The California state environmental requirements (CEQA) are usually more stringent than Federal - many more projects are exempt from NEPA than from CEQA. But if something's NOT exempt from NEPA it can get more complicated quickly due to overlapping permitting and interagency consultation programs. If FRA has to approve it, NEPA applies since they're a federal agency (but they couldn't care less about CEQA work - state stuff doesn't apply to them). As a practical matter, I've seen many projects that have Mitigated NDs or EIRs for CEQA but are exempt under NEPA, including at FRA.

Why environmental for double-tracking in existing r/w? Because it "may" have an impact on the environment and a California government agency is doing it or approving it. That's what the (state) law says. Also, it most likely would *not* be entirely within existing r/w - minor tweaks here and there, station improvements, parking lots, etc. could require more land. Done right, though, those should not be issues, but do need the paperwork.

HOWEVER, JB has been heard to say that he never saw a CEQA exemption he didn't like. The legislature can grant them (statutory exemptions - long list in CEQA). Several stadium projects have gotten them. So why not lobby for one for ACE? Would make plenty of sense to me.

BTW, I wonder if the ACE project gets much if any gas tax funding? ACEForward's web site doesn't talk about funding much, at least in the first level or 2 of pages. If it doesn't use state gas tax funds, the new increases won't help it. Need to do some more webdigging, or does Transportation Planner have the inside scoop?