Fall 2024

On the Right Track: Federal Incentives Finally Landing Investment in American High-Speed Rail

By: Cesar Pereira, Special Counsel, Sheppard Mullin, and Mitchell M. Bower, Staff Attorney, Sheppard Mullin

American railroads have historically served as a national circulatory system - networks of rails flowing to and through metropolitan hubs and vast countryside, tying cities across the country together. Today, though highways and airports have become the standards of passenger travel, high-speed rail offers modern competitive means of passenger transport and have placed railways back on the forefront of infrastructure initiatives. The United States has been wary of adopting high-speed rails in the same manner as European and Asian nations and has, instead, prioritized roads and highways. But high-speed rails offer many unique benefits such as reduced highway congestion, significantly lower carbon emissions, and lower land usage. Now, in 2024, several high-speed rail projects have been launched into realization, with private and public actors alike taking unprecedented leaps toward the future of American railways.

 

Though the United States was once a nation of bustling and robust railway usage, decline in passenger count became apparent over the course of the 20th century and reduction in funding and expansion followed.[i] According to a 2019 study of 141 nations conducted by Swiss nonprofit World Economic Forum seeking to compare the competitiveness of national economies, the U.S. ranked second only behind Singapore for overall economic competitiveness, but fell notably behind in certain transportation-related areas of focus.[ii] The U.S. ranked 48th overall in railroad density and 12th overall in efficiency of train services.[iii] As for railroad density, it should be understood that the population spread of the United States is much broader and less dense overall than other wealthy nations to which it was compared.[iv] However, the U.S. ranked first (tying with several other nations) for both road connectivity and airport connectivity, demonstrating that the size and population sprawl of the United States should not necessarily rule out its ability to implement effective and efficient mass passenger transit – especially with respect to railways.[v]

 

The “IIJA”  and “STIA” - the 2021 Infrastructure Enactments

 

Perhaps one of the most ambitious recent efforts to breathe new life into American railways has been the passage of the 2021 Infrastructure Investment and Jobs Act (the “IIJA”). The IIJA aimed to revive American infrastructure, expand union employment on federally funded projects, and reconfigure federally regulated aspects of transportation and infrastructure.[vi] Included within the IIJA was the Surface Transportation Investment Act of 2021 (the “STIA”), which delegated robust funding for railways throughout the United States.[vii] Though the majority of the funding within the STIA was intended to revive and improve existing Amtrak corridors, the STIA further authorized appropriation of substantial funds to the United States Department of Transportation (“USDOT”) for Consolidated Rail Infrastructure and Safety Improvement Grants, as well as federal-state Partnership for Intercity Passenger Rail Grants.[viii] The IIJA effectively doubled USDOT’s private bond capacity from $15B to $30B and it offers access to tax-exempt bonds for privately funded transportation projects, which can reduce the borrower’s interest rate.[ix] USDOT has already entered into federal-state projects in furtherance of the initiatives set forth in the IIJA, including further funding for the ongoing California High-Speed Rail project, for which it announced an award of $3.1B in December 2023.[x] The California Rail Authority plans to use some of the funds it has received from the federal government to purchase six electric trains with the goal of reaching speeds of up to 220mph.[xi]

 

Recent History of Federal Funding Support – and Opposition – for High-speed Rail

 

Though the IIJA surely takes ambitious new steps in allocating more federal funding than previously seen for high-speed rail development and improvements to rail infrastructure as a whole, federal investment in railways is not a novel concept in recent decades. In 1993, the Clinton administration announced a five-year $1.3B plan to create a federal-state partnership to develop high-speed rail service to densely populated areas throughout the nation, marking the first instance of federal support for high-speed rail service outside the Northeast Corridor.[xii] The 1993 Clinton plan sought to make $982M available to state and local governments for high-speed rail improvement projects, $25M for applied research to insure rail-related advances are incorporated into high-speed rail development, and an ambitious $300M toward a prototype train that floats above the tracks on a magnetic cushion.[xiii] While a floating train prototype did not materialize, Amtrak announced the Acela Express line serving the Northeast Corridor in 2000, marking a step forward for high-speed passenger rail development.[xiv]

 

