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California-Nevada Interstate Maglev Project

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By Thomas Bordeaux
Senior Transportation Manager – American Magline Group (AMG)

1. Briefly describe your project (one or two short paragraphs) in terms of the following:
A. Purpose
B. Travel Experience
C. Features of the Transport Technology
D. Public Benefit to Victorville and other High Desert Cities
E. Financing Plan
The California Nevada Interstate Maglev Project (CNIMP) will bring the fastest train service in the world and cover a distance of 269 miles connecting Las Vegas, the entertainment capital of the world, with Southern California, the largest and most diverse population center in the United States. The Maglev system is an advanced technology and will be constructed in this corridor for about $12.1 billion ($45M/mi) which is within the same cost-per-mile range as European style high-speed rail. This estimate was prepared in 2000 and updated in 2005. It will again be updated as part of the environmental process to account for a number of cost reduction innovations that have been developed by the project team over the past five years and to account for the current construction market. The operating and maintenance costs of the Maglev system are significantly less than traditional railway service. There are no moving parts to wear or track to align. The train moves smoothly at high speeds supported by a magnetic field.
The efficiency of modern transportation can be judged by two indicators: the Connections Made and the Travel Time it takes to connect major places. The Maglev system will be the fastest, most efficient transportation mode for High Desert and Southern California residents to travel to and from Las Vegas. Maglev will provide the most convenient option for business, commuters and recreational travel within this corridor. Maglev will make travel to and from the High Desert to International Airports in Ontario, Anaheim, and Las Vegas simpler than ever. Maglev will connect High Desert residents with the heart of Southern California within minutes, compared to today’s difficult commute. Maglev will allow for a visit to Las Vegas for dinner and a show, and a quick trip home.
With the connections made by the Maglev service, Victorville will become a major distribution point for Southern California. It will also become a highly desirable and sustainable suburb with a shortened commute times for employees who work in Orange County and live in Victorville or other surrounding High Desert communities.
The Maglev technology has been developed over thirty years and has been operating successfully in Shanghai for six years at over 99.8% on-time reliability. The Maglev trains utilize the latest in control and construction technology, are equipped with passenger amenities, and are extremely quiet in operation. Running the length on an elevated guideway, the Maglev service is fast, efficient and unlike any other operating train system in the world.
The project financial plan is discussed under Question 2.
2. Who are your financial and development partners? Please list them.
The California-Nevada Super Speed Train Commission (CNSSTC) is designing and building the California-Nevada Interstate Maglev Project (CNIMP) through a Public-Private Partnership with the American Magline Group (AMG), a partnership including MNC & Associates, Parsons Corporation, Hirschfeld Industries, General Atomics and Transrapid International-USA, Inc. This public-private partnership is advancing the next generation Transrapid Maglev technology and elevated systems in the United States. The technology has been developed over thirty years and has been operating successfully in Shanghai for nearly six years at over 99.8% on-time reliability.

