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Moreover, what the DEIS does not mention is that the LBG Study predicts ridership levels for 2019 to range from a low of 3.5 million (in what is characterized as the "base case" which ignores developments that are "subject to some uncertainty"), to 4 million (in the "business plan case," which takes into account AAF's plan to expand ridership), to a high of 5.1 million in the "management case" (which accounts for more aggressive marketing strategies by AAF). Moreover, even in the "business plan case" the study predicts ridership to rise to approximately 5.5 million by 2030. LBG Study at 4-4. Thus, based upon AAF's own study, ridership is expected to be more than S times the ridership expected when service begins in 2016. Most of the operational impacts of rail projects — including but not limited to noise, vibration and navigation delays at draw bridges — are caused by train pass -by incidents. Since the significance of the impacts depends, in important part, upon the number of passbys, the adequacy of the analysis in an EIS for a rail project depends upon the accuracy of the prediction of how many passbys will occur. Under NEPA, an EIS must examine both the short-term impacts of a project, and also the reasonably foreseeable effects of that project over the long-term. Accordingly, the DEIS should have examined the anticipated effects of the Proposed Project not only upon the commencement of service but also over the longer term horizon. There is nothing in the DEIS to indicate that 16 round trips per day would meet ridership demand over the long term, or was properly used as the touchstone for the impacts analysis in the document.' The Board does not dispute the appropriateness of including in the DEIS an analysis of short-term operational impacts of the Proposed Project, utilizing a realistic commencement date baseline year. However, it believes that a second baseline year of 2030 or later must also be assessed to capture the long-term impacts of the Proposed Project, in combination with other projects expected to be on line as of that time. This is particularly important because it can reasonably be anticipated that the new two -track FECR corridor created by the Proposed Project will be much more heavily used at that time for both passenger and freight traffic. The DEIS itself indicates that freight traffic is expected to increase sharply upon completion of the Panama Canal improvements, DEIS at 5-17, and other projects such as Tri -Rail Coastal Link can be reasonably expected to be operational a few years after the Proposed Project comes on line. Since it fails to present such a "horizon year" analysis the DEIS is woefully deficient in its assessment of the long-term cumulative operational impacts of the Proposed Project on noise, vibration and other critical issues. ° The DEIS itself makes no mention of traffic and transportation impacts in any years other than 2016 and 2019. However, buried in Appendix 3.3 C, entitled "Grade Crossing Details," is a brief description of some limited analyses performed for both 2016 and 2036. As discussed below, that analysis was not only obscured by its placement in an appendix to the DEIS, it also revealed exceptionally significant impacts, the implications of which should have been disclosed and thoroughly examined in the DEIS. It should be noted that the discussion in that appendix indicates that there would be a range of 16-19 passbys per day. See, e.g, DEIS App. 3.3C at 4-1. 30 i — 1A —Page 10 1824679 November 14, 2014