Similarly, in 2009 the Obama administration announced a long-term plan towards expanding high-speed rails in the United States, followed by a 2010 award of $8B through the American Recovery and Reinvestment Act to states across the country to develop America’s first nationwide program of high-speed intercity passenger rail service.[xv] The 2010 funding award sought to put the United States in rank with China and wealthy European nations whose robust national rail systems had already expanded into high-speed development.[xvi] Similarly, while not focusing specifically on high-speed rail development, the Trump administration was no stranger to rail funding, with a 2018 $908M investment in a 26-mile extension of the Cotton Belt Corridor from Dallas-Fort Worth International Airport to eastern Plano/Richardson, Texas.[xvii] The administration announced in 2020 more funding for several railway projects in Arizona, Indiana, Oregon, and an international line connecting Alaska and Alberta, Canada.[xviii][xix]

 

While prior administrations have acknowledged the importance of offering high-speed rail service to American rail commuters, those efforts have faced a fair share of pushback. For example, the Bush administration’s blueprint for the 2006 budget aimed to zero out Amtrak’s federal $1.2B subsidy, with supporters of the funding cut arguing that many states that would be effectively left without any rail service would fare just as well with access to cars, buses, and airports.[xx][xxi] Some critics also pushed the view that substantial federal investment into railways such as Amtrak posed a fairness issue, as the wide majority of Americans had never taken an Amtrak train.[xxii] The Trump administration’s 2017 budget echoed some of these sentiments in seeking to reduce allotments to railways such as Amtrak due to claims of inefficiency, excess cost, poor performance, and low passenger counts.[xxiii] In 2019, the Trump administration withdrew nearly $1B of funding to the California High-Speed Rail Authority, citing the Authority’s continued failure to meet deadlines set forth in a 2010 federal-state agreement, and overall failure to make reasonable progress on the project.[xxiv] Yet, while federal funding of rail projects has been met with its fair share of opposition, recent steps toward actualizing results in large-scale rail projects have been taken, and plans for future endeavors continue to develop.

 

Beyond advancing some localized high-speed rail projects, the federal-state Partnership for Intercity Passenger Rail Grants awarded $8B in funding from the Federal Railroad Administration for ten projects across nearly as many states for two high-speed rail corridors as well as improvements in service and performance of other existing corridors.[xxv] Sixty-nine rail corridors across forty-four states have been identified for future projects.[xxvi] This announcement comes shortly after a November 2023 announcement from the Federal Railroad Administration of $16.4B in funding for twenty-five projects along the Amtrak Northeast Corridor, $1B for construction of a new passenger rail route from Raleigh, NC to Richmond, VA along the CSX Transportation S-Line, and an extension of the Piedmont Corridor running across central North Carolina from Raleigh to Charlotte.[xxvii] [xxviii] Additional awards include $49.6M to Amtrak for improvements to mail platforms at Chicago Union Station, $44M to expand passenger platforms at Chicago Union Station, $143.6M allotted to the Pittsburgh/Harrisburg, PA route, and $27.5M to the Northern New England Passenger Rail Authority for a connection between Brunswick, ME and Massachusetts along the CSX Transportation line.[xxix] While the goal of California’s high-speed rail is still one to look forward to, there is no question that the effects of the IIJA have already seeped across the continent to revive several key stretches of rail.

 

Current High-Speed Rail Infrastructure Priority Projects

 

In December 2023, USDOT announced an award of $3.1B for the ongoing California High-Speed Rail project, in addition to $3B toward the construction of the anticipated Brightline high-speed rail project linking Las Vegas to Rancho Cucamonga in Southern California.[xxx] From Rancho Cucamonga, passengers will have access to Los Angeles Union Station via the Metrolink Regional Railway.[xxxi] As of December 2023, USDOT also awarded an additional $3B in the IIJA funding for the project to the Nevada Department of Transportation.[xxxii] Future plans include an electric line from San Diego running north along two lines to Sacramento and San Francisco.[xxxiii] In June 2023, USDOT awarded a $25M Rebuilding American Infrastructure with Sustainability and Equity (RAISE) grant to the San Bernardino County Transportation Authority to help finance the Hesperia and Victor Valley stations along the anticipated Brightline route.[xxxiv]

 

As for the California High-Speed Rail project, officials have approved a spending increase from $17.9B to $20B for the Merced to Bakersfield portion, estimating that the total cost could run anywhere from $25.6B to $35.3B.[xxxv] But despite the project’s intimidating price tag, many are optimistic with the progress being made and see the pieces slowly (but surely) falling into place. As of 2023, California had completed work on 10 structures associated with the California High-Speed Rail and has received environmental clearance for nearly 423 miles of the planned 500 miles of the rail line.[xxxvi] The state has also touted the project’s involvement of over 10,000 union workers.[xxxvii]