AMG is committed to delivery of this project through competent and conservative business principles and in the public interest. AMG has stayed the course over the past 10 years, through equity investment of expertise, services, and products. A number of past federal grants have supported the Maglev project development, including: technology review, detailed project description, complete environmental assessment, stakeholder briefings, transportation planning, concept engineering, and initiation of the Environmental Impact Statement (EIS). These efforts have been supported by bi-partisan support in California and Nevada through local governments, and by Congressional representatives from both states, in Washington D.C.
The project financial plan identifies the use of federal grant and TIFIA loan programs, public and private equity contributors, and commercial bond funds. Recently a loan proposal was announced for $7 billion in financing from the Import Export Bank of China. Other equity and loan contributors are in negotiations with the public-private partnership, indicating that strong financing options are available; and each option will be considered carefully with the long-term public interest in mind, and applying the hard lessons learned from recent failures in private financing approaches for rail projects.
3. Where will your system have stations physically located?
The Maglev project will have stations at the following locations: Las Vegas, Ivanpah (future airport), and Primm, in Nevada; and Barstow, Victorville, Ontario, and Anaheim, in California. The EIS work is identifying the preferred sites for the stations. The terminal station in California is planned for the Anaheim Regional Transportation Intermodal Center (ARTIC) in Anaheim.
4. What type of connections will your system create for Victorville and the other High Desert cities?
The Maglev service will provide fast access for residents of the High Desert to three International airports: Ontario, Orange County and Las Vegas. This will essentially connect Victorville with the rest of the world and will make Victorville a far more attractive business and residential community for sustainable growth and economic development. Connections between Victorville and Ontario will be in 16 minutes and far more efficient than any other transportation option. Add another 11 minutes and the Maglev service will arrive in the heart of Southern California at the ARTIC Station in Anaheim. Connections to the Las Vegas McCarran International Airport will be possible in slightly more than an hour (54 minutes from Victorville to the terminus station in Las Vegas, plus connecting time).
With comfortable and state-of-art service to the ARTIC station in less than 30 minutes from the Victorville station, residents will be connected to other transportation services, including the California High Speed trains north to Los Angeles, Metrolink, bus rapid transit and other options. Furthermore, the ARTIC is within minutes of the sports venues, shopping, entertainment, and other business activities in this vibrant area.
Connections to Las Vegas from the Victorville Station in less than an hour will serve tourist, business, and recreational travelers. The Victorville station will become a transportation distribution hub which will generate tremendous economic activity.
5. What are the current plans for facilities at the terminal stations?
A. Retail
B. Hotels
C. Parking, etc.
The ARTIC station in Anaheim will be a world-class multimodal facility and activity center in the “Platinum Triangle” and is currently in design. The ARTIC project is a partnership between the City of Anaheim and the Orange County Transportation Authority (OCTA), and is a multi-year project, that will offer new and expanded transportation services and development. The project includes site work and preparation, transportation center and supporting facilities, guideway, trackwork and platforms, parking, public art, and will be an intermodal hub for Amtrak, Metrolink, local and international buses, shuttles, bikes, other fixed guideway, California High Speed Rail, and the California-Nevada Interstate Maglev. It will also provide opportunities for Public Private Partnerships development for commercial, retail, office, and residential uses with the cities Platinum Triangle Mixed Use Overlay Zone. More information on the ARTIC can be found at this link:
The Terminal Station in Las Vegas will be designed to achieve the same integration with other transportation services and facilities, and urban development similar to that planned for the ARTIC Terminal Station. The preliminary design will determine all facilities to be included at the terminal stations in consultation with coordinating public and private stakeholders.
In overview, the stations for the Maglev system will be the first point of contact for passengers, and must be efficiently laid out and managed to provide the best possible experience for the customers. The stations will be environmentally pleasing, with clear, easy-to-understand signage and an intuitive and uncomplicated passenger amenities for all phases of the ticketing and fare collection process. The stations’ designs will separate the access and egress paths to minimize conflicting walking paths. Requirements of the Americans with Disabilities Act (ADA) will be included in the station design. All public areas of the stations shall be handicapped accessible.
6. What is the socio-economic and market profile of potential users of your system?
Because of the low cost of our ticket structuring and the opportunity for fare packages for returning commuters, our system will become a backbone of tourism, commuter and business travelers. There will not be a better transportation option and connection in this corridor. The City of Victorville and the nearby High Desert Communities will have a lifeline transportation system like nowhere else in the world.
The Maglev system can also handle small cargo, which will be carried on the line primarily at night. This will also create economic opportunities and a boost to the overall economy in the High Desert.
7. How long will it take to transport passengers from Victorville to Las Vegas and Las Vegas to Victorville and/or Anaheim and at what cost?
The travel time and cost are developed as part of the EIS and earlier work completed in 2000 for a comprehensive Environmental Assessment report. The EIS scope of work includes comparison of the Maglev project with the proposed DesertXpress project.
The Maglev train will transport people from Las Vegas to Victorville in 54 minutes for a one-way fare of $36; and between Las Vegas and Anaheim via express service in 81 minutes and for a one-way fare of $55. These fares were assumed as percentages of the airline fares between Las Vegas and Orange County. The ridership and revenue analysis will be updated as part of the EIS process.

