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4, Climate Change_: The DEIS Fails toe n the ProposedR' Legal Project igation to Adequately Analyze the Effects of Climate Chang The Proposed Project sponsors are seeking $1.875 billion in low interest federal loan funds to facilitate construction of a high speed rail line in a corridor that lies completely within Florida's coastal zone and skirts in and out of the existing flood plain along 128.5 miles ks thet by climate of Florida. Although the DEIS makes passing reference to the lantic Coast sorts o posed change in locating a major new transportation facility in that area, it provides no meaningful analysis of such risks or the alternatives or mitigating measures that might minimize or avoid them. Thus, the DEIS notes that "[t]ransportation systems [such as the Proposed Project] are vulnerable to ense storm extreme weather and climate change effects such o[t]hetN S and �1PB�M ts ." DEIS at 5-71. More particularly, the document acknowledges that n the near Corridors of the Project are vulnerable to climate changeeffects cfoastahwater bodies. Bridgeth of these structures, corridors are along the Florida coast and cross se with lower elevation, will have increased vulnerability over time, and potential particularly those result from flooding, tidal damage and/or storms." Id. at 5-73. infrastructure damage may ation of the vulnerability of the Nevertheless, the DEIS offers only the most cursory examin Proposed Project to sea level rise or the more intense storm surges the document itself acknowledges will occur in the near future. The DEIS subjects only two of the 18 bridge crossings uired for the N -S corridor to any sea level rise analysis at all, and with respect to those facilities it reqand simply compares their elevations to expected sea leves bridin OesOwould be undo water at high tide the DEIS finds that the bottom chord of one of theg during a 100 year storm in 2030, with no mention at all of impacts in 2060. Id. at 5-75. The vague is is that the "vulnerability [of the Proposed Project conclusion drawn from this lackluster analys bridges] will increase as sea level rises" and "there may be increasing periods of time where the train is out of service during storm events." Id. Nothing is said regarding the nature and extent of the property damage that may be caused to the bridge structures, or whether other components of the Proposed Project located within the substantially expanded future floodplain would also be at risk. Moreover, not a word is mentioned as to whether and how public safety would be put at risk in operating a high speed rail service within the corridor under such conditions, or mitigation opportunities. his issue stnds at s with firmly The truncated analysis presented in the DEIS with respect aoccounted foram agencydplanning. In established federal policy on how climate change Is to Ener President Obama's 2009 Executive Order ("E.O.") 13514 "Federal LeadershiWe e direct detoae�stabli, and Economic Performance," all federal agencies, 174 Fed. ng Reg. 5DO7,a5d 252124 (10/8/2009). The Climate Change Adaptation Plans. President subsequently instructed federal agencies to "ensure that climate risk -management considerations are fully integrated into federal infrastructure ... planning" in his "Climate Action Plan" issued in June 2013. Shortly thereafter, the President issued E.O. 13653, "Preparing the United States for the Impacts of Climate Change," which required all federal agencies to "reform policies and 5()j, f.\— Page 11 November 14, 2014 1824679