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Section Z • Aff,'( t- d Eili+!I�`t tl �'1it _n�i f YiS` i=rf�l it f. tl�ni',�Ue'!II NS <br />that inclusion of the banks of the North, Main or South Relief canals as wetlands is appropriate. <br />Background information is required to confirm the accuracy of these estimates. <br />The following are specific examples from Sections 4 and 5 of the DEIS deficiencies: <br />There is a statement in Section 4.3 that "Wetlands were identified and characterized for areas in <br />which the Project would require ground disturbing activities." Those areas should be specifically <br />identified and include all planned activities (roads, utilities, noise barriers and other mitigation, etc.) <br />as well as staging and equipment laydown locations. <br />Section 4 states that field delineations were conducted for the FECR corridor but there are no <br />figures showing wetland boundaries for that corridor. The text references the land use figures in <br />Appendix 4.1.1-A, which do not show wetlands. The only wetlands figures in the appendices are for <br />the E -W corridor. <br />3 USACE jurisdictional determination should be included in the DEIS/EIS- <br />2.8 Threatened and Endangered Species Impacts <br />The limited geographic scope of the DEIS prevents CDM Smith from fully analyzing the impact of the <br />Proposed Project on threatened and endangered species. As is noted consistently throughout CDM Smith's <br />review of the DEIS, impacts to threatened and endangered species are addressed only within the railroad <br />ROW. The USACE, U.S. Fish and Wildlife Service (USFWS) and National Marine Fisheries Service (NMFS) <br />determinations that the Proposed Project will have no adverse effect on threatened and endangered <br />species are based on the assumption that all work will occur within the existing ROW (reference Sep. 18, <br />2013 letter from USACE to the National Oceanic and Atmospheric Administration; September 24, 2013 <br />letter from USACE to USFWS; Oct. 28 letter from NMFS to USACE; AMEC notes from Sep. 6, 2013 meeting <br />with USFWS, USACE and NMFS). The determination needs to take into account any activity outside the <br />ROW. AAF needs to present information about these activities to the agencies and include their feedback <br />in the DEIS. <br />Smith z -i3 <br />