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Memorandum <br />To: Mr. Chris Mora <br />From: Ms. Jill Grimaldi, BCES <br />Date: November 14, 2014 <br />Subject: All Aboard Florida <br />On September 19, 2014, the Federal Railroad Administration (FRA) released the Draft Environmental <br />Impact Statement (DEIS) for the All Aboard Florida (AAF) high-speed rail project's Phase 2 (West Palm <br />Beach to Orlando segment). FRA is serving as the lead Federal Agency for the review of the project. An <br />Environmental Assessment (EA), presumably using similar methodology, was completed for the Miami <br />to West Palm Beach segment (Phase 1) of the project in 2012. The FRA issued a Finding of No Significant <br />Impact (FONSI) for Phase 1. A supplemental EA is under review (concurrently with the DEIS) for the <br />revised location of a maintenance facility. The supplemental EA has no bearing on the DEIS review. <br />CDM Smith has conducted a thorough review of the DEIS. It should be noted that CDM Smith's review <br />comments focus solely on the information presented in the DEIS that pertains to the portion of the <br />Proposed Project within Indian River County's boundaries (including impacts on municipalities). The <br />detailed summary is provided as Attachment 1 to this memorandum. <br />After completing the review of the DEIS, CDM Smith has concluded that the evaluation has significant <br />deficiencies when compared to the requirements of the National Environmental Policy Act, which <br />outlines the requirements for an Environmental Impact Statement. The following presents a summary of <br />the deficiencies. Additional discussion on each item is presented in Attachment 1. <br />Conclusions <br />Upon review of the DEIS, CDM Smith concludes that the document is incomplete and lacking in the following <br />primary areas: <br />1. No impacts outside the FECR ROW were included. <br />2. As presented, the alternatives analysis appears to be insufficient. <br />3. Noise and vibration impacts assessment is not complete. <br />a. Vibration data is lacking. <br />b. General methodologies were used instead of the detailed assessment called for under the <br />FRA manual. <br />3 1 ►l� . ;Z I M—orandum.docx <br />