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Lauderdale and Miami) may result in secondary effects such as creating potential for development and redevelopment outside the development directly associated with the stations. This additional development may also create impacts such as induced traffic generated by those developments." This statement contradicts Section 5.2.1.3, which states "The areas surrounding the proposed stations are already developed; the Project is not anticipated to result in induced growth or development that could generate additional emissions of criteria pollutants, and would not result in indirect or secondary effects to air quality." 1.3 Permitting and Regulatory Reviews The DEIS fails to include documentation that USACE and FAA agreed to act as cooperating agencies for purposes of reviewing the Proposed Project. The NEPA-required cover page of the DEIS lists USACE, USCG and FAA be cooperating agencies. A "cooperating agency" is an agency that has jurisdiction by law or special expertise with respect to any environmental impact involved in a proposal (or a reasonable alternative) and will typically will have some responsibilities for the analysis related to its jurisdiction or special expertise (See 40 CFR 1501.6 and 40 CFR 1508.5). Page 1-5 of the DEIS indicates that USACE was asked to participate as a cooperating agency and USACE agreed; there is a similar statement regarding FAA's involvement on page 1-6. No cooperating agency documentation was provided for either the USACE or the FAA. An EIS should include detailed statements concerning the environmental impacts of the proposed project; not bypass this obligation to other permitting processes. On October 7, 2014, the USACE issued a notice stating that, "The applicant has estimated that the north/south component of the proposed railway would occur within the existing FECR ROW and would only require minor impacts to waters of the United States (wetlands and surface waters) at various locations along the corridor. The Corps has initially determined these minor improvements could be verified in accordance with the Corps' Nationwide Permit (NWP) program. Verification by NWP would not require further public coordination." The notice further stated that USACE will use the final EIS as the NEPA document for issuance of the NWP. Additional discussions with the USACE Project Manager indicated that authority for review of the proposed bridge improvements and replacements along the North-South (N -S) segment would be delegated to the USCG, in accordance with Section 9 of the Rivers and Harbors Act. Section 9 states that a USACE permit may still be required pursuant to Section 404 of the Clean Water Act if the construction of a bridge over a navigable waterway requires the discharge of dredged and/or fill material into waters of the United States. Without preliminary design plans for the Proposed Project, it is difficult to evaluate the extent of required dredge and fill activities, and therefore to what extent USACE involvement is required. In addition to USACE and USCG authority, local permits will be required for the proposed bridge replacements and expansions. The Indian River Farms Water Control District (IRFWCD) maintains the North, Main and South Relief Canals. The referenced canals are listed in Appendix 5.3.6-66 of the DEIS (ESA Section 7 Consultation 20140129) to be upgraded (not replaced). CDM Smith spoke with the superintendent of the IRFWCD, who indicated that there has been no contact or coordination to date between the AAF project team and IRFWCD regarding permit or maintenance requirements. IRFWCD further indicated that the existing support for the North Relief Canal Bridge is in a state of disrepair with significant washouts and undermining being observed on the southern support. CDM ''JCI 1-3 Smith