 

The Brightline West high-speed rail will span nearly 218 miles primarily along the I-15 median in Southern California, with an estimated $12B price tag.[xxxviii] On January 23, 2024, USDOT announced that it would be contributing $2.5B to the project in private activity bonds.[xxxix] As a high-speed rail, trains could reach speeds of 186mph, reducing the Las Vegas to Rancho Cucamonga commute from a nearly five-hour drive to a two hour train ride.[xl] The current plans for the Brightline West rail include trains to be powered by electricity and zero carbon emissions, which tout a massive reduction in environmental impact compared to highway automobile travel.[xli]

 

Plans for a high-speed rail project connecting Dallas and Houston, Texas have also been revived after a tumultuous few years.[xlii] Though initial plans released by Texas Central Partners aimed to keep the entire project privately funded, the developer has focused on strengthening its relationship with Amtrak and has submitted various applications for federal grants relating to further study and design work for the project.[xliii]

 

The IIJA has made strides in putting railroads back into focus in the national infrastructure conversation. While previous administrations have taken steps toward rejuvenating the railways, no legislation has come close to the IIJA’s ambitious budget  in what it allots to American rails. Work is under way and big players can sit with an optimistic glimpse of the future knowing the priority that has been placed on these projects. But putting the funding aside, it is worth considering what other issues could threaten the success of these projects.

 

Support for investments in ambitious high-speed rail projects has been met with equal political dissent. As mentioned above, nearly a decade after USDOT entered into a 2010 agreement with the California High-Speed Rail Authority for the construction of a 119-mile stretch to be completed by 2022, the agency withdrew nearly $1B in funding, citing a lack of progress being made on the project.[xliv][xlv] Many have also criticized the location of the anticipated California High-Speed rail, stretching through the flat and rural California Central Valley from Merced to Bakersfield as a “train to nowhere.”[xlvi] Such critics are skeptical that any notable portion of the commuting public would immediately draw any real benefit from the completion of the route.[xlvii]

 

Industry pushback from other transportation lobbies has historically proven effective in impeding progress on high-speed rails in the United States. A 1991 plan in Texas for a conglomeration of private actors sought to connect Houston, Dallas/Fort Worth, and San Antonio with a privately financed high speed rail system.[xlviii] However, the project was estimated to cost $5.6B and would come entirely from private sources due to state restrictions on use of public funds.[xlix] Various lobbies, including airlines, fast food establishments, and hotel chains, all fought against the plan because their locations were along highways and this new method of affordable and efficient mass passenger transit directly threatened their investments in their respective markets.[l] The project was canceled shortly afterward in 1994.[li]

 

Backlash against such high-speed rail projects has also been present in the private sector, where outspoken personalities such as Elon Musk have called upon legislators to simply pull the plug on the California High-Speed rail. Musk has relented against the effectiveness of public transportation and proposed in 2013 that a more efficient use of resources would be to research his proposed Hyperloop – a system of tubes in which pressurized passenger capsules could hypothetically travel through a partial vacuum reaching speeds of up to 700mph).[lii] Musk has also been a staunch promoter of automobile tunnels, a field in which his Boring Company specializes, as a more efficient means of fast and reliable transportation.[liii] However, despite such pushback, the Brightline West rail has chugged on and finally broke ground early this year.[liv] Conversely, as of December 2023, Musk’s company, Hyperloop One, officially closed up shop.[lv]

 

Finally, as with any massive infrastructure project, there are countless other issues that could potentially derail progress. Needs for further property acquisition could present delays, as could awaiting results on mandatory environmental studies and regulatory approvals – an area in which California is known to have particularly stringent requirements.[lvi][lvii] Additionally, cost overruns and potential lawsuits are always of concern when dealing with projects of this magnitude. But as of mid-2023, 422 miles of the 500-mile stretch had been environmentally cleared and 119 miles of track were under active construction – a massive step in the right direction for the California High-Speed Rail.[lviii] Current plans anticipate further heavy construction commencing in 2025.[lix]

 

