Plans. The General Conformity Rule applies to all federal actions except programs and projects 

requiring funding or approval from the USDO), the Federal Highway Administration, the Federal 

Transit Administration, or a Metropolitan Planning Organization. 

4.1.1.3. Federal Climate Change Policy 

There are currently no federal standards related to greenhouse gas (GHG) emissions and no 

federal framework for considering GHG impacts in NEPA analyses. 

Massachusetts v. USEPA 

In April 2007, in Massachusetts v. USEPA,10 the United States (US) Supreme Court directed the 

Administrator of the USEPA to determine whether GHG emissions from new motor vehicles 

cause or contribute to air pollution that may reasonably be anticipated to endanger public 

health or welfare, or whether the science is too uncertain to make a reasoned decision. In 

making these decisions, the USEPA Administrator was directed to follow the language of 

Section 202(a) of the CAA. In December 2009, the Administrator signed a final rule with two 

distinct findings regarding GHGs under Section 202(a) of the CAA: 

• Elevated concentrations of GHGs— carbon dioxide (CO2), methane (CH4), nitrous oxide 

(N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride 

(SF6)—in the atmosphere threaten the public health and welfare of current and future 

generations. This is referred to as the “endangerment finding.”

• The combined emissions of GHGs—CO2, CH4, N2O, and HFCs—from new motor vehicles 

and new motor vehicle engines contribute to the GHG air pollution that endangers 

public health and welfare. This is referred to as the “cause or contribute finding.” 11 

These two findings were necessary to establish the foundation for regulation of GHGs from new 

motor vehicles as air pollutants under the CAA. 

Federal Plan to Reduce GHG Emissions by 2025 

In 2015, President Obama signed Executive Order (EO) 13693,12 which was intended to reduce 

the federal government’s GHG emissions by 40 percent by 2025 by requiring the following: 

1. Ensuring that 25 percent of total energy consumption is from clean energy sources; 

2. Reducing energy use in federal buildings by 2.5 percent per year between 2015 and 

2025; 

10 Massachusetts v. USEPA. 2007. 549 US 497. 

11 USEPA. n.d. Endangerment and Cause or Contribute Findings for Greenhouse Gases Under Section 202(a) of the Clean Air Act. 

12 Federal Register. 2015. Executive Order 13693: Planning for Federal Sustainability in the Next Decade. 

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3. Reducing per-mile GHG emissions from federal fleets by 30 percent (from 2014 levels) 

by 2025 and increasing the percentage of zero-emissions and plug-in hybrid vehicles in 

federal fleets; and 

4. Reducing water intensity in federal buildings by 2 percent per year through 2025. 

This executive order was revoked by President Trump’s EO 13834 in May 2018, which requires 

Federal agencies meet statutory requirements in a manner that increases efficiency, optimizes 

performance, eliminates unnecessary use of resources, and protects the environment. In 

implementing this policy, each agency shall prioritize actions that reduce waste, cut costs, 

enhance the resilience of Federal infrastructure and operations, and enable more effective 

accomplishment of its mission.13 President Biden’s EO 13990 revoked Executive Order 13834 

except for sections 6 (Duties of the Federal Chief Sustainability Officer), 7 (Duties of Heads of 

Agencies), and 11 (General Provisions). EO 13990 directs Federal agencies to immediately 

review, and take action to address, Federal regulations put into effect and other actions taken 

during the Trump Administration that conflict with national objectives to improve public health 

and the environment; ensure access to clean air and water; limit exposure to dangerous 

chemicals and pesticides; hold polluters accountable, including those who disproportionately 

harm communities of color and low-income communities; reduce greenhouse gas emissions; 

bolster resilience to the impacts of climate change; restore and expand our national treasures 

and monuments; and prioritize both environmental justice and employment. 14 

Executive Order 14008 

On January 27, 2021, President Biden issued an Executive Order on Tackling the Climate Crisis 

at Home and Abroad (Executive Order 14008). 15 Part I of the Order highlights putting the 

climate crisis at the center of United States foreign policy and national security. Addressing the 

climate crisis will require significant short-term global reductions in GHG emissions and net zero 

global emissions by mid-century or sooner. The United States will pursue green recovery efforts 

and initiatives to advance the clean energy transition. 

Part II of the Order relays the government-wide approach to the climate crisis, which involves 

reducing climate pollution in every sector of the economy, especially through innovation, 

commercialization, and deployment of clean energy technologies and infrastructure. A National 

Climate Task Force is established to focus on addressing the climate crisis through key federal 

actions to reduce climate change impacts. A 100 percent carbon pollution-free electricity sector 

is targeted by no later than 2035 and a net-zero emissions economy is to be achieved by no 

later than 2050. Offshore wind is aimed to be doubled by 2030. Opportunities for federal 

funding of clean energy technology and infrastructure shall be identified. Federal permitting 

decisions need to consider the effects of GHG emissions and climate change. 

13 Federal Register. 2018. Executive Order 13834: Efficient Federal Operations. 

14 White House Briefing Room. 2021a. Executive Order on Protecting Public Health and the Environment and Restoring Science to Tackle the 

Climate Crisis. 

15 White House Briefing Room. 2021b. Executive Order on Tackling the Climate Crisis at Home and Abroad. 

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Paris Climate Agreement 

On June 1, 2017, President Trump withdrew the United States from the Paris Agreement. 16 The 

Paris Agreement was negotiated within the United Nations Framework Convention on Climate 

Change in 2015 to reduce GHG emissions internationally. The goal of the Paris Agreement was 

to keep the global temperature rise this century to below 2 degrees Celsius above pre-industrial 

standards, with efforts to limit temperature increase even further to 1.5 degrees Celsius. The 

Paris Agreement became effective on November 4, 2016. As of October 5, 2016, 155 of 197 

parties had ratified the Paris Agreement. 17 On January 20, 2021, President Biden signed an 

Executive Order formally rejoining the United States to the Paris Agreement. 18 

Federal Vehicle Standards 

In response to the Massachusetts v. USEPA decision discussed above, in 2007, President Bush 

directed the USEPA, the Department of Transportation (USDOT), and the Department of Energy 

(DOE) to establish regulations that reduce GHG emissions from motor vehicles, non-road 

vehicles, and non-road engines by 2008. In 2009, the National Highway Traffic Safety 

Administration (NHTSA) issued a final rule regulating fuel efficiency for and GHG emissions from 

cars and light-duty trucks for model year 2011; and, in 2010, the USEPA and NHTSA issued a 

final rule regulating cars and light-duty trucks for model years 2012–2016. 

In August 2017, the USEPA asked for additional information and data relevant to assessing 

whether the GHG emissions standards for model years 2022-2025 remain appropriate. In early 

2018, the USEPA Administrator announced that the midterm evaluation for the GHG emissions 

standards for cars and light-duty trucks for model years 2022-2025 was completed and stated 

his determination that the current standards should be revised in light of recent data. 

Subsequently, in 2018, the USEPA and NHTSA proposed to amend certain existing Corporate 

Average Fuel Economy (CAFE) standards and tailpipe carbon dioxide emissions standards for 

passenger cars and light trucks and establish new standards, covering model years 2021-2026. 

Compared to maintaining the post-2020 standards now in place, the pending proposal would 

increase US fuel consumption. 19 California and other states have announced their intent to 

challenge federal actions that would delay or eliminate GHG reductions. In April 2020, NHTSA 

and USEPA amended the CAFE and GHG emissions standards for passenger cars and light trucks 

and established new less stringent standards, covering model years 2021 through 2026. 

In 2010, President Obama issued a memorandum directing the same federal agencies to 

establish additional standards regarding fuel efficiency and GHG reduction, clean fuels, and 

advanced vehicle infrastructure. In response to this directive, the USEPA and NHTSA proposed 

stringent, coordinated federal GHG and fuel economy standards for model year 2017–2025 

light-duty vehicles. 

In addition to the regulations applicable to cars and light-duty trucks described above, in 2011, 

the USEPA and NHTSA announced fuel economy and GHG standards for medium- and heavy16 USEPA. 2017. Administrator Scott Pruitt Speech on Paris Accord, As Prepared. 

17 United Nations Framework Convention on Climate Change. 2017. The Paris Agreement. 

18 White House Briefing Room. 2021c. Paris Climate Agreement. 

19 Federal Register. 2018. The Safer Affordable Fuel-Efficient (SAFE) Vehicles Final Rule for Model Years 2021-2026 Passenger Cars and Light 

Trucks. 

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duty trucks for model years 2014–2018. The standards for CO2 emissions and fuel consumption 

are tailored to three main vehicle categories: combination tractors, heavy-duty pickup trucks 

and vans, and vocational vehicles. 

In August 2016, the USEPA and NHTSA announced the adoption of the phase two program 

related to the fuel economy and GHG standards for medium- and heavy-duty trucks. The phase 

two program will apply to vehicles with model year 2018 through 2027 for certain trailers, and 

model years 2021 through 2027 for semi-trucks, large pickup trucks, vans, and all types of sizes 

of buses and work trucks. The final standards are expected to lower carbon dioxide emissions 

by approximately 1.1 billion MT and reduce oil consumption by up to two billion barrels over 

the lifetime of the vehicles sold under the program.20 

On September 27, 2019, the USEPA and NHTSA published the SAFE Rule (Part One).21 The SAFE 

Rule (Part One) went into effect in November 2019, and revoked California’s authority to set its 

own GHGs standards and set zero emission vehicle mandates in California. The SAFE Rule (Part 

One) froze new zero emission vehicle (ZEV) sales at model year 2020 levels for year 2021 and 

beyond. The SAFE Rule was subject to ongoing litigation and on February 8, 2021, the D.C. 

Circuit Court of Appeals granted the Biden Administration’s motion to stay litigation over Part 

One of the SAFE Rule. On April 22 and April 28, 2021, respectively, NHTSA and USEPA formally 

announced their intent to reconsider the Safe Rule (Part One).22,23 In December 2021, after 

reviewing all the public comments submitted on NHTSA’s April 2021 Notice of Proposed

Rulemaking, NHTSA finalized the CAFE Preemption rulemaking to withdraw its portions of the 

SAFE Rule (Part One).

