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deficiencies are not corrected, billions of dollars in federal resources could be poured into a project that would be under an ever-increasing threat from future sea level rise and storm surges, with no serious attention paid to the ensuing consequences to public safety or the investment itself, and with no consideration paid to the measures that could be taken to avoid them. Indeed, according to the DEIS no action would be taken at all to assure that the Proposed Project is designed to withstand the future risks of sea level rise. On the contrary, AAF has announced its intention to build according to a construction design that would "maintain existing elevations where feasible," DEIS at S-14; and has specifically rejected the USCG request that alternatives be considered to raise the clearance beneath certain low bridges. Additionally, according to the DEIS, FRA has concluded that it would not be feasible to raise the clearance beneath certain bridges due to the significant delay it would cause to the Proposed Project, the overall costs and the risk associated with elevating the structures. Id. at 5-27.' One can only assume from this conclusion that the short-term success of the Proposed Project is.being given greater weight than the overall safety of the public and of the federal investment. Moreover, since other viable high speed routes were screened out of the analysis, no consideration whatsoever has been given to alternatives, such as the utilization of the interior CSX corridor for high speed rail, that would avoid such risks altogether. The effects of future sea level rise and storm surges on the Proposed Project are "reasonably foreseeable" impacts, and the DEIS was materially deficient in failing to address them. 5. Floodplains: Locating the Proposed Project in Floodplains Is Not Demonstrated to be the Only Practicable Alternative. The Proposed Project would result in the siting of long stretches of a multi -billion dollar high speed rail line in Florida's currently mapped floodplains, which can be expected to expand as a result of FEMA's ongoing "coastal flood risk study" for the East Coast of Central Florida. In addition, the Proposed Project's encroachment on floodplains would only increase with time as sea level continues to rise. FRA should not approve such a risky endeavor without first taking a hard look at other practicable alternatives, as required by the directives discussed below. The very real risks of floodplain encroachment to humans and infrastructure were first recognized by President Carter in E.O. 11988, "Floodplain Management," which was intended to "avoid [the federal government's] direct or indirect support of floodplain development wherever there is a practicable alternative." 42 Fed. Reg. 26951 (5/24/1977). This order requires federal agencies that propose to support or allow floodplain development to first consider alternatives to such development. Id. at 26952. As mandated by E.O. 11988, USDOT issued its own floodplain directive, which sets forth the department's policy with regard to floodplains. USDOT Order 5650.2 "Floodplain Management and Protection," (4/23/1979). Under that directive, all USDOT agencies, including FRA, must take certain steps before supporting a project that would result in a 5 This determination appears to the Board to be premature, since the NEPA process has not yet been completed. Moreover, there is no hard data presented in the DEIS to support the rationale for such a determination. 30 1 ` -Page 13 1824679 November 14, 2014