Despite immense hurdles, the Brightline West project officially broke ground in April 2024.[lx] While the project’s general contractor has not been announced, Brightline has elected for the civil and rail infrastructure portions of the project to be led by HNTB in California and Jacobs in Nevada.[lxi] In May 2024, Siemens Mobility was announced as the “preferred bidder” for the manufacture of the project’s high speed train sets.[lxii] Most recently, on September 26, 2024, the FRA officially signed the $3B grant agreement with the NDOT with Brightline West that was announced by President Biden in December 2023, representing to Americans that the next step in advanced infrastructure is finally within reach.[lxiii] And the operation of the Brightline West rail couldn’t come at a more convenient time for Southern California. Eyeing a 2028 completion date, the project anticipates operation commencing in time for the Los Angeles Olympic games.[lxiv] The California High-Speed Rail and the Brightline West rail symbolize the next steps forward for passenger transit in Southern California and across the United States.


[i] Adam Burns, The Decline of Rail Travel (USA): Three Decades of Turmoil, American Rails (May 7, 2023), https://www.american-rails.com/decline.html.

[ii] Id.

[iii] Id.

[iv] Id.

[v] Id.

[vi] The White House, UPDATED FACT SHEET: Bipartisan Infrastructure Investment and Jobs Act, The White House (Aug. 2, 2021), https://www.whitehouse.gov/briefing-room/statements-releases/2021/08/02/updated-fact-sheet-bipartisan-infrastructure-investment-and-jobs-act/.

[vii] Infrastructure Investment and Jobs Act, PL 117-58, 135 Stat. 429, November 15, 2021

[viii] Id.

[ix] Tom Ichniowski, US DOT Approves $2.5B for Vegas-to-California High-Speed Rail, Engineering News-Record (Jan. 23, 2024), https://www.enr.com/articles/58019-us-dot-approves-25b-for-vegas-to-california-high-speed-rail.

[x] James Leggate, US DOT Awards $6B in Grants for Two California High-speed Rail Projects, Engineering News-Record (Dec. 6, 2023), https://www.enr.com/articles/57779-us-dot-awards-6b-in-grants-for-two-california-high-speed-rail-projects.

[xi] Derek Lacey, ‘Historic’ $8B in Grants Will Fund US Passenger Rail Expansion, Engineering News-Record (Dec. 8, 2023), https://www.enr.com/articles/57834-historic-8b-in-grants-will-fund-us-passenger-rail-expansion.

[xii] Martin Tolchin, Administration Unveils $1.3 Billion High-Speed Rail Proposal, The New York Times, (Apr. 29, 1993), at 10.

[xiii] Id.

[xiv] Supporting Passenger Rail for Our Nation’s Transportation Future, Feb. 28, 2000, https://clintonwhitehouse5.archives.gov/WH/New/html/20000228_1.html.

[xv] Obama announces $8 billion investment in high-speed train system, CNN.com (Jan. 28, 2010), https://www.cnn.com/2010/POLITICS/01/28/obama.trains/index.html.

[xvi] President Obama, Vice President Biden to Announce $8 Billion for High-Speed Rail Projects Across the Country, Whitehouse.Gov (Jan. 28, 2010), https://obamawhitehouse.archives.gov/the-press-office/president-obama-vice-president-biden-announce-8-billion-high-speed-rail-projects-ac.

[xvii] U.S. Department of Transportation Announces $908 Million Loan to Finance the Cotton Belt Corridor Regional Rail Project, US Department of Transportation (Mar. 22, 2018), https://www.transportation.gov/briefing-room/us-department-transportation-announces-908-million-loan-finance-cotton-belt-corridor.

[xviii] Angela Cotey, Trump tweets announce funding for tail projects in Arizona, Indiana, Oregon, Trains (May 29, 2020), https://www.trains.com/trn/news-reviews/news-wire/29-trump-tweets-announce-funding-for-rail-projects-in-arizona-indiana-oregon/.

[xix] Sarah Rieger, Trump to approve $22B railway between Alaska and Alberta, CBC News (Sept. 28, 2020), https://www.cbc.ca/news/canada/calgary/a2a-railway-1.5740678.

[xx] M. Rupert, House panel votes to slash Amtrak subsidy, Washington Examiner (May 29, 2006), https://www.washingtonexaminer.com/news/121093/house-panel-votes-to-slash-amtrak-subsidy/.

[xxi] Matthew L Wald, Bush to Propose Elimination of Federal Subsidy for Amtrak, The New York Times, (Feb. 2, 2005), at 17.

[xxii] Martin Wolk, Amtrak on the Chopping Block - Again, MSNBC, (Feb. 10, 2005).

