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"significant encroachment" — a term that includes likely future damage to transportation infrastructure in a floodplain that could be substantial in cost or extent. Id. at 4, 8. There can be no doubt that the Proposed Project would result in a "significant encroachment" on floodplains. According to the DEIS, more than three quarters of the Proposed E -W corridor and one third of the N -S corridor would traverse currently mapped floodplains.' Thus, overall at least a third of the total project area (or more than a thousand acres) would be located in floodplains. For FRA to provide RRIF funding for the Proposed Project it must satisfy certain requirements under USDOT Order 5650.2. First, it must ensure that the EIS "reflects consideration of alternatives to avoid [a significant] encroachment." Id. at 8. Next, the responsible individual at FRA must make a written finding that the proposed significant encroachment is the only practicable alternative. Id. Such a finding "requires a careful balancing and application of individual judgment" which should "include the full range of environmental, social, economic, and engineering considerations" where "special weight should be given to floodplain management concerns." Id. In addition, the finding must include a description of why the Proposed Project must be located in the flood plain, including the alternatives considered and why they were not practicable. The finding must also include a statement that the action conforms to applicable state and/or local floodplain protection standards. Id.' The DEIS is entirely bereft of the information needed to satisfy FRA's obligations under E.O. 11988 or USDOT Order 5650.2. For example, due to the so-called "tiered" approach that AAF employed to screen out any meaningful alternatives analysis, neither in the few scant pages dedicated to floodplains nor anywhere else in the DEIS is there any detailed consideration of other possible routes.' Moreover, the DEIS does not so much as identify, and certainly does not discuss, applicable state and/or local floodplain protection standards, so FRA would be wholly unable to find that the Proposed Project conforms to such standards. Accordingly, approval of the Proposed Project on the current record would run counter to the letter and spirit of a federal policy aimed at ensuring that federal dollars are not spent on infrastructure projects most vulnerable to the risk of flooding, unless there is no other practicable alternative. a These percentages are based on project area (corridor lengths and widths provided in DEIS Chapter 2) and the project study area within the 100 -year flood plains identified in DEIS Table 4.3.4-1. Similar requirements are reflected in FRA's own NEPA Procedures. See 64 Fed. Reg. 28555. Under those procedures, the agency may only facilitate floodplains development if: (i) the head of the agency finds that the only practicable alternative to the project is to site it in the floodplain; (ii) the agency designs or modifies the project to minimize potential harm to or within the floodplain consistent with E.O. 11988, and (iii) the agency prepares and circulates a notice containing an explanation of why the action is proposed to be located in the floodplain. Id. s See the Board's Comment 1, above. 3 ()1 - A. Page 14 1824679 November 14, 2014