24 Also in December 2021, USEPA finalized revised national GHG emissions 

standards for passenger cars and light trucks for Model Years 2023-2026.25 On March 9, 2022, 

EPA reinstated California’s authority under the CAA to implement its own GHG emission 

standards and zero emission vehicle sales mandate and entirely rescinded the SAFE Rule (Part 

One). 

Energy Independence and Security Act 

The Energy Independence and Security Act of 2007 (EISA) facilitates the reduction of national 

GHG emissions by requiring the following: 

• Increasing the supply of alternative fuel sources by setting a mandatory Renewable Fuel 

Standard that requires fuel producers to use at least 36 billion gallons of biofuel in 2022; 

• Prescribing or revising standards affecting regional efficiency for heating and cooling 

products, procedures for new or amended standards, energy conservation, energy 

efficiency labeling for consumer electronic products, residential boiler efficiency, electric 

motor efficiency, and home appliances; 

20 USEPA and National Highway Traffic Safety Agency (NHTSA), 2016. Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium 

and Heavy-Duty Engines and Vehicles – Phase 2. 

21 USEPA and NHTSA. 2019. Federal Register, Vol. 84, No. 188, The Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule Part One: One National 

Program. 

22 NHTSA. 2021a. NHTSA Advances Biden-Harris Administration’s Climate & Jobs Goals. 

23 USEPA. 2021a. Federal Register, Vol. 86, No. 80, California State Motor Vehicle Pollution Control Standards; Advanced Clean Car Program; 

Reconsideration of a previous Withdrawal of a Waiver of Preemption; Opportunity for Public Hearing and Public Comment. 

24 NHTSA. 2021b. NHTSA Repeals SAFE I Rule. 

25 USEPA. 2021b. Final Rule to Revise Existing National GHG Emissions Standards for Passenger Cars and Light Trucks Through Model Year 

2026. 

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• Requiring approximately 25 percent greater efficiency for light bulbs by phasing out 

incandescent light bulbs between 2012 and 2014; requiring approximately 200 percent 

greater efficiency for light bulbs, or similar energy savings, by 2020; and 

• While superseded by the USEPA and NHTSA actions described above, 

(i) establishing miles per gallon targets for cars and light trucks and (ii) directing the 

NHTSA to establish a fuel economy program for medium- and heavy-duty trucks and 

create a separate fuel economy standard for trucks. 

Additional provisions of EISA address energy savings in government and public institutions, 

promote research for alternative energy, additional research in carbon capture, international 

energy programs, and the creation of “green jobs.”

4.1.2. California Regulations 

Air quality is regulated at the state level by the California Air Resources Board (CARB), the 

agency designated to prepare the SIP required by the federal CAA under the California Clean Air 

Act of 1988 (Assembly Bill [AB] 2595) and other provisions of the California Health and Safety 

Code.26 California’s Clean Air Act (CCAA) requires all districts designated as nonattainment for 

any pollutant to “adopt and enforce rules and regulations to achieve and maintain the state and 

federal ambient air quality standards in all areas affected by emission sources under their 

jurisdiction.”

The responsibility for controlling air pollution in California is shared by 35 local or regional air 

pollution control and air quality management districts, CARB, and USEPA. The districts issue 

permits for industrial pollutant sources and adopt air quality management plans and rules. 

CARB establishes the state ambient air quality standards, adopts and enforces emission 

standards for mobile sources, adopts standards and suggested control measures for toxic air 

contaminants, provides technical support to the districts, oversees district compliance, 

approves local air quality plans, and prepares and submits the SIP to USEPA. USEPA establishes 

NAAQS, sets emission standards for certain mobile sources (airplanes and locomotives), 

oversees the state air programs, and reviews and approves the SIP. CARB inventories sources of 

air pollution in California’s air basins and is required to update the inventory triennially, starting 

in 1998.27 CARB also identifies air basins that are affected by transported air pollution.28 

4.1.2.1. California Climate Change Policy 

The State of California considers GHG emissions and the impacts of climate change to be a 

serious threat to the public health, environment, economic well-being, and natural resources of 

California, and has taken an aggressive stance to mitigate the State’s impact on climate change 

through the adoption of policies and legislation. CARB is responsible for the coordination and 

oversight of State and local air pollution control programs in California. California has numerous 

regulations aimed at reducing the State’s GHG emissions. Some of the major initiatives are 

summarized below. 

26 Health and Safety Code §3900 et seq. 

27 Health and Safety Code §39607 and 3607.3. 

28 Health and Safety Code §38500 et seq. 

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Executive Order S-3-05 

In 2005, Governor Schwarzenegger issued EO S-3-05, which identifies Statewide GHG emission 

reduction targets to achieve long-term climate stabilization as follows: 

• Reduce GHG emissions to 1990 levels by 2020; and 

• Reduce GHG emissions to 80 percent below 1990 levels by 2050. 

In response to EO S-3-05, California Environmental Protection Agency (CalEPA) created the 

Climate Action Team (CAT), which in March 2006 published the Climate Action Team Report 

(the “2006 CAT Report”).29 The 2006 CAT Report identified a recommended list of strategies 

that the State could pursue to reduce GHG emissions. These are strategies that could be 

implemented by various State agencies to ensure that the emission reduction targets in 

EO S­3­05 are met and can be met with existing authority of the State agencies. The strategies 

include, but are not limited to, the reduction of passenger and light-duty truck emissions, the 

reduction of idling times for diesel trucks, an overhaul of shipping technology/infrastructure, 

increased use of alternative fuels, increased recycling, and landfill CH4 capture. 

Assembly Bill 32 (AB 32) 

Assembly Bill (AB) 32,30 the California Global Warming Solutions Act of 2006, was enacted after 

considerable study and expert testimony before the Legislature. The heart of AB 32 is the 

requirement that statewide GHG emissions be reduced to 1990 levels by 2020. To achieve this 

reduction mandate, AB 32 requires California Air Resources Board to adopt rules and 

regulations in an open public process that achieve the maximum technologically feasible and 

cost-effective GHG reductions. 

In 2007, CARB approved a statewide limit on the GHG emissions level for year 2020 consistent 

with the determined 1990 baseline. CARB’s adoption of this limit is in accordance with Health & 

Safety Code Section 38550, as codified through enactment of AB 32. 

Per Health & Safety Code Section 38561(b), CARB also is required to prepare, approve and 

amend a scoping plan that identifies and makes recommendations on “direct emission 

reduction measures, alternative compliance mechanisms, market-based compliance 

mechanisms, and potential monetary and nonmonetary incentives for sources and categories of 

sources that [CARB] finds are necessary or desirable to facilitate the achievement of the 

maximum feasible and cost-effective reductions of GHG emissions by 2020.”31 

In 2008, CARB adopted the Climate Change Scoping Plan: A Framework for Change (2008 

Scoping Plan) in accordance with Health & Safety Code Section 38561. During the development 

of the 2008 Scoping Plan, CARB created a planning framework that is comprised of eight 

emissions sectors: (1) transportation; (2) electricity; (3) commercial and residential; (4) industry; 

(5) recycling and waste; (6) high GWP gases; (7) agriculture; and (8) forest net emissions. The 

2008 Scoping Plan established an overall framework for the measures that will be adopted to 

reduce California’s GHG emissions from the eight emissions sectors to 1990 levels by 2020.32 

29 California Environmental Protection Agency (CalEPA), 2006. Climate Action Team Report to Governor Schwarzenegger and the Legislature. 

30 Assembly bill (AB) 32. 2006. 

31 Health & Safety Code Section §38561(b). 

32 California Air Resources Board (CARB). 2008. Climate Change Scoping Plan: A Framework for Change (December 2008). 

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In the 2011 Final Supplement to the AB 32 Scoping Plan Functional Equivalent Document (2011 

Final Supplement), CARB revised its estimates of the projected 2020 emissions level in light of 

the economic recession and the availability of updated information about GHG reduction 

regulations. 

In 2014, CARB adopted the First Update to the Climate Change Scoping Plan: Building on the 

Framework (2014 First Update).33 The stated purpose of the 2014 First Update is to “highlight

[...] California’s success to date in reducing its GHG emissions and lay [...] the foundation for

establishing a broad framework for continued emission reductions beyond 2020, on the path to 

80 percent below 1990 levels by 2050.”34 The 2014 First Update found that California is on track 

to meet the 2020 emissions reduction mandate established by AB 32, and noted that California 

could reduce emissions further by 2030 to levels squarely in line with those needed to stay on 

track to reduce emissions to 80 percent below 1990 levels by 2050 if the State realizes the 

expected benefits of existing policy goals.35 The 2014 Update also identified key recommended 

actions in the following sectors that would facilitate achievement of the 2050 reduction target: 

(1) energy; (2) transportation (vehicles/equipment, sustainable communities, housing, fuels, 

and infrastructure); (3) agriculture; (4) water; (5) waste management; and (6) natural and 

working lands. 

In November 2017, CARB published California’s 2017 Climate Change Scoping Plan (2017

Scoping Plan), which was subsequently adopted by CARB’s Board in December 2017.36 The 2017 

Scoping Plan identifies CARB’s strategy for achieving the State’s 2030 GHG target as established

in Senate Bill (SB) 32 (discussed below). The strategy includes continuation of the Cap-andTrade Program through 2030 and incorporates a Mobile Source Strategy that includes 

strategies targeted to increase zero emission vehicle fleet penetration and a more stringent 

target for the Low Carbon Fuel Standard by 2030. The 2017 Scoping Plan also incorporates 

approaches to cutting short-lived climate pollutants (SLCPs) under the Short-Lived Climate 

Pollutant Reduction Strategy (a planning document that was adopted by CARB in March 2017) 

and acknowledges the need for reducing emissions in agriculture and highlights the work 

underway to ensure that California’s natural and working lands increasingly sequester carbon. 