8. How long will it take to transport passengers and for what price from Las Vegas to other parts of Southern California and what locations in Southern California would you propose?
A travel time and fare comparison is provided in the table below. The Maglev services as planned will make connections in the fastest time possible through efficient Maglev system technology and proven safe operations. Comparisons are made with the DesertXpress project, which is considered as an alternative in the environmental studies.
9. What is the expected annual ridership and how will passengers get on and off at Victorville or other High Desert cities?
The projected ridership for the Las Vegas to Anaheim service is projected for the year 2025, showing more than 42 million annual (one-way) trips on the Maglev service. Of this total, about 13.9 million annual (one-way) trips would occur in the Anaheim to Ontario segment; and about 14.3 million annual (one–way) trips would occur in the Las Vegas to Primm segment. The ridership estimates were prepared prior to the initiation of the planning for Ivanpah Airport and do not include potential riders using Maglev to access the planned airport.
These ridership projections primarily include the diversion from other transportation modes: auto trips and intercity airline trips. The current work will include a more thorough examination of the number of “induced” new trips that would be generated by the availability of the service. For example, as noted above, people from Victorville and the High Desert, as well as Southern California, may make more frequent trips to Las Vegas for entertainment or business purpose, as a result of the fast connection provided with Maglev service.
10. How many people will go from other cities within Southern California to Victorville if your project is fully implemented?
The overall ridership projections shown in the table illustrate the total segment number of riders or one-way trips, for projections on an annual and daily basis. These include connections by auto and other transit modes, from communities nearby each of the station cities.
Victorville along the corridor and as a gateway station connecting into Southern California would be ideally situated for accommodating travelers in either direction. The Victorville station is projected to generate a significant ridership demand with the order of magnitude similar to the level of ridership shown for both the Primm and Anaheim stations and connecting segments.
11. What is the implementation schedule for your project?
The original timeline was to begin construction on the starter segment this year, 2010. A delay in release of the federal grant for the environmental and engineering work has delayed completion of the Environmental Impact Statement until the end of 2011. Some work may begin (at-risk) in advance of that date to prepare facilities for manufacture and assembly of the system components.
Current timeline is:
Release of SAFETEA-LU grant
and completion of final phase of
the EIS/Preliminary Design: 4th Quarter, 2011.
Build starter segment, initiate operations, and begin other segments: 4th Quarter, 2014.
Full corridor complete & initiate operations: 2016/2018.
12. Are there any extensions planned or required for your project?
None are required. The planned Maglev project is a complete system. (See, also response to #17.) However, it should be noted that several inter-mountain states have started discussions regarding high speed ground transportation connecting Nevada, Utah, Colorado, Idaho, New Mexico, and Arizona. Maglev may be considered a best solution for the Rocky Mountain region.
13. What is the status of the environmental studies for your project and have you completed the requirements under the California Environmental Quality Act (CEQA)?
Over the past ten years, substantial work relevant to the federal requirements of an EIS/EIR in both California and Nevada has already been completed and approved by the Federal Railroad Administration (FRA). This work, as listed below, is fast-tracking the completion of the EIS/EIR for the full corridor:
• Environmental Assessment, Las Vegas to Primm, 2000
• Las Vegas-Primm Project Description, June 2000
• Las Vegas-Barstow Project Description, August 2002
• Anaheim-Ontario Project Description, August 2003
• Ontario-Barstow Project Description, February 2004
• Full Corridor Project
Description (Las Vegas to
Anaheim), September 2005
The EIS is underway for the first segment from Las Vegas to Primm. This will be followed by completion of the EIS/EIR for the segments within California. The CNIMP Team has already completed Phases 1 and 2 of the PEIS for the full 269-mile corridor and specific deliverables to the FRA under prior PEIS contracts. Some of these deliverables include the Draft PEIS Scope of Work, the Purpose and Need Statement, the Draft Preliminary Alternatives Analysis for Las Vegas to Primm, detailed mapping and extensive public outreach and coordination with local stakeholders.
The timeline for completion of the EIS is shown above in the response to Question #11.
14. How will your project impact the environment and what are the required mitigations?
The project’s environmental impacts and benefits are being fully documented in the EIS/EIR. The construction and operations of the Maglev system along the planned alignment and through the desert environment will have some visual and land consumption impacts to the surrounding areas. The Maglev team will work to integrate the infrastructure along the guideway and at the stations in full cooperation with the various cities and governmental stakeholders. Examples from the operating Maglev system in Shanghai China, provides a good perspective of how well Maglev can be integrated into the urban and rural environments.
The Maglev system by its design will yield significant environmental benefits due to the considerable reduction in traffic congestion and pollutant emissions (See Question #22 for more details). The EIS/EIR work accomplished indicates that the impacts from a Maglev system will be substantially less than traditional railway systems or highway widening. The Maglev is electrically powered thus reducing emissions, is fully grade separated to avoid blocking wildlife corridors, and maintains a smaller footprint running along steeper grades thus allowing it to follow the I-15 corridor, without tunneling or impacting sensitive habitats, such as the Mojave National Preserve. A Maglev corridor typically requires less right-of-way clearance than conventional rail and less than one-fifth the width of an equivalent highway corridor.
There are several significant advantages that come from the Maglev system using a no-contact technology. The most obvious benefit of having no grinding wheels on track is that the Maglev is much quieter than conventional rail at comparable speeds. There is almost no sound or vibration except that created by the train passing through the air.
Given there is no friction and wear and tear to its parts, the Maglev system requires less maintenance and has lower impacts and surrounding land. By comparison, traditional railways require maintenance on a frequent basis, which includes maintenance vehicles and frequent maintenance equipment access along the right-of-way.
The Maglev system is the “green solution”, addressing the need for fast and efficient surface transportation systems and sound environmental management. Maglev offers frictionless technology, estimated to use 30 percent less energy than traditional railway systems traveling at the same speeds. The electrical system requirements for substations along the Maglev guideway can be met in part with alternative energy sources, including solar, wind, and other emerging “green” technologies. This will reduce draw from the electrical grid during peak demand periods and reduce operating costs.