[xxiii] Ilaria Grasso, What has Trump Done for the U.S. Rail Industry?, Railway Technology (Oct. 26, 2020), https://www.railway-technology.com/features/what-has-trump-done-for-the-us-rail-industry/?cf-view.

[xxiv] Id.

[xxv] Derek Lacey, ‘Historic’ $8B in Grants Will Fund US Passenger Rail Expansion, Engineering News-Record (Dec. 8, 2023), https://www.enr.com/articles/57834-historic-8b-in-grants-will-fund-us-passenger-rail-expansion.

[xxvi] Id.

[xxvii] President Biden Advances Vision for World Class Passenger Rail with $16 Billion Investment in America’s Busiest Corridor, US Department of Transportation (Mar. 22, 2023), https://www.transportation.gov/briefing-room/president-biden-advances-vision-world-class-passenger-rail-16-billion-investment.

[xxviii] Derek Lacey, ‘Historic’ $8B in Grants Will Fund US Passenger Rail Expansion, Engineering News-Record (Dec. 8, 2023), https://www.enr.com/articles/57834-historic-8b-in-grants-will-fund-us-passenger-rail-expansion.

[xxix] Id.

[xxx] James Leggate, US DOT Awards $6B in Grants for Two California High-speed Rail Projects, Engineering News-Record (Dec. 6, 2023), https://www.enr.com/articles/57779-us-dot-awards-6b-in-grants-for-two-california-high-speed-rail-projects.

[xxxi] Id.

[xxxii] Tom Ichniowski, US DOT Approves $2.5B for Vegas-to-California High-Speed Rail, Engineering News-Record (Jan. 23, 2024), https://www.enr.com/articles/58019-us-dot-approves-25b-for-vegas-to-california-high-speed-rail.

[xxxiii] James Leggate, US DOT Awards $6B in Grants for Two California High-speed Rail Projects, Engineering News-Record (Dec. 6, 2023), https://www.enr.com/articles/57779-us-dot-awards-6b-in-grants-for-two-california-high-speed-rail-projects.

[xxxiv] Tom Ichniowski, US DOT Approves $2.5B for Vegas-to-California High-Speed Rail, Engineering News-Record (Jan. 23, 2024), https://www.enr.com/articles/58019-us-dot-approves-25b-for-vegas-to-california-high-speed-rail.

[xxxv] James Leggate, US DOT Awards $6B in Grants for Two California High-speed Rail Projects, Engineering News-Record (Dec. 6, 2023), https://www.enr.com/articles/57779-us-dot-awards-6b-in-grants-for-two-california-high-speed-rail-projects.

[xxxvi] NEWS RELEASE: California High-Speed Rail Releases Final Environmental Studies to Finalize Project Alignment into San Francisco, California High Speed Rail (June 10, 2022), https://hsr.ca.gov/2022/06/10/california-high-speed-rail-releases-final-environmental-studies-to-finalize-project-alignment-into-san-francisco/.

[xxxvii] James Leggate, US DOT Awards $6B in Grants for Two California High-speed Rail Projects, Engineering News-Record (Dec. 6, 2023), https://www.enr.com/articles/57779-us-dot-awards-6b-in-grants-for-two-california-high-speed-rail-projects.

[xxxviii] Tom Ichniowski, US DOT Approves $2.5B for Vegas-to-California High-Speed Rail, Engineering News-Record (Jan. 23, 2024), https://www.enr.com/articles/58019-us-dot-approves-25b-for-vegas-to-california-high-speed-rail.

[xxxix] Id.

[xl] Id.

[xli] Id.

[xlii] Daniel Tyson, Texas Planned High-Speed Rail Inches Forward, Despite Earlier Trouble, Engineering News-Record (Mar. 12, 2024), https://www.enr.com/articles/58296-texas-planned-high-speed-rail-inches-forward-despite-earlier-trouble.

[xliii] Texas Central and Amtrak Seek to Explore High-Speed Rail Service Opportunities Between Dallas and Houston, Amtrak Media Center (Aug. 9, 2023), https://media.amtrak.com/2023/08/texas-central-and-amtrak-seek-to-explore-high-speed-rail-service-opportunities-between-dallas-and-houston/.

[xliv] Richard Simon, California to get $2.25 Billion in High-Speed Rail Funding, Los Angeles Times, (Jan. 28, 2010).