The 2022 Scoping Plan Update will assess progress towards achieving the Senate Bill 32 2030 

target and lay out a path to achieve carbon neutrality no later than 2045. As of January 2022, 

this plan update has not yet been finalized, but there have been numerous workshops held 

pertaining to scenario inputs, building decarbonization, natural and working lands scenarios, 

the electricity sector, short lived climate pollutants, and engineered carbon removal. The plan is 

expected to be considered by the Board in late 2022. 

Senate Bill 605 – Short-Lived Climate Pollutants 

Short-lived climate pollutants (i.e., black carbon, fluorinated gases, and CH4) are powerful 

climate forcers that remain in the atmosphere for a much shorter period of time than longerlived climate pollutants. Their relative potency, when measured in terms of how they heat the 

atmosphere, can be tens, hundreds, or even thousands of times greater than that of CO2. The 

33 Health & Safety Code Section 38561(h) requires CARB to update the Scoping Plan every five years. 

34 CARB, 2014. First Update to the Climate Change Scoping Plan: Building on the Framework 

35 Ibid. 

36 CARB. 2017a. California’s 2017 Climate Change Scoping Plan. 

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impacts of short-lived climate pollutants are especially strong over the short term. Reducing 

these emissions can make an immediate beneficial impact on climate change.37 Governor 

Brown signed SB 605 on September 21, 2014, which directed CARB to develop a Short-Lived 

Climate Pollutant Strategy by January 1, 2016. In September 2015, CARB released a draft of 

their Short-Lived Climate Pollutant Strategy. Several updates to the draft were made since 

September 2015, with the most current version dated March 2017. The Strategy aims for a 

40 percent reduction in CH4 and HFC emissions below 2013 levels by 2030 and a 50 percent 

reduction in anthropogenic emissions of black carbon below 2013 levels by 2030.38 

Cap-and-Trade Program 

California’s Cap-and-Trade Program regulates the emissions of large electric power plants, large 

industrial plants, and fuel distributors (including transportation fuel and natural gas). These 

sources are responsible for about 85 percent of the State’s total GHG emissions inventory.39,40 

In the Cap-and-Trade Program, the State regulates the quantity of emissions by determining, in 

advance, how many allowances to issue—i.e., setting the “cap.” Each allowance is essentially a

permit issued by the State authorizing a certain quantity of GHG emissions. There are only a 

finite number of allowances, ensuring that covered entities may only lawfully emit a certain 

quantity of GHGs. If a covered entity wishes to emit carbon, it must obtain allowances to 

authorize those emissions. 

Importantly, the Cap-and-Trade Program has been designed to provide a firm cap, ensuring that 

the 2020 statewide emissions limit identified by CARB in the 2008 Scoping Plan will not be 

exceeded.41 Thus, for the emission sources covered by the Program, which are nearly all of the 

sources associated with land use development projects, compliance with AB 32’s 2020 mandate 

is assured by the Cap-and-Trade Program. 

AB 398 extended the statutorily-defined horizon year of the Cap-and-Trade Program to 

December 31, 2030, thereby facilitating continued reliance on the Cap-and-Trade Program for 

purposes of achieving SB 32’s 2030 statewide reduction target.42 

Executive Order B-30-15 and Senate Bill 32 

In April 2015, Governor Brown signed EO B-30-15, which established the following GHG 

emission reduction goal for California: by 2030, reduce GHG emissions to 40 percent below 

1990 levels.43 This EO also directed all state agencies with jurisdiction over GHG-emitting 

sources to implement measures designed to achieve the new interim 2030 goal, as well as the 

pre-existing, long-term 2050 goal identified in EO S-3-05 (see discussion above). Additionally, 

the EO directed CARB to update its Scoping Plan (see discussion above) to address the 2030 

goal. 

37 CARB. 2016. Reducing Short-Lived Climate Pollutants in California. 

38 CARB. 2017b. Short-Lived Climate Pollutant Reduction Strategy. 

39 California Code of Regulations. 2015. Article 5. California Cap on Greenhouse Gas Emissions and Market-Based Compliance Mechanisms. 

40 CARB, 2015. Overview of CARB Emissions Trading Program. 

41 CARB, 2008. Climate Change Scoping Plan: A Framework for Change 

42 Assembly Bill 398. 2017. 

43 Office of the Governor Edmund G. Brown Jr. 2015. Governor Brown Establishes Most Ambitious Greenhouse Gas Reduction Target in North 

America. 

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Enacted in 2016, SB 32 codifies the 2030 emissions reduction goal of EO B­30-15 by requiring 

CARB to ensure that statewide GHG emissions are reduced to 40 percent below 1990 levels by 

2030.44 

Executive Order B-55-18 

In September 2018, Governor Brown signed EO B-55-18, which established a new statewide 

goal “to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and

maintain net negative emissions thereafter.” This EO directs CARB to “work with relevant state

agencies to ensure future Scoping Plans identify and recommend measures to achieve the 

carbon neutrality goal.”

In January 2019, CARB kicked off workshops regarding carbon neutrality in California,45 during 

which CARB staff explained that the definitional parameters and meaning of the term – carbon 

neutrality – are still being explored. CARB held additional workshops throughout 2019 and 2020 

to explore specific topics related to the pursuit of carbon neutrality, engage with other experts 

in the field and stakeholders, and conduct research to ensure that any path to carbon neutrality 

balances scientific, economic, and social justice principles. 

Energy Sources 

Renewable Portfolio Standard 

As most recently amended by SB 100,46 California’s Renewables Portfolio Standard requires 

retail sellers of electric services and local publicly-owned electric utilities to increase 

procurement from eligible renewable energy resources to 50 percent of total retail sales by 

2026, and 60 percent of total retail sales by 2030. SB 100 also established a state policy goal to 

achieve 100 percent renewables by 2045. 

In March 2021, the California Energy Commission (CEC), California Public Utilities Commission 

(CPUC), and CARB released a joint-agency report evaluating the current feasibility of achieving 

the energy resource and GHG reductions goals of SB 100. The report finds that SB 100 is 

technically feasible when analyzed under scenarios of varying timelines, advancements in 

energy generation technology, and energy source portfolios. Under the SB 100 Core Scenario, it 

is anticipated that California will need to triple its current electricity power capacity.47 

Building Energy Efficiency Standards 

Title 24, Part 6 of the California Code of Regulations regulates the design of building shells and 

building components. The standards are updated periodically to allow for consideration and 

possible incorporation of new energy efficiency technologies and methods. 

The CEC’s 2019 Building Energy Efficiency Standards (2019 Building Standards), which became 

effective January 1, 2020, are the currently applicable version of these standards. In general, 

single-family homes built to the 2019 standards are anticipated to use about 7% less energy 

due to energy efficiency measures than those built to the 2016 standards, and nonresidential 

44 State Bill 32. 2016. 

45 CARB. 2019. Carbon Neutrality in California Context Webinar. 

46 Senate Bill 100. 2018. 

47 CEC. 2021. 2021 SB 100 Joint Agency Report, Achieving 100 Percent Clean Electricity in California: An Initial Assessment. 

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buildings built to the 2019 standards will use an estimated 30% less energy than those built to 

the 2016 standards.48 

In addition to the CEC’s efforts, in 2008, the California Building Standards Commission adopted 

the nation’s first green building standards. The California Green Building Standards Code (Part

11 of Title 24) is commonly referred to as CalGreen Building Standard (CalGreen), and 

establishes voluntary and mandatory standards pertaining to the planning and design of 

sustainable site development, energy efficiency, water conservation, material conservation, 

and interior air quality. Like Part 6 of Title 24, the CalGreen standards are periodically updated, 

with increasing energy savings and efficiencies associated with each code update. 

Mobile Sources 

Sustainable Communities Strategy Plans 

SB 375,

49 the Sustainable Communities and Climate Protection Act, coordinates land use 

planning, regional transportation plans (RTP), and funding priorities to reduce GHG emissions 

from passenger vehicles through better-integrated regional transportation, land use, and 

housing planning that provides easier access to jobs, services, public transit, and active 

transportation options. SB 375 specifically requires the Metropolitan Planning Organization 

relevant to the Project area (here, the Southern California Association of Governments [SCAG] 

and San Bernardino County Transportation Authority [SBCTA]) to include a Sustainable 

Communities Strategy in its RTP that, if implemented, will achieve GHG emission reduction 

targets set by CARB by reducing VMT from light-duty vehicles through the development of 

more compact, complete, and efficient communities. 

Senate Bill 743 

Public Resources Code Section 21099(c)(1), as codified through enactment of SB 743,50 

authorized the Office of Planning and Research (OPR) to establish “alternative metrics to the

metrics used for traffic levels of service for transportation impacts outside transit priority 

areas.” SB 743 reflects a legislative policy to balance the needs of congestion management with 

statewide goals related to infill development, promotion of public health through active 

transportation, and reduction of GHG emissions. As finalized in December 2018, amendments 

to the State California Environmental Quality Act (CEQA) Guidelines adopted in furtherance of 

SB 743 establish VMT, in lieu of level of service (LOS), as the new metric for transportation 

analysis. 

Pavley Regulations 

AB 1493 required CARB to adopt regulations to reduce GHG emissions from non-commercial 

passenger vehicles and light-duty trucks for model years 2009–2016. CARB obtained a waiver 

from the USEPA that allows for implementation of these regulations notwithstanding possible 

federal pre-emption concerns.51 

Low Carbon Fuel Standard 

48 CEC. 2018. 2019 Building Energy Efficiency Standards – Frequently Asked Questions. 

49 Senate Bill (SB) 375. 2008. 

50 SB 743, 2013. 

51 AB 1493. 2002. 

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EO S-1-07, as issued by Governor Schwarzenegger, called for a 10 percent or greater reduction 

in the average fuel carbon intensity for transportation fuels in California regulated by CARB by 

2020. In response, CARB approved the Low Carbon Fuel Standard (LCFS) regulations in 2009, 

which became fully effective in April 2010. Thereafter, a lawsuit was filed challenging CARB’s 

adoption of the regulations; and, in 2013, a court order was issued compelling CARB to remedy 

substantive and procedural defects of the LCFS adoption process under CEQA. However, the 

court allowed implementation of the LCFS to continue pending correction of the identified 

defects. In September 2015, CARB re-adopted the LCFS regulations. The LCFS would reduce 

GHG emissions by reducing the carbon intensity of transportation fuels used in California by at 

least 10% by 2020 and, as amended in 2018, by at least 20% by 2030. 

