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Section 1.. Genera! Comments 1.1, Background The National Environmental Policy Act (NEPA) was signed into law on January 1, 1970. NEPA establishes "national environmental policy and goals for the protection, maintenance, and enhancement of the environment and provides a process for implementing these goals within the federal agencies." From the U.S. Environmental Protection Agency's (U.S. EPA) NEPA website, "Title I of NEPA contains a Declaration of National Environmental Policy which requires the federal government to use all practicable means to create and maintain conditions under which man and nature can exist in productive harmony. Section 102 requires federal agencies to incorporate environmental considerations in their planning and decision-making through a systematic interdisciplinary approach. Specifically, all federal agencies are to prepare detailed statements assessing the environmental impact of and alternatives to major federal actions significantly affecting the environment. These statements are commonly referred to as environmental impact statements (EIS)." On September 19, 2014, the Federal Railroad Administration (FRA) released the Draft Environmental Impact Statement (DEIS) for the All Aboard Florida (AAF) high-speed rail project's Phase 2 ("Proposed Project"). FRA is serving as the lead Federal Agency for the review of the Proposed Project. An Environmental Assessment (EA), presumably using similar methodology, was completed for the Miami to West Palm Beach segment (Phase 1) of the project in 2012. The FRA issued a Finding of No Significant Impact (FONSI) for Phase 1. A supplemental EA is under review (concurrently with the DEIS) for the revised location of a maintenance facility. The supplemental EA has no bearing on the DEIS review. CDM Smith has conducted a thorough review of the DEIS. It should be noted that CDM Smith's review comments focus solely on the information presented in the DEIS that pertains to the portion of the Proposed Project within Indian River County's boundaries (including impacts on municipalities). 1..2 General comments The DEIS limits the review of impacts to those activities being planned within the existing right-of-way (ROW) for the Florida East Coast Railroad (FECR), when in fact, the more significant local impacts would fall outside of the corridor at the individual roadway crossings (traffic control and signalization improvements) and bridge crossings. In general, FECR maintains a 100 foot ROW throughout Indian River County. CDM Smith was notified during the diagnostic field evaluation that intersection improvements would include the addition of 100 foot long traffic separating medians on each side of the crossing to address safety requirements for high speed rail projects. This adds up to 200 feet of additional impacts at each of the intersections where the median installation is feasible for the given crossing geometry (exit gates/4- quadrant gates will be used where medians cannot be accommodated). The addition of these medians, at many of the crossings, will require road widening, filling of stormwater swales/ditches, relocation of overhead and underground utilities and potential traffic impacts from shortened queue in turn lanes. CDM 11