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development, including cost of land acquisitions, access, construction, and environmental mitigation." Id. at 3-2. The document then applies such "critical determining factors" to other available routes. Given the fact that AAF had already secured from its parent corporation the land interests needed for the Proposed Project, and AAF put forward a wholly unrealistic build year of 2016, it is no surprise that the analysis came to the preordained conclusion that all the other alternatives are so meritless as to not warrant substantive analysis in the DEIS. By creating a screen that is tilted in one direction only, the DEIS side-stepped the fact that the Florida High Speed Rail .Authority in a 2003 alternatives evaluation entitled "Orlando -Miami Planning Study "rated every other route as superior to the FECR corridor than would be used by the Proposed Project. That study compares the FECR route to three other potentially available north -south corridors in the following table: Route Travel Time Capital Cost Ridership / Revenue Environmental CSX Fair Good Fair Fair I-95 Good Fair Good Good Turnpike Good Good Fair Good FECR Poor Poor Good Poor Orlando -Miami Planning Study at 7. Thus, under three of the four criteria applied in that study -- travel time (a factor cited as critical in the DEIS on page 3-5), capital cost and environmental impacts -- the FECR corridor was rated at rock bottom. It is only in terms of revenue that the Proposed Project tied with another alternative and was rated favorably. Thus, if the DEIS were to look beyond the economic interests of AAF, the sponsor of the Proposed Project, to salient issues such as environmental impacts, other routes would certainly merit detailed consideration in the DEIS. However, those routes were ruled to be off limits under self-serving criteria of AAF's own devising. The truncated approach utilized in the DEIS does not conform to the requirements of NEPA for one fundamental reason: it is not the project sponsor's purpose and need that should control the alternatives analysis, but the agency's purpose and need in taking the action that is the subject of the NEPA review. Thus, AAF's desire to turn a profit should not dictate the alternatives considered by FRA in determining how it should expend federal rail funds. Guidance issued by CEQ states that "[i]n determining the scope of alternatives to be considered, the emphasis is on what is `reasonable' rather than on whether the proponent or applicant likes or is itself capable of carrying out a particular alternative. Reasonable alternatives include those that are practical or feasible from the 30Page 1824679 November 14, 2014