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Section 2 • Affe, I, tl I irviroim fd a110 1 nen w,� nt,�l C,;n� i_ Project concerning areas without a station that would be adversely affected, but would not receive any economic or social benefits. Additionally, AAF failed to conducted significant public outreach to affected minority communities located along the FECR corridor. AAF received a comment during early scoping for the Proposed Project to include significant public outreach to minority communities that are located along the FECR Corridor; however, there is no discussion within the DEIS of such an outreach occurring within Indian River County. Indian River County has confirmed with Freddie L. Woolfork, an Executive Board Member of the Gifford Progressive Community League, that AAF held a meeting at the Gifford Youth Activity Center for local citizens. The required meeting, however, was described as a "generic, shortened version of a previous (non -Gifford -specific) public meeting." There was no specific information pertaining to the impacts the Proposed Project would have on the Gifford community. In fact, Mr. Woolfork described the meeting with AAF as "more of a discussion to let [the Gifford Community] know that there would be a new passenger project in Florida and that there would be 32 round trips per day going through Indian River County at 120 MPH and that it is a great economic benefit to all of Florida..." It is therefore obvious that AAF held a meeting in the Gifford Community to satisfy a NEPA requirement without any intention of taking into consideration the comments, concerns and issues brought forth by those local residents. 2.6 Natural Resources Impacts CDM Smith notes the following comments/concerns with regards to natural resources impacts: 2,6.1 General Commend The DEIS does not fully address the environmental impacts to the natural resources located within Indian River County. For example, Sections 7.2.6 and 7.2.10 state that the relative mitigation activities will be identified in the various permit requirements (once issued), rather than identifying the impacts and stating what the mitigation activities will entail. NEPA requires that the environmental impacts be addressed in the DEIS, and not deferred to the permitting process. Moreover, on pages 4-54 and 7-8, the DEIS states that the USACE permitting process will rely on the DEIS as the required NEPA document to complete the Section 404(b) (1) analysis. It is therefore necessary that the issues be sufficiently addressed within DEIS document. Thus the analysis of the impacts is inadequate. 2.6.2 Water Resources The following are examples from the DEIS demonstrating the lack of sufficient information necessary to adequately address impacts to water resources: Section 5 of the DEIS says stormwater Best Management Practices will be installed but gives no specifics on what type of Best Management Practices they intend to use or the location. Page 3-35 of the DEIS states that the Proposed Project will include installing a third rail at various locations (3 within Indian River County). On page 5-79 of the DEIS, it states "The Project would include improvements to the existing mainline and reconstruction of the second tracks on the existing track beds. Constructing the Project in the N -S Corridor would not create new impervious surface." The DEIS does not take into account that there will be new impervious surface due to road construction outside the existing corridor. For example, The DEIS fails to address the Smith 2 ii 3c�1 ' 1�•yIt,