Advanced Clean Cars Program 

In 2012, CARB approved the Advanced Clean Cars (ACC) program, a new emissions-control 

program for non-commercial passenger vehicles and light-duty truck for model years 2017-

2025. The program combines the control of smog, soot, and GHGs with requirements for 

greater numbers of zero emission vehicles. By 2025, when the rules will be fully implemented, 

new automobiles will emit 34 percent fewer global warming gases and 75 percent fewer smogforming emissions. At the time of this writing, CARB has developed draft Advanced Clean Cars II 

(ACC II) regulations which “will seek to reduce criteria and GHG emissions from new light- and 

medium-duty vehicles beyond the 2025 model year and increase the number of ZEVs for 

sale”.52 The regulations are expected to be presented to the Board in June 2022. 

Zero Emission Vehicles Program 

ZEVs include hydrogen fuel cell electric vehicles and plug-in electric vehicles, such as battery 

electric vehicles and plug-in hybrid electric vehicles. 

In 2012, Governor Brown issued EO B-16-2012, which calls for the increased penetration of 

ZEVs into California’s vehicle fleet in order to help California achieve a reduction of GHG 

emissions from the transportation sector equaling 80 percent less than 1990 levels by 2050. In 

furtherance of that statewide target for the transportation sector, the EO also calls upon CARB, 

the CEC and the California Public Utilities Commission to establish benchmarks that will: 

(1) allow over 1.5 million ZEVs to be on California roadways by 2025, and (2) provide the State’s 

residents with easy access to ZEV infrastructure. EO B-16-2012 specifically directed California to 

“encourage the development and success of zero-emission vehicles to protect the 

environment, stimulate economic growth, and improve the quality of life in the State.”53 

In 2018, Governor Brown also issued EO B-48-18, which launched an eight-year initiative to 

accelerate the sales of ZEVs through a mix of rebate programs and infrastructure 

improvements. The EO also sets a new target of five million ZEVs in California by 2030 and 

includes funding for multiple state agencies to increase electric vehicle (EV) charging 

infrastructure and provide purchase rebates/incentives. 

In June 2020, CARB approved the Advanced Clean Trucks regulation, which has requirements 

for manufacturer ZEV sales.54 The Advanced Clean Truck Regulation is part of a holistic 

52 CARB. 2021a. Advanced Clean Cars II Program. 

53 State of California. Executive Order B-16-2012. 

54 CARB. 2020. Advanced Clean Trucks. 

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approach to accelerate a large-scale transition of zero-emission medium-and heavy-duty 

vehicles from Class 2b to Class 8. Manufacturers who certify Class 2b-8 chassis or complete 

vehicles with combustion engines are required to sell zero-emission trucks as an increasing 

percentage of their annual California sales from 2024 to 2035. By 2035, zero-emission 

truck/chassis sales need to be 55% of Class 2b – 3 truck sales, 75% of Class 4 – 8 straight truck 

sales, and 40% of truck tractor sales. 

On September 23, 2020, California Governor Gavin Newsom issued Executive Order N­79­20, 

which entails the following actions: 

• All new passenger vehicles sold in California be zero-emission by 2035 

• All medium- and heavy-duty vehicles be zero-emission where feasible by 2045 

• All off-road vehicles and equipment be zero-emission where feasible by 2035 

Governor Newsom ordered extensive inter-agency efforts to support the Executive Order, 

including evaluations of technological feasibility and cost effectiveness, expansion of EV 

charging options and affordable fueling, as well as identification of near-term strategies to 

increase zero-emission public transportation options. 

The Executive Order was generally aimed at transitioning away from fossil fuel dependence in 

the State, with emphasis on transportation initiatives. However, Governor Newsom addressed 

efforts to repurpose oil production facilities and extraction sites while continuing the State’s 

existing goals to reduce the carbon intensity of fuels.55 

4.1.3. National and State Ambient Air Quality Standards 

As required by the Clean Air Act Amendments of 197056 and the Clean Air Act Amendment of 

1977,57 USEPA has established NAAQS for the following air pollutants: CO, ozone (O3), nitrogen 

dioxide (NO2), particulate matter (PM10 and PM2.5), oxides of sulfur (SOX), and lead. CARB has 

also established standards for these pollutants for California.58 The federal and state (California) 

governments have both adopted health-based standards for pollutants. For some pollutants, 

the national and state standards are very similar; for other pollutants, the California state 

standards are more stringent. The differences in the standards are generally the result of the 

different health effect studies considered during the standard-setting process and how these 

studies were interpreted. Per the CAA, the USEPA periodically (every five years) reviews the 

science upon which the NAAQS are based and if needed undertakes a process for revising the 

standards.59 

Table 2-1 lists the federal (NAAQS) and California (CAAQS) standards. The federal primary 

standards are intended to protect the public health with an adequate margin of safety. The 

federal secondary standards are intended to protect the nation’s welfare and account for air

pollutant impacts on soil, water, visibility, vegetation, and other aspects of the general welfare. 

55 State of California. 2020. Executive Order N-79-20. 

56 PL 91-064.1970 

57 PL 95-95.1977. 

58 CARB. n.d. California Ambient Air Quality Standards. 

59 USEPA. n.d. Process of Reviewing the National Ambient Air Quality Standards. 

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Areas that violate these standards are designated nonattainment areas. Areas that once 

violated the standards but now meet the standards are classified as maintenance areas. 

Classification of each area under the federal standards is done by USEPA based on state 

recommendations and after an extensive review of monitored data. 

4.1.4. Urban Air Toxics 

In addition to NAAQS for criteria pollutants, the CAA has established a list of 188 hazardous air 

pollutants (HAPs) or air toxics.60,61 Most air toxics originate from human-generated sources, 

including road mobile sources (e.g., cars, trucks, buses), non-road mobile sources 

(e.g., airplanes, locomotives), stationary sources (e.g., factories, refineries, power plants) and 

indoor sources (e.g., building materials). Some are also released from natural sources such as 

volcanic eruptions and forest fires. Air toxics are referred to as TACs by CARB. Human health 

risks caused by exposure to air toxics at sufficiently high concentrations or extended durations 

include increased risk for cancer or other serious health effects, including damage to the 

immune system; and neurological, reproductive, developmental and respiratory problems. To 

address HAPs in urban areas, section 112(k) of the Clean Air Act directs USEPA to identify a 

subset of 30 HAPs that present the greatest threat to public health in the largest number of 

urban areas. These 30 HAPs are known as the 30 urban air toxics62. 

In February 2007, USEPA identified a group of twenty-one compounds as mobile-source air 

toxics (MSAT) from the abovementioned list of 188 HAPs in its Control of Emissions of 

Hazardous Air Pollutants from Mobile Sources rule.63 From this list of 21 MSATs, USEPA 

identified the following nine MSATs that are among the regional-scale contributors to cancer 

risk and non-cancer hazard in its 2011 National Air Toxics Assessment:64 1,3-

butadiene,acetaldehyde, acrolein, benzene, diesel particulate matter (diesel PM), 

ethylbenzene, formaldehyde, naphthalene, and polycyclic organic matter. The FHWA considers 

these nine compounds as priority MSATs.65 

To address emissions of MSATs, USEPA has issued a number of regulations that are intended to 

significantly decrease MSATs through cleaner fuels and cleaner engines. These include the 

following national mobile source control programs: 

• The reformulated gasoline program66; 

• A new threshold for the toxic content of gasoline67; 

• The national low-emission vehicle standards68; 

60 USEPA. 1990. Clean Air Act Amendment Summary: Title III Air Toxics. 

61 USEPA. n.d. Initial List of Hazardous Air Pollutants with Modifications. 

62 USEPA. n.d. Urban Air Toxic Pollutants. 

63 Federal Register. 2001. Control of Emissions of Hazardous Air Pollutants from Mobile Sources. 

64 USEPA. 2011. NATA: Assessment Results. 

65 FHWA. 2016. Updated Interim Guidance on Mobile Source Air Toxics Analysis in NEPA Documents. 

66 USEPA. n.d. Gasoline Standards – Reformulated Gasoline. 

67 USEPA, n.d. Regulations to Reduce Mobile Source Pollutions. 

68 USEPA, n.d. USEPA Emission Standards for Light-Duty Vehicles and Trucks and Motorcycles. 

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• The Tier 2 motor vehicle emissions standards and gasoline sulfur control 

requirements69; 

• The Tier 3 motor vehicle emission and fuel standards70; 

• The heavy-duty engine and vehicle standards and on-highway diesel fuel sulfur control 

requirements71; and 

• Voluntary programs such as Clean Diesel, Clean School Bus USA, Ports Initiative, and 

SmartWay. 72 

The USEPA has not yet released guidance on how to evaluate the effect of future rail lines on 

ambient concentrations of urban air toxics in the context of the National Environmental Policy 

Act (NEPA). Furthermore, no Federal or California ambient standards exist for mobile source air 

toxics. Tools that can determine the significance of localized concentrations on health, or of 

increases or decreases in emissions are lacking. Specifically, USEPA has not established NAAQS 

or provided other project-level standards for HAPs. 

4.2. Scope of the Air Quality and Greenhouse Gas Assessment 

The technical assessments to be performed for Air Quality (AQ) and GHG evaluation can be 

categorized as follows: 

• Quantification of emissions of criteria air pollutants and GHG during construction 

• Analysis to show that the potential net emissions of CAPs and TACs resulting from the 

Project’s operational activities would be lower than the No Build Alternative 

• Analysis to show that the potential cumulative net emissions of GHGs resulting from the 

Project’s operational activities would be lower than the No Build Alternative 

• General Conformity Determination comparing annual Project emissions to SCAQMD and 

MDAQMD de minimis emissions thresholds for their respective ozone and PM2.5 nonattainment designations73 

• CO Hotspot Analysis using CO hotspot screening analysis. 