15. Does your environmental study consider other city rail?
A full Environmental Assessment was completed in 2000, including a detailed ridership forecast. The ridership models were calibrated to reflect current conditions and for all connecting and alternative modes (light rail, metro rail and other services) for the forecast years. The Federal Railroad Administration which funded these earlier studies, commissioned an independent expert consultancy to review and verify the legitimacy of the Maglev ridership forecasts. These ridership forecasts are being updated to reflect current transportation and economic conditions.
The success of any intercity transportation link is to allow passengers to reach their destination with a minimum of transfers. The terminal station in Anaheim is a wonderful example of bringing passengers close to their destination and providing direct connections to local transit (bus, AGV, taxi) and long distance opportunities (California High Speed Rail, Amtrak/Metrolink commuter rail, John Wayne Airport). Similar connections to the Las Vegas’ Bonneville Transportation Center, under construction in Downtown Las Vegas, are also being explored
16. Are there any potential extensions covered in your environmental studies?
The Maglev system planned for connecting Las Vegas and Anaheim is a complete system that would connect the largest most diverse population center in America with the entertainment capital of the world. No extensions are currently required or planned.
Connections at the ARTIC and Las Vegas terminal stations with services provided by the California HSR system and other surface transportation modes are considered in the environmental and ridership studies; however, these are not part of the project cost or implementation.
17. What is the timeline for completion of any required extension?
There are no required extensions for the California – Nevada Interstate Maglev project. The project is to be implemented in three phased segments: 1) Las Vegas to Primm; 2) Anaheim to Ontario; and 3) Primm to Ontario. The current timeline for delivery of the project is provided above in response to Question #11.
18. What is the observed support for your project in southern Nevada and in the Las Vegas area?
During the development of this project over the last ten years, the Maglev team has participated in an extensive public outreach and local agency planning effort throughout Nevada and California and has always received overwhelming support from all types of stakeholders, including the public-at-large or the future riders, leaders along the corridor, local public agencies, labor unions, environmental groups, local businesses, and Universities.
In two widely distributed recent Nevada media polls the Maglev system was a runaway favorite where as many as 9 out of 10 polled stated a preference for it over the DesertXpress. The Maglev project received more than 81% support from the public of Southern Nevada while DesertXpress received only 7% support of the votes.
CNSSTC and AMG have jointly signed a Letter of Commitment with the Nevada Building Trades Council that reflects the strong feelings of support by Nevada’s union members for the jobs and economic benefits to come from implementation of the Maglev project.
19. What is the observed support for your project in Southern California and any and all of the High Desert cities?
Californians are wildly enthusiastic about the 310 mile per hour train and what it means to their commute. It opens up possibilities of travel to Las Vegas but just as important, it has high importance as a commuter train which allows them to live in less expensive areas such as Ontario and Victorville, even Las Vegas. No other project offers such advantage for commuting to other Southern California cities or making Victorville and Ontario distribution centers.
20. What are near and long term economic benefits of your project to the City of Victorville and other cities within the High Desert Region?
The Maglev would make Victorville a distribution point for southern California. It will be easier to work in southern California and live in Victorville than in cities that are part of the crushing urban traffic. Jobs will be brought to Victorville with the advent of distribution. There is the potential for small package distribution with Maglev trains, in the off-peak hours, that could contribute to Victorville as a center for warehousing and shipping. With Maglev all of the land in the Victorville area could become a valued suburb supporting new jobs in its own right.
21. What are the short and long term economic benefits of your project to the City of Las Vegas?
Nevada and California are currently in one of the worst economic situations in the nation with overall unemployment in double digits. About 50 percent of those in the construction industry are out of work and there are no major building projects on the horizon. Construction of the Maglev project has the potential to create more than 90,000 jobs, a new industry in the United States, and will pump hundreds of millions of dollars into the local economy in this corridor.
The Maglev project offers a long term rebirth of Las Vegas, linking places and people efficiently using the fastest transportation possible, faster than car, more convenient than the airline, faster than private aviation. During the 81 minutes visitors can walk on a train, sit, enjoy a drink or a meal, not hassle traffic, and arrive in one of the world’s most unique cities ever envisioned. Linking the largest and most diverse population center in the United States with the entertainment capital of the world with fast service will provide enormous economic stimulus to Southern Nevada, Southern California, and all the cities along this corridor.
22. How will your project effect the congestion on Interstate 15, south of Victorville connecting to any other cities and/or airports in Southern California?
The CNIMP Team has performed detailed analysis of the benefits resulting in the construction of the Maglev system versus a no-build option. One of the primary benefits would be the value of highway delays saved and the reduction in fatalities on I-15 from diversion of highway trips to the Maglev; however, there would also be a significant net environmental benefit due to the reduction in pollutant emissions.
The full Maglev system from Las Vegas to Anaheim is expected to have total additive benefits estimated to amount to more than $27 billion for an evaluation period of 41 years. This includes more than $8.5 billion saved due to decreased delays on I-15 and more than $1.1 billion due to decreased fatalities on I-15.
Victorville is approximately 90 miles away from Anaheim and the heart of Southern California. Congestion and pollutants from vehicular emissions along this segment of Interstate 15 is the worst part of the freeway. Because the Maglev system will have two additional and very key stations west of Victorville and deeper into the heart of Southern California, the benefits coming from reduction of I-15 congestion and surrounding freeways along this segment alone will be quite significant.
In addition to reduced congestion and fatalities, implementation of the Maglev system would result in a decrease in emissions of pollutants, such as total organic gas (TOG), carbon monoxide (CO), nitrogen oxides (NOX), and CO2. This is especially beneficial for ozone (O3) and CO levels, for which all or parts of the South Coast Air Basin (SCAB) is designated as non-attainment and is under federal mandate to reduce these emissions.

