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Section 2 s Afh%(led Ft o iw)wi of d,Id I (.of,,. (Jtf nM i;l Consistency with these plans has been included in the purpose and need criteria matrix used to develop the Action Alternatives." Comment: The DEIS fails to adequately address the Proposed Project's consistency with Indian River County's local Coastal Zone Element Plan. Under the Florida Coastal Management Program Guide, Chapter 163, Part II, Florida Statutes is an enforceable policy incorporated in the federally -approved FCMP. Chapter 163.3194 provides the legal status of comprehensive plans that have been adopted in conformity with the Coastal Zone Management Act. Therefore, Proposed Project must be consistent with the Indian River County 2030 Comprehensive Plan. There is no information provided in the DEIS specifying how the Proposed Project is consistent with this Comprehensive Plan Also, the only planning consistency criterion used in the alternatives screening is "Consistency with plans of transportation agencies and landowners." There is no reference to consistency with local plans in the discussion of purpose and need or alternatives. 2. "Chapter 252 Emergency Management: The Proposed Project would include the development of a passenger rail system within an existing rail corridor and along an existing highway ROW. The E -W Corridor would be located outside of the defined storm surge zones and hurricane evacuation areas for Brevard and Orange counties. Within the N -S Corridor the rail line would be located within Florida Division of Emergency Management -defined storm surge zones; however the development would occur entirely within the FECR Corridor and would be consistent with the existing transportation uses. While the proposed rail system would encourage regional connection as well as growth in the vicinity of the supporting stations, growth would be focused in previously developed areas and would be consistent with existing commercial and industrial land uses. Consequently, the Proposed Project would not affect the state's vulnerability to natural disasters and would not affect emergency response and evacuation procedures. Further the Proposed Project would be consistent with the emergency preparedness policies within the East Central Florida and Treasure Coast SRPPs." Comment: The DEIS does not present any information regarding how the Proposed Project will affect emergency response and evacuation procedures. Under the Florida Coastal Management Program Guide, Chapter 252, Florida Statutes is an enforceable policy incorporated in the federally - approved FCMP. The statement that the Proposed Project would encourage growth contradicts other statements throughout the DEIS that the Proposed Project will not result in induced growth/development. Furthermore, the conclusion that because growth would occur in developed areas, vulnerability to natural disasters would not be affected is not true. Increased development, even in developed areas, can certainly affect emergency response and evacuation procedures by increasing response times and making evacuation more difficult. "Chapter 259 Land Acquisition for Conservation or Recreation: The Proposed Project would likely result in beneficial impacts; compensatory mitigation would be required including the potential acquisition of environmentally endangered lands. Impacts to delineated wetlands would require mitigation as required by Section 404 Individual Permits. Consequently, while the implementation of the Proposed Project would remove wetlands from the N -S and E -W Corridors, compensatory mitigation would include the potential acquisition of environmentally sensitive habitat types." Comment: The DEIS does not acknowledge the potential negative impacts to Indian River County that could result from mitigation activities and loss of environmentally sensitive lands. There is no sm2-9 Smith 3 0 1• tA