Information on the planned approaches for these analyses are presented in Section 5. 

4.3. Pollutants of Potential Concern 

The pollutants of potential concern are criteria pollutants (including, but not limited to, ozone 

and small airborne particulate matter and their precursors74 and greenhouse gases. The 

following list describes these pollutants of potential concern and their precursors: 

• Particulate matter less than 2.5 microns and particulate matter less than 10 microns 

69 USEPA, 2000, Tier 2 Motor Vehicle Emission Standards and Gasoline Sulfur Control Requirements: Response to Comments. 

70 USEPA, 2014. Final Rule for Control of Air Pollution from Motor Vehicles: Tier 3 Motor Vehicle Emission and Fuel Standards. 

71 USEPA, 2000. 

72 USEPA. n.d. Voluntary Programs to Reduce Mobile Source Pollution. 

73 USEPA. 2022. California Nonattainment/Maintenance Status for Each County by Year for All Criteria Pollutants. 

74 Precursors interact in the atmosphere under specific conditions to form secondary criteria pollutants such as ozone and aerosol PM2.5/PM10. 

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• Ozone 

• Carbon Monoxide 

• Sulfur dioxide (SO2) (in addition to being a primary pollutant, this is also a precursor of 

PM2.5 and PM10) 

• Nitrogen dioxide 

• Oxides of nitrogen (NOx) (precursor of ozone, PM2.5, and PM10) 

• Volatile organic compounds (VOCs) (precursor of ozone, PM2.5, and PM10) 

• GHGs: CO2, CH4, and NOx 

4.4. Study Area 

The Project would be located within two air quality district jurisdictions: the MDAQMD and the 

SCAQMD in California. This analysis will be structured to estimate the potential impacts on the 

two air basins directly affected by the Build Alternative. The rail alignment for the Build 

Alternative is described in further detail in Section 3.2 Build Alternative.75

4.5. Assessments Performed 

The technical assessments performed for AQ evaluation were as follows: 

• Quantifications of emissions for criteria pollutants and GHGs during construction under 

the Build Alternative 

• Analysis to show that the potential net emissions of CAPs and TACs resulting from the 

Project’s operational activities under the Build Alternative are lower than the No Build 

Alternative 

• Analysis to show that the potential cumulative net emissions of GHGs resulting from the 

Project’s operational activities under the Build Alternative are lower than the No Build 

Alternative 

• General Conformity Determination comparing emissions to appropriate SCAQMD and 

MDAQMD de minimis emissions thresholds for ozone and PM2.5 (and precursors) 

• CO Hotspot Analysis using CO hotspot screening analysis 

Table 5-1 summarizes the technical analysis performed, including what activities, sources, and 

pollutants were assessed, as well as what assessments were performed for each group of 

pollutants. 

75 Since this report was prepared, the Project alignment has been refined such that the northern portion of the Project would run entirely 

within the I-15 median. This change was considered but determined not to affect the results of the air quality modeling. 

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4.6. Methods Used 

4.6.1. Quantification of Construction Emissions 

Emissions quantification forms the basis for all air quality and GHG assessments. This section 

provides a description of the methodology for estimating criteria air pollutant and GHG 

emissions from Project construction. 

The primary sources of construction-related criteria air pollutant emissions are off-road 

construction equipment, fugitive dust from material movement, construction-related truck 

trips, vendor vehicles, and worker commute vehicles. Emissions of CAPs and GHGs associated 

with each of these activities during all phases of construction were estimated. 

To estimate the Project related air emissions emission estimation software was used. Details of 

the methodology used for construction emissions estimates are discussed in the following 

sub­sections. 

4.6.1.1. Criteria Air Pollutant Emissions 

The criteria pollutants and precursors that were evaluated in this analysis include NOX, CO, SO2, 

PM10, PM2.5, and VOCs. Since there are no large sources of lead (Pb) emissions associated with 

the construction of the Project, lead emissions were not evaluated. 

Quantification of emissions from construction can be broadly divided in three steps: 

• Step 1: Compiling the following construction activity data:

– a construction schedule which may establish different phases of construction

– number, type, and hours of operations of off-road construction equipment used in

each construction phase

– acreage disturbed and quantity of material handled (tons or cubic yards) during each

construction phase

– the number of construction-related truck trips, vendor deliveries, and worker

commute trips associated with each construction phase

– area (square feet) of surfaces with architectural coatings applied

• Step 2: Estimating emission factors for the various off-road construction equipment,

material handling activities, and on-road construction-related vehicles. California

Emissions Estimator Model (CalEEMod®) Version 2020.4.0 (hereafter referred to as

“CalEEMod ”) was used for estimating construction emissions. CalEEMod® is a statewide

program tool designed to calculate both criteria pollutant and GHG emissions from

development projects in California. The default emission factors in CalEEMod® are from

sources including USEPA AP-42 emission factors, CARB’s on-road and off-road

equipment emission models such as the Emission FACtor model (EMFAC) and the

Emissions Inventory Program model (OFFROAD), and studies commissioned by California

agencies such as the CEC and CalRecycle. The current version of CalEEMod uses

emission factors from EMFAC2017 and OFFROAD2011. A newer version of EMFAC,

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BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL 

EMFAC2021,76 was released in January 2021, but it has not yet been approved by 

USEPA. A newer version of the OFFROAD model77 has been released, however, as noted 

below, the Project is committing to Tier 4 Final construction equipment, so USEPA 

emission factors for Tier 4 equipment were selected in CalEEMod directly. 

• Step 3: Inputting the construction activity assumptions (from Step 1) and the emission 

factors (from Step 2) into an emissions model to generate emission estimates for each 

construction phase. As noted under Step 2, CalEEMod® was used for this purpose. 

Details of the model are discussed below. 

CalEEMod® splits construction activities into on-road, off-road, and fugitive dust emissions. 

Listed below are the construction activity-related inputs accepted by CalEEMod®: 

• Construction start date. 

• Construction schedule (including start/end dates for each phase). 

• Construction off-road equipment by phase (including number of pieces of each 

equipment, hours/day, horsepower, and load factor). 

• Construction material import/export quantities (tons of debris or cubic yards). 

• Estimated number of acres disturbed per day. 

• Demolition material (building square footage or tons of debris). 

• Estimated worker, vendor, and hauling trip counts and lengths (miles). 

• Areas for architectural coating and VOC content of coatings (g/L). 

As shown in Figure 4-1, the Project construction is expected to occur in seven construction 

segments spanning two air basins (SCAB and MDAB). These include: 

• Segment 1 – Apple Valley to Mojave River (MDAB) 

• Segment 2 – Mojave River to Bear Valley Road (MDAB) 

• Segment 3 – Bear Valley Road to Oak Hill (MDAB) 

• Segment 4 – Oak Hill to Kenwood (MDAB and SCAB) 

• Segment 5 – Kenwood to Glen Helen Pkwy (SCAB) 

• Segment 6 – Glen Helen Pkwy to Baseline (SCAB) 

• Segment 7 – Baseline to Rancho Cucamonga (SCAB) 

A separate CalEEMod® model run was performed to estimate the construction related 

emissions from each construction segment. The following project-specific construction activityrelated inputs were used to override the default assumptions in the CalEEMod® model runs: 

• construction schedule78 as detailed in Table 5-2, 

76 CARB. 2021b. EMFAC2021. 

77 CARB. n.d. Off-Road Emissions. 

78 The Project construction is based on the construction schedule dated November 3, 2021. 

AIR QUALITY TECHNICAL REPORT, OCTOBER 2022 29 
 

 

 

 

• construction equipment mix and activity presented in Table 5-3, 

• material movement volumes shown in Table 5-4, 

• demolition material quantities summarized in Table 5-5, 

• worker, vendor, and hauling trips activity data provided in Table 5-6, and 

• construction mitigation measures described below. 

30 AIR QUALITY AND GREENHOUSE GAS TECHNICAL REPORT, OCTOBER 2022 
31 

BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL 

Figure 4-1 Limit of Disturbance 

DRAFT AIR QUALITY TECHNICAL REPORT, AUGUST 2022 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

VOC emissions associated with paving activities and the use of architectural coatings during the 

construction of parking areas in the vicinity of the passenger stations located in Construction 

Segments 3 and 7 were estimated outside the CalEEMod® model runs. A brief description of the 

methodologies used for these emission estimates are provided. 

The annual CAP mass emissions from construction activities for the Project were estimated 

using the CalEEMod® output data (Appendix A) and performed additional calculations for VOC 

emissions from paving activities (Table B-1 in Appendix B) and architectural coatings (Table B-2 

in Appendix B). For a high-level summary of CalEEMod outputs, refer to Appendix B. 

Construction Mitigation Measures 

The Project is committed to using Tier 4 construction equipment. As such, EPA emission factors 

for Tier 4 equipment was incorporated into the CalEEMod model. The following mitigation 

measures were incorporated into the Project air quality analysis: 

• Mitigation Measure 1: Fugitive Dust Control Plan during Construction to Meet 

MDAQMD Rule 40379 Requirements. 

– Consistent with the MDAQMD Rule 403 (Fugitive Dust Control), the following control 

measures shall be implemented: 

▪ Use periodic watering (two times daily) for short-term stabilization of disturbed 

surface area to minimize visible fugitive dust emissions. Use of a water truck to 

maintain moist disturbed surfaces and actively spread water during visible 

dusting episodes shall be considered sufficient to maintain compliance. 

▪ Take actions sufficient to prevent Project-related trackout onto paved surfaces. 

Actions may include the use of: 

o Gravel or aggregate vehicle tracking pads at temporary site entrances and 

exits 

o Wash racks that use pressurized water to clean tires as they pass through. 

Wash racks introduce water to the trackout control system which must be 

contained within the jobsite. 

o Rumble plates, rumble strips, cattle guards that use vibration to shake off 

debris from vehicle tires. 

▪ Cover loaded haul vehicles while operating on publicly maintained paved 

surfaces. 

