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Section 2 e Aff+-i (,' j L. i �.� kn li iii Yi�lr'n(d (l�i1SE>r �u�n�ec 10. The DEIS did not properly analyze the noise and vibration impacts to land uses, historical structures or archeological resources that are within 600 feet of the Proposed Project's Rail Corridor. Page 4-37 of the DEIS specifically states that the Project Study Area for vibration extends approximately 600 feet from the rail corridor; however, on page 4-122, the DEIS deviates from the 600 feet boundary and presented a vibration analysis for archaeological resources that was limited to the footprint of subsurface activities within the existing approximately 100 -foot wide FECR ROW for the N -S Corridor. 11 The DEIS fails to disclose the total number of land uses that are sensitive to noise or vibration (a.k.a. sensitive receptors) currently being affected by existing noise levels. In Section 5.2.2.2, numbers of impacted sensitive receptors are presented for various project components. AAF should discuss the total number of sensitive receptors and ones that may already be impacted without the Proposed Project in the Affected Environment section (refer to FRA Manual). 1.2. The DEIS fails to adequately describe the noise and vibration mitigation. Section 7.2.4 indicates that AAF will implement mitigation measures as part of the project design; however, it is unclear what that mitigation would be, or what its effectiveness would be in addressing significant impacts. 13. The DEIS fails to include a documented mitigation analysis. Moderate and Severe impacts are identified in the DEIS, however, mitigation analysis is not documented. Noise barrier analysis or horn noise assessment using the FTA and FRA noise assessment manuals is not included in the DEIS. The FRA manual for high-speed rail projects is designed to complement the FTA manual. The High -Speed Ground Transportation Noise Spreadsheet Model has been developed in conjunction with the FRA manual for calculating noise from high-speed rail projects. 2.3 Air Impacts The DEIS did not use the correct methodology to analyze the increase in vehicular emissions caused by the Proposed Project. The Methodology section on page 5-34 of the DEIS states that for vehicular emissions modeling, "all vehicles were assumed to be gasoline burning vehicles." The assumption is not used by the Federal Highway Administration (FHWA) and is not a U.S. EPA -recommended methodology for NEPA analyses [U.S. EPA, "Policy Guidance on the Use of MOVES2014 for State Implementation Plan Development, Transportation Conformity, and Other Purposes" (EPA -420—B-14-008, July 2014)]. The DEIS should analyze the vehicular emissions using the latest version of the U.S. EPA's Motor Vehicle Emissions Simulator (MOVES), MOVES2014 [Note that the older version, MOVES2010, is also acceptable. (79 FR 60343)]. The FRA should have obtained MOVES2014 input files from the Florida Department of Environmental Protection or FDOT for Florida vehicle fleet distributions, by geographic area, and run these to obtain accurate, up-to-date, and defensible emissions inventories for a representative mix of vehicle types and ages. The DEIS fails to examine the negative localized impacts of air emission rates due to the Proposed Project. Tables 5.2-1 and 5.2.2 show the overall regional net benefit in annual mass air emissions due to the induced modal switch from passenger cars to train use. The text suggests that this benefit is not uniformly distributed across the state. The Miami to West Palm section of the project will receive most of the benefit, because that is where train stations are available to travelers; however, it is likely that Indian River County will suffer detriment because the Proposed Project will INCREASE annual mass air emission rates in its area. This is because Indian River County will have no train stations to remove on -road vehicle trips, but will have Smith 3 0 1 1Pt `-� a 2-7