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Section 2 , Ai(,, i- I I ffww, i,[ ,,,o h —mmw no,:El1 , e_piFii , increased emissions from passenger trains, induced additional freight trains, and greater idling at at -grade crossings. The Proposed Project's air emissions impacts specific to Indian River County should be modeled and disclosed. The public should have complete information about impacts the Proposed Project will cause in some portions of the state so that other portions of the state can receive benefits. The DEIS fails to address the Proposed Project impacts to the localized air quality. Potentially significant localized impacts would be expected to be associated with maintenance yards, terminals, and park -to -ride lots., The Proposed Project plans to have third -rail siding at three locations in Indian River County .If the purpose of the third track siding is to hold idling freight trains while the high-speed passenger trains passes, the DEIS should include modeling for these emissions, especially diesel particulate matter emissions. The DEIS should also address potential effects to sensitive receptors nearest these locations. The intersection carbon monoxide analysis has been generalized from the 2012 Phase 1 studies. An up-to- date analysis with the latest traffic and emissions data is recommended to determine if a microscale dispersion models should be run for carbon monoxide concentrations at the worst-case at -grade crossing in Indian River County (FHWA Technical Advisory T 6640.8A). An analysis for the new one-hour nitrogen dioxide National Ambient Air Quality Standard (NAAQS) should be included. Although quantitative modeling is not required by FHWA Technical Advisory T 6640.8A, this new stringent NAAQS is a possible issue at congested intersections. Section 5.2.1.4 Construction -Period Impacts evaluation lacks the detail required for an adequate DEIS. Among other things, the analysis should include a discussion of the length of the construction period along each segment, identification of areas where contaminated soils would be disturbed (and specific mitigation measures), identification of construction staging areas and their activities, description of and commitment to specific dust control measures, and an evaluation of exposure to diesel particulate matter emissions from construction equipment (FHWA Technical Advisory T 6640.8A). Regarding DEIS Section 7.2.3 — Mitigation Measures, Air Quality, the discussion of mitigation for fugitive dust control is generic, and there is no mention of mitigation for diesel particulate matter emissions. Mitigation discussion is required under 40 CFR 1502.16(h). The section should identify the Best Management Practices that would be employed at staging areas and at construction sites. CDM Smith recommends also that AAF commit to use of construction equipment meeting U.S. EPA Tier 4 emissions standards, or to retrofitting equipment not meeting these standards with diesel particulate matter filters. 2.4 Coastal Zone Management The DEIS speaks to the applicable coastal zone management statutes (Table 5.2.5-1) and concludes that the Proposed Project is consistent, but there is very little back-up for this conclusion. Additionally, Table 5.2.5-1 omits applicable, enforceable policies 553 (Building and Construction Standards) and 597 (Aquaculture). As in the rest of the DEIS, the assumption is made that all work will occur within the existing FECR corridor, which does not take into account intersection improvements, staging, noise barriers, stormwater management, etc. The following excerpts from Table 5.2.5-1 are examples of unsupported statements: I "Chapter 163, Part II Growth Policy; County and Municipal Planning; Land Development Regulation: The Proposed Project would be consistent with local, regional, and state comprehensive plans. 2-8 13 01. IN - 12) Smith