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Mr. Chris Mora <br />November 14, 2014 <br />Page 2 <br />c. Noise levels are underestimated when compared to the existing conditions data collected by <br />CDM Smith. <br />d. Future condition predicts a near doubling of noise levels. <br />4. Construction/temporary impacts are not addressed (other than minimal construction noise data). <br />5. Traffic evaluation is insufficient. <br />a. Number of crossings evaluated is not adequate. <br />b. Very significant queuing impacts will result from the Project that were not properly <br />disclosed. <br />c. Traffic projections not based on actual traffic counts kept by Indian River County (updated <br />annually). <br />d. AM peak not included. <br />e. Delay and queuing calculations are unclear. <br />f. RTC model results do not include impacts to at -grade crossings or the results of multiple <br />trains at rail crossings. <br />g. No mention of future greenway plans (for bicycle and pedestrian use). <br />In. No data given on the projected emergency vehicle impacts for at -grade crossings; no <br />indication of the local emergency routes that were input into the RTC model to render a <br />solution on possible delay impacts. <br />6. Wetlands analysis is incomplete. Evaluation must include potential impacts resulting from <br />improvements made at crossings outside of the existing ROW. <br />7. Threatened and Endangered Species analysis is incomplete. Evaluation must include potential <br />impacts resulting from improvements made at crossings outside of the existing ROW. <br />8. EJ requirement for community outreach is insufficient; specifically, outreach to disadvantaged <br />communities was not adequate. <br />9. Regarding Coastal Zone Management, enforceable policies 553 and 597 were not addressed. <br />10. Cultural Resource evaluation is grossly lacking. <br />a. No mention was made of the historic districts or dozens of historic sites. <br />b. Local governments/groups/individuals as Section 106 Consulting Parties. <br />c. No archaeological survey appears to have been conducted for portions of the project APE. <br />d. No vibration analysis information provide as it pertains to cultural or archaeological sites. <br />In conclusion, CDM Smith believes that the evaluation included in the DEIS is incomplete and recommends <br />that a supplemental DEIS be required prior to issuance of a Record of Decision by the FRA. <br />Sal - A •AR <br />Memora ndu do <br />