▪ Stabilize graded site surfaces upon completion of grading when subsequent 

development is delayed or expected to be delayed more than 30 days, except 

when such a delay is due to precipitation that dampens the disturbed surface 

sufficiently to eliminate visible fugitive dust emissions. 

AIR QUALITY AND GREENHOUSE GAS TECHNICAL REPORT, OCTOBER 2022 

79 MDAQMD. 2020. 

32 


 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL 

estimates GHG emissions using emission factors from EMFAC and OFFROAD to estimate 

emissions. The methodology used to estimate these emissions is described in Section 4.6.1.1. 

Refer to Appendix A, and Table B-3 and Table B-4 in Appendix B for CalEEMod® output data and 

post-processing details. 

4.6.2. Operational Emission Evaluation 

The operational emissions evaluation includes the following: 

• Operational CAP and TAC emissions from the electric-powered rail line would be near 

zero. On-road VMT under the No Build and Build Alternatives were compared in the 

traffic analysis prepared for the Project. The reduction in VMT caused by the Project 

would result in a net decrease in emissions of all CAP and TAC pollutants. 

• The predominant source of GHG emissions during Project operation are emissions 

associated with electricity production (provided by SCE) used to power the rail line. 

These GHG emissions were estimated using the projected electricity use (in Megawatt 

hours, or MWh) and electricity carbon intensity factors estimated from data published 

in SCE sustainability reports (Table 5-7). The reductions in the on-road VMT result in 

reductions in GHG emissions. Therefore, the net GHG impacts were estimated as a 

difference in the GHGs associated with electricity and reductions from on-road VMT. 

GHG emission factors for passenger cars were derived based on EMFAC2017 output for 

San Bernardino - South Coast and San Bernardino - Mojave Desert in 2025, the first year 

of full Project operation, and 2045, the Project horizon year. These emission factors are 

presented in Table 5-8. 

4.6.3. General Conformity De Minimis Comparison 

The General Conformity regulations dictate the process federal agencies use to demonstrate 

that their actions will not interfere with a state or tribe’s plans to attain and maintain NAAQS. 

In accordance with General Conformity regulations, the maximum annual Project potential 

emissions were compared against de minimis thresholds for each air basin (the South Coast Air 

Basin and the Mojave Desert Air Basin) and each nonattainment pollutant of interest (Table 5-

9).

81 

4.6.4. Localized Carbon Monoxide Impacts 

Mobile-source impacts occur on two basic scales of motion. Locally, proposed Project traffic will 

be added to the City’s roadway system. There is a potential for the formation of microscale CO 

“hotspots” in the area immediately around points of congested traffic. 

Projects contributing to adverse traffic impacts may result in the formation of CO hotspots. To 

verify that the proposed Project would not cause or contribute to a violation of the CO 

standard, a screening evaluation of the potential for CO hotspots was conducted. The Project 

Transportation Impact Analysis included an evaluation of the LOS (i.e., increased congestion) 

impacts at intersections affected by the Project. The Project includes eleven intersections that 

81 USEPA. 2021. General Conformity. 

AIR QUALITY TECHNICAL REPORT, OCTOBER 2022 35 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

are classified as LOS D, E, or F in the Project opening year (2025) and/or the horizon year (2045) 

and, as such, require a CO hot-spot analysis. 

The California Line Source Dispersion Model (CALINE4) procedure developed by the Bay Area 

Air Quality Management District (BAAQMD)82 was used to calculate 1-hour and 8-hour localized 

CO concentrations for the eleven identified intersections. The BAAQMD methodology assumes 

worst-case meteorological conditions and provides a screening tool to identify if further 

analysis is required. The inputs to this simplified CALINE4 procedure include background CO 

concentrations in the vicinity of the intersection, AM and PM peak hour traffic volumes at the 

intersections, and CO emission factors for vehicles at the intersection. Traffic volumes from the 

traffic analysis for the Project and CO emissions factors from CARB’s mobile source inventory 

model EMFAC2017 were used to perform these analyses.

83 Appendix C includes details of this 

CALINE4 modeling analysis. 

To determine if there is an exceedance of the CO NAAQS, the screening 1-hour and 8-hour CO 

concentrations obtained from these analyses at each intersection were compared against the 

1­hour and 8-hour CO NAAQS, 35 ppm and 9 ppm, respectively, as well as the corresponding 

CAAQS of 20 ppm and 9 ppm, respectively. 

5. Affected Environment 

5.1. General Discussion of Air Quality Pollutants 

5.1.1. Criteria Air Pollutants 

Criteria air pollutants are defined as pollutants for which the federal and state governments 

have established ambient air quality standards, or criteria, for outdoor concentrations to 

protect public health. The federal and state standards have been set, with an adequate margin 

of safety, at levels above which concentrations could be harmful to human health and welfare. 

These standards are designed to protect the most sensitive people from illness or discomfort. 

Pollutants of concern include O3, NO2, CO, SO2, PM10, and PM2.5. As noted previously, there are 

no large sources of Pb emissions associated with the construction or operation of the Project; 

hence Pb emissions were not evaluated. In California, sulfates, vinyl chloride, hydrogen sulfide, 

and visibility-reducing particles are also regulated as criteria air pollutants. These pollutants are 

discussed in the following paragraphs. 

5.1.1.1. Ozone 

Ozone is a colorless gas that is formed in the atmosphere when VOCs, sometimes referred to as 

reactive organic gases (ROG), and NOX react in the presence of ultraviolet sunlight. O3 is not a 

primary pollutant; it is a secondary pollutant formed by complex interactions of two pollutants 

directly emitted into the atmosphere. The primary sources of VOCs and NOX, the precursors of 

O3, are automobile exhaust and industrial sources. Meteorology and terrain play major roles in 

82 BAAQMD CEQA Guidelines. 

83 As noted previously, a newer version of EMFAC, EMFAC2021, was released in January 2021, however it has not been approved by USEPA. 

36 AIR QUALITY AND GREENHOUSE GAS TECHNICAL REPORT, OCTOBER 2022 
BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL 

O3 formation, and ideal conditions occur during summer and early autumn on days with low 

wind speeds or stagnant air, warm temperatures, and cloudless skies. Short-term exposures 

(lasting for a few hours) to O3 at levels typically observed in Southern California can result in 

breathing pattern changes, reduction of breathing capacity, increased susceptibility to 

infections, inflammation of the lung tissue, and some immunological changes. 

5.1.1.2. Nitrogen Dioxide 

Most NO2, like O3, is not directly emitted into the atmosphere but is formed by a chemical 

reaction between nitric oxide (NO) and atmospheric oxygen. NO and NO2 are collectively 

referred to as NOX and are major contributors to O3 formation. The primary sources of NO, the 

precursor to NO2, include automobile exhaust and industrial sources. High concentrations of 

NO2 can cause breathing difficulties and result in a brownish-red cast to the atmosphere, 

causing reduced visibility. There is some indication of a relationship between NO2 and chronic 

pulmonary fibrosis, and some increase in bronchitis in children (2 and 3 years old) has also been 

observed at concentrations below 0.3 parts per million by volume (ppm).84 

5.1.1.3. Carbon Monoxide 

Carbon monoxide is a colorless and odorless gas formed by the incomplete combustion of fossil 

fuels. CO is emitted almost exclusively from motor vehicles, power plants, refineries, industrial 

boilers, ships, aircraft, and trains. In urban areas, such as the Project location, automobile 

exhaust accounts for the majority of CO emissions. CO is a non-reactive air pollutant that 

dissipates relatively quickly; therefore, ambient CO concentrations generally follow the spatial 

and temporal distributions of vehicular traffic. CO concentrations are influenced by local 

meteorological conditions, primarily wind speed, topography, and atmospheric stability. CO 

from motor vehicle exhaust can become locally concentrated when surface-based temperature 

inversions are combined with calm atmospheric conditions, a typical situation at dusk in urban 

areas between November and February. The highest levels of CO typically occur during the 

colder months of the year when inversion conditions, where a layer of warm air sits atop cool 

air, are more frequent and can trap pollutants close to the ground. In terms of health, CO 

competes with oxygen, often replacing it in the blood, thus reducing the blood’s ability to

transport oxygen to vital organs. The results of excess CO exposure can be dizziness, fatigue, 

and impairment of central nervous system functions. 

5.1.1.4. Sulfur Dioxide 

Sulfur dioxide is a colorless, pungent gas formed primarily by the combustion of sulfurcontaining fossil fuels. The main sources of SO2 are coal and oil used in power plants and 

industries; as such, the highest levels of SO2 are generally found near large industrial 

complexes. In recent years, SO2 concentrations have been reduced by the increasingly stringent 

controls placed on stationary source emissions of SO2 and limits placed on the sulfur content of 

fuels. SO2 is an irritant gas that attacks the throat and lungs, and can cause acute respiratory 

84 American Lung Association. 2020. Nitrogen Dioxide. Available at: https://www.lung.org/clean-air/outdoors/what-makes-airunhealthy/nitrogen-dioxide. Accessed: June 2022. 

AIR QUALITY TECHNICAL REPORT, OCTOBER 2022 37 
symptoms and diminished ventilator function in children. SO2 can also yellow plant leaves and 

erode iron and steel. 

5.1.1.5. Particulate Matter 

Particulate matter (PM) pollution consists of very small liquid and solid particles floating in the 

air, which can include smoke, soot, dust, salts, acids, and metals. Particulate matter can form 

when gases emitted from industrial activity and motor vehicles undergo chemical reactions in 

the atmosphere. PM2.5 and PM10 represent fractions of particulate matter. Fine particulate 

matter, or PM2.5, is roughly 1/28 the diameter of a human hair. PM2.5 results from fuel 

combustion (e.g., motor vehicles, power generation, and industrial facilities), residential 

fireplaces, and woodstoves. In addition, PM2.5 can form in the atmosphere from gases such as 

SOX, NOX, and VOCs. Inhalable or coarse particulate matter, or PM10, is about 1/7 the thickness 

of a human hair. Major sources of PM10 include crushing or grinding operations; dust stirred up 

by vehicles traveling on roads; wood-burning stoves and fireplaces; dust from construction, 

landfills, and agriculture; wildfires and brush/waste burning; industrial sources; windblown dust 

from open lands; and atmospheric chemical and photochemical reactions. 

