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DEIS, AAF publicly shifted the opening date to 2017 even though the DEIS was keyed to 2016. See Orlando Business journal, "3 Reasons Idly All Aboard Florida in Orlando lYlas Delayed' (7/9/2014). However, even 2017 seems like a pipedream, given the long list of items that must be satisfied and the sheer magnitude of the construction that must be completed before the system could become operational. See, e.g., id. (which notes that approval of new station at the Orlando Airport still has many hurdles to overcome and would take three years to construct from final approval). Utilization of an unrealistically early baseline year would result in the understatement of certain critical impacts, including and possibly most notably, noise. The reason for this is that the idance are based upon a sliding scale that is keyed to significance criteria set forth in the relevant gu ambient noise levels as they are expected to exist in the baseline year. See FRA's "High -Speed Ground Transportation Noise and Vibration Impact Assessment Guidance Manual' (the "FRA Noise Manual") at Chapter 3 (12/2012); FTA's "Transit Noise and Vibration Impact Assessment" at Chapter 3 (5/2006). Under those criteria, the higher the noise levels are during the baseline year, the lower the incremental increase need be to create a significant impact. Id As the DEIS indicates, freight and vehicular traffic are expected to increase along the FECR corridor in the coming years, and other projects (including but not limited to Tri -Rail Coastal Link) can be expected to come on-line in the near future. Accordingly, existing ambient noise will increase and the noise increment that would produce significant impacts will decrease as time goes on. Therefore, noise impacts may be understated if an unrealistically early baseline year is utilized in the analysis. For these reasons, FRA mit -grounded conceptual development schedule for should require AAF to prepare and sub the Proposed Project that either justifies utilization of the 2016 baseline year or provides for a more realistic timetable for completion. In the event a later baseline year is identified, the noise analysis must be revised to reflect background conditions in that year. In addition, as a result of the illusory 2016 build year the DEIS omitted any real discussion of construction, including its duration, sequencing, staging, techniques and impacts, claiming that the activities and impacts associated with building the Proposed Project would all be extremely short term. As discussed in the comments below, the details regarding the construction of this massive $1.875 billion dollar project, as well as the impacts that would be experienced during the period of construction, need to be brought to light and analyzed under a realistic construction schedule. There is a second fundamentally flawed assumption running through the DEIS analyses of noise, vibration and navigation, in that they focus on operations of the Proposed Project as of an opening fine is in full operation. Thus, day, rather than on operating conditions as they per bee number f trips needed to the DEIS assesses the effects of 16 round trips p y, which reflects service passenger demand as of 2016. According to the All Aboard Florida Ridership Revenue Study Summary Report prepared by the Louis Berger Group in September 2013 (the "LBG Study'), which is attached as Appendix 3.3.F to the DEIS, approximately 1 million riders are expected as of that year. However, the DEIS itself reports that ridership is expected to grow sharply in the first few years of operation, and level off at 3.5 million passengers as of 2019. 301 - A— Page 9 ' November 14, 2014 1824679