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Preliminag Project Development Report at 1-14. Moreover, this case is not a circumstance where the Tri - <br />ail Coastal Link project is so speculative as to preclude a meaningful cumulative impact analysis. <br />R <br />On the contrary, a wealth of detailed planning and environmental information has been available for <br />years, and that information should have been tapped in assessing the combined impacts of these <br />related projects and whether the Proposed Project, if approved, would adversely affect the operation <br />of the Tri -Rail Coastal Link. The DEIS is fundamentally flawed in that it failed to do so. <br />3. DEIS Assumptions: The DEIS is Based on an Unrealistic Build Year and Assesses <br />Critical Impacts Only on Opening Day, Thereby Failing to Analyze Projected Full <br />Operational Impacts <br />The analysis presented by the DEIS is founded upon fundamentally flawed assumptions that <br />provide no basis for an accurate projection of long-term impacts. <br />First, 2016 is not a proper baseline year for the mysis on thece that DEIS naDecember 20140 tyears <br />wholly <br />today. Given that FRA will be reviewing comm <br />unrealistic to believe that all of the following items can be completed by 2016: <br />• concluding the NEPA review process; <br />securing all permits and approvals, including those from the United States Army <br />Corps of Engineers, Federal Aviation Administration, United State Coastal Guard <br />("USCG"), Federal Highway Administration ("FHWA"), United States Fish and Wildlife <br />Service, National Marine Fishery Service, plus those from multiple state and local agencies; <br />finalizing all design documents; <br />letting all construction contracts; <br />• constructing: <br />o a new station in Orlando; <br />o a new vehicle maintenance facility; <br />o dozens of new overpasses, bridges, tunnels, ramps, and related infrastructure <br />and safety features; <br />highway -rail grade crossings, including designing <br />O upgrading/ expanding 170 <br />and installing safety infrastructure; and <br />o hundreds of miles of rail bed and new track; and <br />• performing diagnostic and system testing of all individual elements and system wide <br />operations for performance and safety. <br />Nothing in the DEISgives any indication that extraordinary arrangements have been put into place <br />to accomplish the tasks required for completion of the Proposed Project within such a compressed <br />timetable. In fact, the document does not even call for, or analyze, after-hours work during the <br />construction period. In light of the impossibility of meeting a 2016 opening date, prior to issuing the <br />301- A Page 8 November 14, 2014 <br />1824679 <br />