PM2.5 and PM10 pose a greater health risk than larger-size particles. When inhaled, these tiny 

particles can penetrate the human respiratory system’s natural defenses and damage the 

respiratory tract. PM2.5 and PM10 can increase the number and severity of asthma attacks, 

cause or aggravate bronchitis and other lung diseases, and reduce the body’s ability to fight

infections. Very small particles of substances such as lead, sulfates, and nitrates can cause lung 

damage directly or be absorbed into the bloodstream, causing damage elsewhere in the body. 

Additionally, these substances can transport absorbed gases, such as chlorides or ammonium, 

into the lungs, also causing injury. Whereas PM10 tends to collect in the upper portion of the 

respiratory system, PM2.5 is so tiny that it can penetrate deeper into the lungs and damage lung 

tissues. Suspended particulates also damage and discolor surfaces on which they settle, as well 

as produce regional haze and reduce visibility. 

5.1.2. Greenhouse Gases 

There is a general scientific consensus that global climate change is occurring, caused in whole 

or in part by increased emissions of GHGs that keep the Earth’s surface warm by trapping heat

in the Earth’s atmosphere, in much the same way that glass traps heat in a greenhouse.85 The 

Earth’s climate is changing because human activities, primarily the combustion of fossil fuels, 

are altering the chemical composition of the atmosphere through the buildup of GHGs. 

GHGs allow the sun’s radiation to penetrate the atmosphere and warm the Earth’s surface, but

do not let the infrared radiation emitted from the Earth escape back into outer space. As a 

result, global temperatures are predicted to increase over the century. In particular, if climate 

change remains unabated, surface temperatures in California are expected to increase 

anywhere from 4.1 to 8.6 degrees Fahrenheit by the end of the century, compared to 2021 

AIR QUALITY AND GREENHOUSE GAS TECHNICAL REPORT, OCTOBER 2022 

85 Intergovernmental Panel on Climate Change (IPCC). 2021: Climate Change 2021: The Physical Science Basis. Contribution of Working Group 

I to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change 

38 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL 

levels.

86 Not only would higher temperatures directly affect the health of individuals through 

greater risk of dehydration, heat stroke, and respiratory distress, the higher temperatures may 

increase ozone formation, thereby worsening air quality. Rising temperatures could also reduce 

the snowpack, which would increase the risk of water shortages. Higher temperatures along 

with reduced water supplies could reduce the quantity and quality of agricultural products. In 

addition, there could be an increase in wildfires and a shift in distribution of natural vegetation 

throughout the State. Global warming could also increase sea levels and coastal storms 

resulting in greater risk of flooding. 

Emissions of carbon dioxide are the leading cause of global warming, with other pollutants such 

as methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride also 

contributing. The magnitude of each GHG’s impact on global warming differs because each GHG 

has a different global warming potential (GWP), which indicates, on a pound for pound basis, 

how much the pollutant will contribute to global warming relative to how much warming would 

be caused by the same mass of CO2. CH4 and N2O, for example, are substantially more potent 

than CO2, with GWPs of 25 and 298, respectively.87 

5.2. Air Resources by Basin 

The air quality attainment designations for the South Coast and Mojave Desert air basins are 

provided in Table 6-1. As shown in the table, both areas are designated as non-attainment for 

certain pollutants which are regulated under the Federal Clean Air Act. Refer to Table 2-1 for a 

complete list of NAAQS and CAAQS. 

5.2.1. South Coast Air Basin 

The South Coast Air Basin is comprised of Orange County and portions of Los Angeles, San 

Bernardino, and Riverside counties. 

86 California Natural Resources Agency. 2021. Draft California Climate Adaptation Strategy. Available at: https://resources.ca.gov/-

/media/CNRA-Website/Files/Initiatives/Climate-Resilience/SAS-Workshops/Draft-CA-Climate-Adaptation-Strategy-ada.pdf. 

87 Intergovernmental Panel on Climate Change (IPCC). 2021: Climate Change 2021: The Physical Science Basis. Contribution of Working Group I 

to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change. Available at: 

https://www.ipcc.ch/report/ar6/wg1/#SPM. 

AIR QUALITY TECHNICAL REPORT, OCTOBER 2022 39 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Figure 5-1. South Coast Air Basin 

Under the Federal Clean Air Act, the USEPA and CARB have designated portions of SCAQMD 

nonattainment for ozone and PM2.5. 

On October 1, 2015, the USEPA strengthened the NAAQS for ground-level ozone, lowering the 

primary and secondary ozone standard levels to 70 parts per billion (ppb). The SCAB is classified 

as an “extreme” non-attainment area and the Coachella Valley is classified as a “severe-15” 

non-attainment area for the 2015 Ozone NAAQS. The 2022 Air Quality Management Plan 

(AQMP) is being developed by SCAQMD to address the requirements for meeting this 

standard.88 The 2022 AQMP is meant to include a comprehensive analysis of emissions, 

meteorology, regional air quality modeling, regional growth projections, and the impact of 

existing and proposed control measures. At the time of this writing, there have been numerous 

working group meetings to address the various source categories of emissions (i.e., aircraft, 

construction and industrial equipment, heavy-duty trucks, ocean-going vessels) and control 

measures and strategies are being developed/considered for the 2022 AQMP. 

The SCAQMD has recently prepared the Final 2021 Redesignation Request and Maintenance 

Plan for the 2006 and 1997 24-Hour PM2.5 Standards for South Coast Air Basin in October 

2021.

89 This document was prepared to revise the PM2.5 SIP to request redesignation of the 

Basin to attainment for both the 2006 24-hour average PM2.5 standard and the 1997 24-hour 

average PM2.5 standard, and to submit the maintenance plan and other required actions to 

qualify for such redesignation. 

5.2.2. Mojave Desert Air Basin 

The Mojave Desert Air Basin consists of portions of San Bernardino, Kern, Los Angeles, and 

Riverside counties. 

88 SCAQMD. 2022. Air Quality Management Plan (AQMP). 

89 Ibid. 

40 AIR QUALITY AND GREENHOUSE GAS TECHNICAL REPORT, OCTOBER 2022 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL 

Figure 5-2. Mojave Desert Air Basin 

The Mojave Desert Air Basin is comprised of four air districts, the Kern County Air Pollution 

Control District, the Antelope Valley Air Quality Management District (AVAQMD), the 

MDAQMD, and the eastern portion of the South Coast AQMD. The MDAQMD has jurisdiction 

over the desert portion of San Bernardino County and the far eastern end of Riverside County. 

This region includes the incorporated communities of Adelanto, Apple Valley, Barstow, Blythe, 

Hesperia, Needles, Twentynine Palms, Victorville, and Yucca Valley; as well as the National 

Training Center at Fort Irwin, the Marine Corps Air Ground Combat Center, the Marine Corps 

Logistics Base, the eastern portion of Edwards Air Force Base, and a portion of the China Lake 

Naval Air Weapons Station. 

Under the Federal CAA, the USEPA and CARB have designated portions of MDAQMD 

nonattainment for ozone and PM10. The MDAQMD has adopted state (California) and Federal 

attainment plans for the region within its jurisdiction. In 1995, the MDAQMD submitted a 

Federal Particulate Matter (PM10) Attainment Plan90, which demonstrates how attainment of 

the Federal PM10 standard will be achieved by the earliest practicable date. The PM10 

Attainment Plan outlines selected control measures that would be imposed to limit the amount 

of PM10 released into the atmosphere. Part of this plan requires Dust Control Plans for 

construction projects disturbing 100 or more acres. The USEPA approved the first MDAQMD 

Ozone Attainment Plan in 2004, followed by an 8-hour ozone attainment plan for the Western 

Mojave Desert Non-Attainment Area in 2008.

91 This document addressed all existing and 

forecast O3 precursor producing activities within the MDAQMD through the year 2020. The plan 

mainly targeted reduction of NOx and VOC emissions. MDAQMD also prepared a 70 ppb Ozone 

Standard Implementation Evaluation Reasonably Available Control Technology State 

Implementation Plan Analysis more recently in October 2019. 

The MDAQMD has adopted rules and regulations to implement portions of the abovementioned attainment plans. Several of these rules would apply to construction or operation of 

the Project. For example, MDAQMD Rule 40392 requires suppression of fugitive dust emissions 

from construction activity such that no visible dust extends beyond the property line of the 

90 MDAQMD. 1995. Mojave Desert Planning Area Federal Particulate Matter (PM10) Attainment Plan. 

91 MDAQMD. 2008. MDAQMD Federal 8-hour Ozone Attainment Plan (Western Mojave Desert Non-attainment Area). 

92 MDAQMD. 2020. 

AIR QUALITY TECHNICAL REPORT, OCTOBER 2022 41 
 

 

 

 

 

 

 

 

 

 

 

 

emissions source. A Dust Control Plan for construction projects disturbing 100 or more acres is 

required by the MDAQMD Federal PM10 Plan.

93 

5.3. Air Quality Setting 

5.3.1. Existing Emissions 

Under existing conditions (Year 2020), on-road motor vehicles contribute mobile emissions to 

the South Coast and Mojave Desert air basins. Table 6-2 demonstrates the level of emissions in 

2020 from on-road motor vehicles based on EMFAC201794 emissions data. 

5.3.2. Ambient Air Monitoring Data 

5.3.2.1. Rancho Cucamonga 

Monitoring data summarized in Table 6-3 show the 1-hour and 8-hour ozone concentrations, 1-

hour and 8-hour CO concentrations, 1-hour and annual NO2, 1-hour and 24-hour SO2 

concentrations, and 24-hour and annual PM10 and PM2.5 concentrations at the nearest 

representative monitoring station to the proposed Rancho Cucamonga passenger station. 

5.3.2.2. Hesperia 

Similarly, monitoring data summarized in Table 6-4 shows the same pollutants with 

concentrations presented from the nearest representative monitoring station to the proposed 

Hesperia passenger station. 