[xlv] Kathleen Ronayne, Trump administration pulls $1B from California rail project, AP News (May 17, 2019), https://apnews.com/article/7a9b03eed47a44c986a1a2f06d0a6c4e.

[xlvi] Andrew Gumbel, Train to nowhere: can Californias high-speed rail project ever get back on track?, The Guardian (May 29, 2022), https://www.theguardian.com/us-news/2022/may/29/california-high-speed-rail-bullet-train.

[xlvii] Id.

[xlviii] Brian Potter, The Long, Sad History of American Attempts to Build High-Speed Rail, Part II, Construction Physics (Oct. 19, 2023), https://www.construction-physics.com/p/the-long-sad-history-of-american-971.

[xlix] Id.

[l] Id.

[li] Id.

[lii] Bob Sorokanich, Did Musk Propose Hyperloop to Stop California High-Speed Rail?, (Aug. 11, 2022), https://jalopnik.com/did-musk-propose-hyperloop-to-stop-california-high-spee-1849402460.

[liii] Luke Fortney, The Boring Company: What It Is, Products, and the Elon Musk Factor, Investopedia (Jan. 15, 2023), https://www.investopedia.com/what-is-the-boring-company-4581757.

[liv] Greg Aragon, $12B Las Vegas to Southern California High-speed Rail Launches, Engineering News-Record (Apr. 23, 2024), https://www.enr.com/articles/58503-12b-las-vegas-to-southern-california-high-speed-rail-launches.

[lv] "Sean O’Kane, Hyperloop’s loss is high-speed rail’s gain, TechCrunch (Dec. 22, 2023), https://techcrunch.com/2023/12/22/hyperloop-one-elon-musk-high-speed-rail/?guccounter=1&guce_referrer=aHR0cHM6Ly93d3cuYmluZy5jb20v&guce_referrer_sig=AQAAAKGxFVgoyVDH8I8MK8a4Kf8MFTrE59uaUSKueCatvnqReLsjgQluOXkxaN2f-_inuZrP--Wvus8EqoIEdxKBSUbWHZfA5L9whtf9bovVHAmc10qrIJceTwd0ZJu_v5LHWsczVfBDPiT3HlPEbeEQsnDDRZTrtL4gp1u2gsc1Za5d.

[lvi] Tim Sheehan, California's high-speed rail project still needs to purchase hundreds of pieces of land, The Fresno Bee (Dec. 17, 2021), https://www.fresnobee.com/news/local/high-speed-rail/article256650307.html.

[lvii] Getting in Its Own Way: Behind California's CEQA Curtain, Holland & Knight LLP, https://www.hklaw.com/en/case-studies/getting-in-its-own-way-behind-californias-ceqa-curtain.

[lviii] Advancing Statewide: Progress in the Central Valley, Northern and Southern California, California High-Speed Rail Authority, https://hsr.ca.gov/about/project-update-reports/2023-project-update-report/chapter-4/.

[lix] Mick Akers, Brightline’s Vegas-to-LA project advances; heavy construction to begin in 2025, Local (Sept. 26, 2024), https://www.reviewjournal.com/local/traffic/brightline-wests-3b-high-speed-rail-grant-signed-heavy-construction-to-begin-in-2025-3177566/.

[lx] Greg Aragon, $12B Las Vegas to Southern California High-speed Rail Launches, Engineering News-Record (Apr. 23, 2024), https://www.enr.com/articles/58503-12b-las-vegas-to-southern-california-high-speed-rail-launches.

[lxi] Id.

[lxii] BRIGHTLINE WEST SELECTS SIEMENS TO MANUFACTURE HIGH SPEED RAIL TRAIN SETS, Brightline (May 1, 2024), https://www.gobrightline.com/press-room/2024/brightline-west-selects-siemens-to-manufacture-high-speed-rail-train-sets.

[lxiii] Signed, Sealed and Delivered: $3 Billion Grant Agreement for Brightline West Project Officially Signed, Brightline West (Sept. 26, 2024), https://www.brightlinewest.com/media/press-releases/2024/signed-sealed-and-delivered-3-billion-grant-agreement-for-brightline-west-project-officially-signed.

[lxiv] Greg Aragon, $12B Las Vegas to Southern California High-speed Rail Launches, Engineering News-Record (Apr. 23, 2024), https://www.enr.com/articles/58503-12b-las-vegas-to-southern-california-high-speed-rail-launches.

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