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Section 1 a Genes 31 Cc�n�n,e��i� The diagnostic report provided via email by Indian River County staff outlines some of the intersection improvements being proposed; however, this information is not presented in the DEIS. Therefore, the DEIS should be considered incomplete due to the lack of information addressing impacts outside of the ROW. The DEIS is also silent on the potential impacts from construction activities. The document does not identify construction lay -down or staging areas, information on construction sequencing or duration, dust control measures, or the potential noise and vibration impacts to archaeological or historical sites along the corridor within the Area of Potential Effects (APE). In addition to the missing construction and intersection improvement impacts, the following general comments were noted during CDM Smith's review: The presentation of the Miami to West Palm Beach segment (Phase 1) separate from the remaining segments appears to be a clear case of segmentation (i.e. Phase 1 was reviewed and approved independently of and ahead of Phase 2). For a project to be segmented under NEPA, AAF would have had to demonstrate "Independent Utility" in order for project components to be reviewed and considered separately. CDM Smith is not convinced AAF has demonstrated "Independent Utility," and would request further documentation from FRA that this process was undertaken in accordance with NEPA requirements. 2. AAF applied for federal funds from FRA through the Railroad Rehabilitation and Improvement Financing (RRIF) program. Compliance with the NEPA is a prerequisite for approval of the RRIF loan application. CDM Smith also reviewed the RRIF loan application for the purpose of confirming consistency between the documents. 3. The Proposed Project as analyzed in the DEIS is assumed to include 5 additional passenger train sets; 16 round-trip trips (32 one-way trips). The DEIS does not account for the increase in freight traffic that is noted in the RRIF loan application or the potential for increased passenger rail traffic over time. 4. The U.S. Coast Guard (USCG) cooperating agency acceptance and jurisdiction determination are included but the U.S. Army Corps of Engineers (USACE) and Federal Aviation Administration (FAA) documents are not included. 5 The DEIS draws conclusions throughout without adequate justification. For example, the document concludes that no significant localized traffic impacts would result from operation of the Proposed Project; however, Appendix 3.3 C indicates that queues stretching for more than a mile would occur at least 4 times an hour at certain area intersections. Such impacts, which could occur all along the corridor of the Proposed Project, were not appropriately addressed. 1 .3 Indirect and Secondary Impacts The DEIS concludes that there will be "no induced growth" as a result of the Proposed Project; however, there are direct statements to the contrary within the DEIS. For example, Table 5.2.5-1 states that, "The project would provide linkages between regional and statewide multi -modal transportation networks and promote commercial development within the vicinity of transit systems" and "The Project would have an indirect beneficial effect on future business opportunities and would likely promote tourism in the region." Section 5.1.2.3 states "The three proposed stations for the WPB -M Corridor (in West Palm Beach, Fort CDM1-2 Smith 301