Significant benefits will be derived for the highly congested segment, between Anaheim and Ontario, which covers the last 35 of the 90 miles between Victorville and Anaheim. Benefits attributable to the Maglev system versus the No-Build along this segment are estimated to amount to nearly $6.8 billion in savings from reduced delay and accidents, over the project study evaluation period, 2010 and 2050. Furthermore, the Maglev system will reduce between 28,000 and 42,000 daily person trips from area freeways over the period respectively. These diversions would also result in the following benefits:
• Reduction in Vehicle Miles Traveled (VMT) is projected to be approximately 744 thousand daily and 267 million annually.
• Reduction in Vehicle Hours Traveled (VHT) is projected to be approximately 55,000 daily and 20 million annually.
• The impact of these diversions was monetized and results showed that the value of delays saved varied from $205 million in 2010 to $247 million in 2050.
• Fatality savings would range between about $3 million per year in 2010 to about $5 million in 2050.
2000 California-Nevada interstate Maglev Project, Project Description, submitted to the FRA; 2003 California-Nevada interstate Maglev Project, Anaheim to Ontario Study, submitted to the FRA.

Over the last year, since being elected an Assemblyman, I’ve strived to meet my commitment to regularly reach-out to constituents – to be accessible to citizens throughout the High Desert. Through one-on-one meetings, community events, town halls and many other activities, the people I meet and the stories I hear of perseverance through the adversity in our economic downturn are uplifting and at the same time disheartening. By far, the loudest message I hear from citizens and business owners alike is that the state’s economy and jobs are priority one.
I’m confident that California’s resilient business men and women are ready and willing to create the jobs we desperately need to boost our state’s economy. They just want one thing from the rest of us to get the ball rolling: for California government to get out of the way and let employers do what only they can do – be competitive, make a profit, expand and hire people.
Regrettably, California has a longstanding practice of smothering businesses with excessive rules and regulations and unreasonable taxes and fees. Our government has created this hostile business environment that discourages employers, large and small, from moving to or investing in our state because the risk of failure is significantly higher than other states.
Businesspeople know what it takes to succeed; their livelihood depends on it. Unlike many bureaucrats and some legislators, who believe that government knows best, never makes mistakes, and can create a thriving economy and more jobs by throwing around stacks of taxpayer dollars.
At one of my town halls, an audience member summed it up well when he said: “The bureaucracy is expanding to serve the expanding needs of the expanding bureaucracy.” The killing of California’s businesses and jobs didn’t start with the current recession. The process has been going on in our state for decades, one little law, rule, tax, fee, and regulation at a time. Taken individually, they may have seemed harmless at the time, but the cumulative effect leaves California with a dwindling pool of employers, few incentives to attract new businesses, and unemployment rates running over 20 percent in some parts of the state.
While nobody in the Legislature wants to take responsibility for killing jobs in California, citizens can see for themselves who voted for and against the job-killer bills. The pro-business California Chamber of Commerce maintains the voting records of all state legislators on bills identified as “Job Killers” and “Job Builders.” Go to to separate the political promises from the hard reality.
Jobs come from prosperity invested in private companies which produce goods and services to be sold around the world to finance further business growth and new jobs; That age-old process of commerce works without any help from the government. But the dependable private enterprise engines of economic prosperity can be shut down by unwise and unrealistic government policies.
Many businesses today are not hiring because owners and managers have no confidence in the job-killing, anti-business economic policies and practices at all levels of government. Bluntly, there is no incentive for a company to put its money at risk without a reasonable expectation of financial growth from the investment of time and money. Risk is a fact of life for business even in the best of times. But risk in a recession is logically far more difficult to take.
If we truly want to rebuild our economy and help the private sector provide wealth-producing jobs for our families, friends, and neighbors, then we must insist that our elected representatives work on unleashing the spirit of free enterprise that made California green and golden. And we must all work to reduce spending by eliminating unnecessary and duplicative programs, services, and regulations, and by making the remaining programs efficient and cost-effective.
Cutting government spending opens the door to put more money back into the pockets of taxpayers, thereby giving Californians a real chance to stimulate the economy and create new jobs on their own. My confidence lies in the private-sector to create jobs that will better our State, not the lie that the State creates jobs.
Assemblyman Steve Knight, (R-Antelope Valley), represents the 36th Assembly District in the California Legislature, which includes many communities throughout the Antelope and Victor Valleys.

