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6. Construction Impacts: The Identification and Discussion of Construction Impacts is Virtually Absent from the DEIS. It is well established that a NEPA EIS must discuss and evaluate the construction impacts that would result from a proposed action. See, e.g., FRA NEPA Procedures, 64 Fed. Reg. 28556 (an FRA NEPA EIS "should identify and assess the impacts associated with the conshwaion period of each alternative" (emphasis added)); USDOT NEPA Procedures, Attachment 2 at 13. Proceeding from the unrealistic premise that the Proposed Project would be constructed by 2016, the DEIS provides only the most superficial description of the construction -related activities that are anticipated, and little substantive assessment of the "temporary" construction period impacts those activities would cause. Thus, no details whatsoever are provided concerning the schedule for the work, the sequence of activities, the nature of those activities, the number and types of equipment that would be used, the level of truck traffic that would be generated in delivering materials to and disposing of waste from the work sites, the routes such trucks would take, road closures, detours, staging and storage area locations, or other matters critical to a meaningful impacts analysis. As a result, nothing of substance is discussed with respect to the impacts of construction activities on surrounding land uses, traffic, emergency response, or other critical issues. Thus, the DEIS brushes aside construction -related land use impacts with a few words about "short- term construction easements on privately owned properties," and the assurance that "pre -construction land use patterns would return once the construction period concludes." DEIS at 5-5. Not a word is mentioned about the nature and extent of the disruption that would be caused to adjacent homes and businesses during the period that a massive infrastructure project is being constructed through the heart of downtown and residential areas. Indeed, rather than addressing the socioeconomic impacts of Proposed Project construction at all, the DEIS merely comes up with a few numbers on the economic benefits and jobs that could be generated by the work. DEIS at 5- 130. Likewise, the DEIS dismisses out of hand the traffic -related impacts of construction activities, stating that "the Project would result in minor, short-term impacts to freight rail transportation, regional highways and local vehicular traffic during construction." DEIS at 5-14. With respect to freight traffic, the document reaches that conclusion based upon the assurance that "[n]ew track construction ... would be performed according to best management practices" without specifying what those BMPs might be or how they might avoid disruption to freight traffic. Id. With respect to vehicular traffic, the document mentions that there would be road closures, but states that "typically," they would last no more than a week. No discussion appears at all as to whether there are certain roads that would be closed for a longer period; nor does the DEIS address whether police, fire or EMS emergency response would be delayed as a result of the road closures (and if so, what could be done to mitigate that impact). Moreover, no analysis is presented with respect to whether construction -related truck traffic would cause significant congestion on the roadways surrounding work sites and staging areas. Instead of disclosing construction period traffic impacts and identifying the mitigation measures to address them, the DEIS simply waves the issue away with .30 1 -A— Page 15 1824679 November 14, 2014