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Section 2 a �,. Ii i:„tr , (i l -I k , (ui'nrgilE m c explanation of what compensatory mitigation and/or acquisition of environmentally sensitive habitat types is envisioned elsewhere in the DEIS (should be included under "Mitigation Measures and Project Commitments" in Section 7). Furthermore, it's not accurate to say that the Proposed Project would result in beneficial impacts. The Proposed Project would result in negative impacts, thereby requiring mitigation. 4 "Chapter 288 Commercial Development and Capital Improvements: The Proposed Project would have an indirect beneficial effect on future business opportunities and would likely promote tourism in the region." Comment: Again, this statement in the DEIS contradicts other statements in the DEIS that there will be no induced growth/development. 5 In addition to the unsupported statements, the DEIS states that the Clearinghouse determined that a positive consistency determination from a "similar project" would be valid for the Proposed Project (see below from Section 5.2.5): "As stated in the 2013 FONSI for the WPB -M Corridor, the Florida State Clearinghouse has reviewed the South Florida East Coast Corridor Transit Analysis, a similar project to the Phase I to the WPB M Corridor described in the 2012 EA. The South Florida project was determined to be consistent with the FCMP, and the State Clearinghouse determined that this consistency determination would be valid for the AAF project because the AAF Project Study Area is fully encompassed within the South Florida East Coast Corridor Transit Analysis area which was found to be consistent in 2006 and there have been no relevant changes in the CZMA or FCMP criteria that would affect that determination." Comment: The Florida State Clearinghouse made a consistency determination without input from all of the Florida Coastal Management Plan agencies. In Florida, under Section 380.23, Florida Statutes, a project can only be found consistent if all commenting agencies (under the FCMP agency umbrella) with relevant statutory responsibilities concur. In this case, the FCMP agencies were not given an opportunity to comment on the project by the Florida State Clearinghouse. Rather the Florida State Clearinghouse made the determination without agency input. Per the Florida State Clearinghouse manual (http://www dep state fl us/secretary/oip/manual/manual.htm), the Clearinghouse sends the document or application to OIP for coordination of DEP review. The appropriate DEP division or district contacts distribute the project to appropriate division bureaus and satellite offices. Based on the information provided in the DEIS, this process was never conducted. Additionally, the South Florida East Coast Corridor Transit Analysis is cited as similar to Phase I, so the consistency determination for this project would not be valid for Phase II of AAF. 2.5 Environmental Justice (EJ) The DEIS overlooks the negative impacts to minority and low income communities in those areas of the Proposed Project that do not have proposed stops. The EJ analysis indicates, under Indirect and Secondary Impacts, that the Proposed Project would have a beneficial effect on minority and low income populations in Orlando, West Palm Beach, Fort Lauderdale and Miami by providing an alternative transportation option that would improve access and mobility between Orlando, West Palm Beach, Fort Lauderdale and Miami. There however is no discussion of what type of beneficial effect the Proposed Project would have upon other EJ populations along the rail line. This is also connected to early comments received on the Proposed 2-10 r , Smith