Air Quality Politics

MDAQMD Urges Governor To Reconsider AB 32

Published by:

By Eldon Heaston
Executive Director, MDAQMD

The Mojave Desert Air Quality Management District has always strived to lead by example and takes great pride in its role as a leader among local regulatory agencies. In 2003, the MDAQMD was the first public agency in the High Desert to install its own solar electric generating system to meet almost half of the energy needs of its Victorville headquarters. In 2006, the MDAQMD became the first air district in the state to join the Climate Action Reserve and voluntarily certify its own carbon emission reductions. On February 3, 2010, the MDAQMD became the first air district in the state to write a letter to Governor Schwarzenegger and legislators, urging them to reconsider moving forward with regulations under AB32 until a careful review of the implementation impacts on California’s existing regulatory scheme and its struggling economy could be undertaken.

Although our governing board’s position on AB 32 has not exactly made us the darling of the state or other air districts, we have been encouraged by the overwhelming support we have received from local municipalities, businesses, and everyday citizens of the High Desert. These entities understand that the MDAQMD’s position is not based on the science of global warming – it’s based on the High Desert’s economic future and the possibility that our region may not survive the mounting regulatory gridlock which threatens to cripple our struggling economy and hinder our agency’s ability to adequately protect local air quality and the health of our residents.

