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r� <br />Executive Sumr-nary <br />Upon review of the DEIS, CDM Smith concludes that the document is incomplete and lacking in the <br />following 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 />c. Noise levels are underestimated when compared to the existing conditions data collected <br />by 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 Proposed Project that were not <br />properly 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 resuits 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 />h. 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 />CDM ES -1 <br />top <br />