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Section 2 e Af[2, (-1 t. ilv 1 =f 11, 10 -I'1 I z ii' .I cm ci environmental impacts of the new impervious surfaces that AAF is required to install outside the existing corridor to qualify as a sealed corridor. On page 5-79, the DEIS states that constructing the Proposed Project in the N -S corridor will not create new impervious surfaces. This statement is contradicted in several areas throughout the DEIS. Page 3-33 of the DEIS states that the existing railroad system was built and is maintained to FRA Class IV track standards. On page 3-36, the DEIS states that the Proposed Project intends to operate at a speed of up to 110 miles per hour, which, according to the Railroad -Highway Grade Crossing Handbook—Revised Second Edition (2007), would require track improvements to achieve Class VI standards. Specifically, Class VI tracks (high speed rail) requires a sealed corridor, which includes the installation of a 100 foot median on each side of the road crossing (where feasible; 4 -quadrant gates can be used as an alternative if crossing geometry does not support the installation of the median)(see Section 3 of the above -referenced handbook). These necessary improvements will cause new impervious surfaces that fall outside of the FECR ROW. The DEIS should address the additional impacts from these impervious surfaces. 2,6.E C onstrrictiot, The DEIS does not address staging or equipment laydown locations or temporary/permanent impacts on the natural environment. Under NEPA, the DEIS is required to address both construction and post - construction impacts of the proposed action. See Federal Register (volume 64, No. 101 dated May 26, 1999). This has not been done. 2,6.4 Mitigation The DEIS fails to identify specific mitigation measures for the adverse effects the Proposed Project will cause on the natural environment. For example, page 7-10 of the DEIS states: "AAF will obtain an appropriate Section 404 permit from USACE prior to construction, and implement mitigation as required by the wetland permit conditions." NEPA requires that the specific impact be identified and corresponding planned mitigation presented. The DEIS appears to claim the benefits of mitigation in several instances, without specifically describing the mitigation activity. Under NEPA, the impacts must be analyzed first before mitigation can be considered. According to Table 5.2.5-1 regarding land acquisition for conservation and recreation: "The 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 Project would remove wetlands from the N -S and E -W Corridors, compensatory mitigation would include the potential acquisition of environmentally sensitive habitat types." There is no explanation of what compensatory mitigation and/or acquisition of environmentally sensitive habitat types would be required in the DEIS. 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. That mitigation should have been addressed and described in detail in the DEIS. 2.1 Wetland Impacts The wetlands discussion in Sections 4 and 5 of the DEIS is inadequate. No figures showing wetland locations relative to the Proposed Project area appear in the DEIS text or appendices. The DEIS does, however, include approximate acreages for impacts. IRFWCD staff has indicated that they do not believe 2-12 CDM