5.3.3. Climate Data 

5.3.3.1. Rancho Cucamonga 

Rancho Cucamonga climate data was used to characterize Project vicinity climate conditions at 

the Rancho Cucamonga passenger station. The average Project area summer (July) and winter 

(December) temperatures are 76.6 °F and 50.0 °F, respectively. The annual average rainfall is 

18.7 inches.95 

5.3.3.2. Hesperia 

Hesperia climate data was used to characterize Project vicinity climate conditions at the 

Hesperia passenger station. The average Project area summer (July) and winter (December) 

temperatures are 78.6 °F and 44.6 °F, respectively. The annual average rainfall is 8.5 inches.96 

93 MDAQMD. 1995. 

94 As noted previously, a newer version of EMFAC, EMFAC2021, was released in January 2021, however it has not been approved by USEPA. 

95 Climate Data. n.d. Rancho Cucamonga temperature and precipitation data is for the period from 1999 – 2019. 

96 Climate Data. n.d. Hesperia temperature and precipitation data is for the period from 1999 – 2019. 

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BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL 

6. Environmental Consequences and Mitigation 

6.1. Build Alternative 

6.1.1. Construction Effects 

Construction of the Build Alternative would temporarily generate emissions between 2022 and 

2025. Mitigated emissions for each criteria air pollutant during each year of construction were 

compared to the de minimis thresholds for the two air basins. 

South Coast Air Basin Construction Emissions: The criteria air pollutant emissions in the SCAB 

that would result from construction of the Project are displayed in Table 7-1. The annual criteria 

air pollutant emissions from construction would not exceed General Conformity de minimis 

thresholds. The greenhouse emissions from Project construction are summarized in Table B-4 in 

Appendix B. These are temporary emissions that would be offset by the reductions in the 

annual operational GHG emissions over the Project lifetime as the HSR ridership increases. 

There are no federal de minimis thresholds for GHG emissions. 

Mojave Desert Air Basin Construction Emissions: The criteria air pollutant emissions in the 

MDAB that would be generated from construction of the Project are detailed in Table 7-2. The 

annual criteria air pollutant emissions from construction are below the de minimis levels for all 

criteria air pollutants. The greenhouse emissions from Project construction are summarized in 

Table B-4 in Appendix B. These are temporary emissions that would be offset by the reductions 

in the annual operational GHG emissions over the Project lifetime with increase in HSR 

ridership. There are no federal de minimis thresholds for GHG emissions. 

6.1.2. Operational Effects 

The potential emissions of CAPs, TACs, and GHGs resulting from the Project’s operational

activities under the Build Alternative are lower than the No Build Alternative operational 

emissions due to the large reduction in on-road VMT expected as a result of the proposed rail 

line. 

Operational CAP and TAC Emissions Evaluation: As noted previously in Section 4.6.2, 

operational CAP and TAC emissions from the electric-powered rail line would be near zero. 

Reduction in on-road VMT under the Build Alternative as compared to the No Build Alternative 

resulting from the avoided passenger car travel would generate a decrease in emissions of all 

CAPs and TACs. Hence, the Project is expected to generate a net decrease in CAP and TAC 

emissions. 

South Coast Air Basin Operational GHG Emissions Evaluation: The GHG emissions associated 

with the SCAB that would result from implementation of the Project at opening year 2025 and 

horizon year 2045 are provided in Table 7-3. This includes the GHG emissions associated with 

operating the HSR and the GHG emissions reductions from avoided on-road passenger car 

travel. The net annual GHG emissions due to the Project in the opening year is 338 MT CO2e, 

which is well below the SCAQMD’s proposed screening level of 3,000 MT CO2e/year for 

AIR QUALITY TECHNICAL REPORT, OCTOBER 2022 43 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

residential and commercial projects.

97 Further, as noted in Table 7-3, the Project results in a net 

decrease in GHG emissions of 13,608 MT CO2e in the horizon year 2045 as the ridership on the 

HSR increases. Hence, the Project would result in a net reduction in GHG emissions in the SCAB 

over its lifetime. 

Mojave Desert Air Basin Operational GHG Emissions Evaluation: The GHG emissions 

associated with the MDAB that would result from implementation of the Project at opening 

year 2025 and horizon year 2045 are provided in Table 7-4. The net annual GHG emissions due 

to the Project in the opening year is 9,612 MT CO2e. As noted in Table 7-3, the Project results in 

a net decrease in GHG emissions of 20,861 MT CO2e in the horizon year 2045 as the ridership 

on the HSR increases. Hence, the Project would generate a net reduction in GHG emissions in 

the MDAB over its lifetime. 

Evaluation of CO Hotspots: Based on CO Hotspot analysis of the most congested Project 

intersection locations requiring evaluation in the opening year 2025, the concentrations of CO 

at these intersections would not violate CAAQS and NAAQS thresholds (i.e., result in a CO hot 

spot) at any intersection. Table 7-5 shows the CO concentrations at each intersection in the 

opening year and demonstrates that these concentrations are below the CAAQS and NAAQS 

thresholds. In the horizon year 2045, as seen in Table 7-6, the CO concentrations at all 

evaluated intersections are also lower than the CAAQS and NAAQS threshold concentrations. 

6.2. General Conformity De Minimis Summary 

The Project construction emissions were compared against the de minimis thresholds 

(Table 7­1 and Table 7-2) and the annual emissions from maximum Project emissions over the 

Project lifetime were less than the thresholds for all criteria air pollutants. 

6.3. No Build Alternative 

6.3.1. Construction Effects 

The No Build Alternative does not include any construction and, therefore, would result in no 

impacts related to construction. 

6.3.2. Operational Effects 

In the No Build Alternative, there would be no HSR connecting between Victor Valley, 

California, and Rancho Cucamonga, California. Hence travelers would continue to use passenger 

cars for their commute. As noted under Section 6.1.2., the CAP, TAC, and GHG emissions from 

these passenger cars would be greater than those from the HSR that is proposed under the 

Project. 

6.4. Avoidance, Minimization, and/or Mitigation Measures 

The following mitigation measures were incorporated into the Project air quality analysis: 

AIR QUALITY AND GREENHOUSE GAS TECHNICAL REPORT, OCTOBER 2022 

97 SCAQMD. 2008. Interim CEQA GHG Significance Threshold for Stationary Sources, Rules, and Plan. 

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• Mitigation Measure 1: Fugitive Dust Control Plan during Construction to Meet 

MDAQMD Rule 40398 Requirements. 

– Consistent with the MDAQMD Rule 403 (Fugitive Dust Control), the following control 

measures shall be implemented: 

▪ Use periodic watering (two times daily) for short-term stabilization of disturbed 

surface area to minimize visible fugitive dust emissions. Use of a water truck to 

maintain moist disturbed surfaces and actively spread water during visible 

dusting episodes shall be considered sufficient to maintain compliance. 

▪ Take actions sufficient to prevent Project-related trackout onto paved surfaces. 

Actions may include the use of: 

o Gravel or aggregate vehicle tracking pads at temporary site entrances and 

exits 

o Wash racks that use pressurized water to clean tires as they pass through. 

Wash racks introduce water to the trackout control system which must be 

contained within the jobsite. 

o Rumble plates, rumble strips, cattle guards that use vibration to shake off 

debris from vehicle tires. 

▪ Cover loaded haul vehicles while operating on publicly maintained paved 

surfaces. 

▪ Stabilize graded site surfaces upon completion of grading when subsequent 

development is delayed or expected to be delayed more than 30 days, except 

when such a delay is due to precipitation that dampens the disturbed surface 

sufficiently to eliminate visible fugitive dust emissions. 

▪ Clean up Project-related trackout or spills on publicly maintained paved surfaces 

within 24 hours. 

▪ Reduce nonessential earth-moving activity under high wind conditions. A 

reduction in earth-moving activity when visible dusting occurs from moist and 

dry surfaces due to wind erosion shall be considered sufficient to maintain 

compliance. 

o Alternatively, Brightline West can elect to apply for and obtain an MDAQMDapproved Alternative PM10 Control Plan that incorporates emission reducing 

measures other than those defined above, as long as it generates equivalent 

emission reductions and is obtained pursuant to the requirements outlined 

in MDAQMD Rule 403. 

• Mitigation Measure 2: Fugitive Dust Control Plan during Construction to Meet SCAQMD 

Rule 40399 Requirements. 

AIR QUALITY TECHNICAL REPORT, OCTOBER 2022 

98 MDAQMD, 2020. 

99SCAQMD. 2005. 

45 
 

 

 

 

 

 

 

 

 

– Follow Best Available Control Measures in Table 1 of Rule 403. 

• Mitigation Measure 3: Utilize additional means to reduce construction period emissions 

of air pollutants. 

– Brightline West shall demonstrate that construction-period emissions of criteria air 

pollutants would not exceed General Conformity de minimis thresholds by 

integrating control measures into approved design-build plans. Examples of control 

measures include the following: 

▪ All off-road internal-combustion engine construction equipment shall be USEPA 

Tier-4 Final certified. 

▪ All signal boards shall be solar-powered. 

▪ All architectural coatings products shall contain no more than 250 grams of VOC 

per liter of coating (2.08 pounds per gallon). 

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BRIGHTLINE WEST CAJON PASS HIGH-SPEED RAIL 

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https://www.whitehouse.gov/briefing-room/presidential-actions/2021/01/20/executive-orderprotecting-public-health-and-environment-and-restoring-science-to-tackle-climate-crisis/. 

Accessed: March 2022. 

White House Briefing Room. 2021b. Executive Order on Tackling the Climate Crisis at Home and 

Abroad. January 27. Available at: https://www.whitehouse.gov/briefing-room/presidentialactions/2021/01/27/executive-order-on-tackling-the-climate-crisis-at-home-and-abroad/. 

Accessed: March 2022 

White House Briefing Room. 2021c. Paris Climate Agreement. January 20. Available at: 

https://www.whitehouse.gov/briefing-room/statements-releases/2021/01/20/paris-climateagreement/. Accessed: March 2022. 

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