While the MDAQMD believes the goals of many of the legislative and regulative enactments behind AB32 are laudable and necessary, we are also finding that in an area of unique economic and regulatory challenges – such as the High Desert – there are serious conflicts among existing and potential proposed regulatory programs.

To begin with, there is the unique issue of transported pollution which overwhelmingly impacts air quality readings measured within the MDAQMD’s jurisdiction. CARB studies have demonstrated that were it not for windblown pollution originating outside of the MDAQMD’s boundaries – primarily in the Los Angeles basin – our area would rarely, if ever, exceed state and federal ozone standards. Unfortunately, the Federal Clean Air Act does not consider the source of pollution, just where the exceedances of the standards happen to be measured. As a result, businesses in the MDAQMD are already subject to costly and stringent New Source Review requirements, which require them to obtain non-existent pollution offsets before they are allowed to locate or expand within our jurisdiction. This requirement – which is precipitated by out-of area smog over which the MDAQMD has no control – has historically forced many an industry to look elsewhere to site its business – often out of state – primarily because we have very few existing industries in the High Desert to provide such offsets through emission reductions.

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Having businesses and the jobs circumvent your region is never a good thing, particularly in an area such as the High Desert, where the average unemployment rate currently looms at 16.6%. The MDAQMD believes that any additional mandates which impose even more stringent requirements and higher fees on local industry will put us at a further competitive disadvantage with neighboring states, which are not regulating greenhouse gasses as stringently, if at all. For this reason, we also believe that the state should delay full implementation of AB32 and consider allowing GHG regulation to occur at the federal level, when the time is right, which insures uniformity between states as opposed to economic disparity and unfair competition. Basically, we support waiting until the playing field is leveled so that both the environment and the economy will benefit. In this vein, the MDAQMD also strongly supports NSR reform and a reopening of the Federal Clean Air Act to correct the plethora of existing problems with both permitting and PSD requirements.

The severe jobs/housing imbalance which exists within the MDAQMD represents a major economic and air quality challenge, in that this imbalance – and the inordinate commuter miles it requires – is also the major source of air emissions and GHGs within the MDAQMD. Surveys show that nearly 50% of High Desert residents commute at least 40 miles each way to work, with many more traveling over 100 miles one way daily. It is estimated that over 200,000 cars travel in and out of the MDAQMD’s jurisdiction each and every work day, often in heavy traffic. Thus, the MDAQMD cannot support any law which has the effect of discouraging business from establishing locally, forcing local residents to commute unnecessarily and consequently increasing air emissions in both our district and elsewhere. It is the MDAQMD’s belief that truly “green cities” will not be possible until we can site jobs in those cities.

In our letter to the Governor, the MDAQMD expressed concerns regarding the layers of conflicting land use mandates, CEQA and other regulatory air quality requirements and policy goals which may potentially come into direct conflict with current state laws and regulations, as well as proposed regulatory measures developed to implement AB32. These mandates include a proposed tightening of the National Ambient Air Quality Standards for Ozone and the USEPA’s recent “Endangerment Finding,” which states that “greenhouse gases threaten the public health and welfare of the American people.” Even closer to home, recent proposals to amend California’s Desert Protection Act pose a threat to the area’s economic and air quality future by severely restricting construction of clean and essential energy generation facilities in the place where they make the most sense: the Mojave Desert, which ranks second only to the Sahara Desert in solar radiation. Clearly, this type of gridlock does not seem to make sense for the environment or the economy.

Over the past 30-plus year, California has made great strides in its efforts to reduce air pollution. Despite the impacts of transported smog, the High Desert’s air quality continues to improve, thanks in large part to emission reduction progress made in the South Coast Air Basin. Even as these improvements continue, conflicting and onerous regulatory requirements threaten to cripple economic growth.

In light of the current economic and regulatory situation, the MDAQMD believes that there will be a time and place for AB32 implementation, but we do not believe that now – during the worst economic climate since the Great Depression – is that time. We are troubled that if we do not proceed with caution at this delicate juncture and fail to clearly set forth our priorities and carefully examine potential conflicts between regulatory programs at both the state and federal Levels, we may make some apparent gains in one area while jeopardizing progress in another. What we are suggesting is not without precedent. The governor’s office and the legislature has waived CEQA and other requirements in order to site football stadiums, finding that there is something very dysfunctional about the California regulatory requirements for projects. We would hope that this region’s air quality and its economy are due the same deference.