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1508.27(b)(7). These principles have been applied by the courts in numerous cases to invalidate EISs for failure to assess indirect and cumulative project impacts. Inexplicably, the DEIS makes no serious attempt to address the indirect or cumulative impacts that would result from the Proposed Project. For example, indirect or secondary impacts on land use are passed over with the statement that "[t]he project would not result in induced growth; no changes to land use due to induced growth would occur." DEIS at 5-4. Although the DEIS mentions that the Phase 1 Environmental Assessment ("EA") addressed "development in the vicinity of' the proposed stations in West Palm Beach, Fort Lauderdale and Miami, id. at 5-5, close examination of the information provided in that document, in light of other statements made by AAF, make clear that no meaningful attention has been paid to the secondary development associated with either phase of the Proposed Project. Thus, according to the DEIS, the EA indicated that "at West Palm Beach and Fort Lauderdale, there will be: 10,000 square feet of retail space within the station. At Miami, the Proposed Project would include 30,000 square feet of retail within the station, and additional 75,000 square feet of transit -oriented retail, 300,000 square feet of office space, 400 residential units, and a 200 -room hotel." Id. at 5-5. Indeed, the Phase 1 EA does recite the same information, and includes a bare - bones (and inadequate) analysis of the environmental impacts that would result from this development. However, nowhere in either the DEIS or the EA is any meaningful information or analysis provided concerning the additional development that would be induced by the Proposed Project and this transit oriented development. The obligation to address the potential effects of such induced development cannot be avoided on the basis that it is speculative. In a "Preliminary Offering Memorandum" dated June 4, 2014, AAF confirmed that there are current plans for construction going well beyond the ancillary development identified in the DEIS and EA, and that sufficient information with respect to such planned development is available for a thorough analysis of its impacts. In particular, that document disclosed that: (i) AAF owns 21 acres in the areas surrounding the proposed stations; (ii) that it anticipates demand for 3.5 million square feet of development on those parcels; and that it expects to build 2 million square feet of that new development contemporaneously with the Proposed Project. That initial development is to include 1.3 million square feet in Miami, and 345,000 square feet in both Palm Beach and Fort Lauderdale. AAF also believes there is demand for subsequent future development: totaling 1.5 million square feet including a 1.1 million square foot "super tower" for the area adjacent to the Miami station, and an additional 345,000 square feet of residential space in Fort Lauderdale. Thus, the development disclosed in the EA is a fraction of the currently planned and future development resulting from the Proposed Project. Given the specificity of RAF's articulated intentions, sufficient information is available for a detailed environmental review of the traffic, air pollution, construction, noise and neighborhood character impacts of this reasonably foreseeable future development. The DEIS is deficient in that it failed to include such a review. The DEIS is also lacking in its analysis of cumulative impacts. For example, it fails to address the cumulative impacts of the Proposed Project together with those of the Tri -Rail Coastal Link Project, 3014 — Page 6 1824679 November 14, 2014