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IRNA's Response to AAF's Final EIS

August 30, 2015
Federal Railroad Administration
1200 New Jersey Avenue
SE Room W38-311
Washington, DC 20590
Attn: John Winkle
Dear Mr. Winkle,
This communication responds to the release of the Final Environmental Impact Statement (FEIS) dated August 4, 2015 addressing the proposed All Aboard Florida (AAF) passenger fast-speed rail service and the expansion of freight transport on the same rail line(s).  It is written on behalf of the Train Impact Coalition (TIC) from Indian River County, Florida representing our local governments, organizations and individuals plus homeowner associations, organizations and individuals in Brevard County (see list at the bottom of this email). 
The Coalition's response to the Draft EIS was submitted on September 26, 2014 stating our intent to protect our communities from adverse impact by appropriately inserting ourselves into the process established by the National Environmental Protection Act (NEPA). We continue to do so acknowledging AAF is a private business venture on private land and the expansion of their rail service with federal financing (RRIF) carries with it a responsibility to mitigate identified, adverse impacts to our natural and human built environments.  
It is of great concern that the FEIS was released before a 90 Percent Plan was issued for our County. The most basic of all impact is contained in that Plan. Without it, the relevancy and accuracy of the FEIS cannot be determined.    
Nor does the FEIS provide adequate information about noise and vibration.  There exists an operating railroad that sets a high base level of noise and vibration.  Train operations over and above this baseline must be established in order to identify any potential adverse impact to the natural and human environments.  There should also be an evaluation of impact due to the length of the trains, both that which is established as baseline along with the projected expansion of rail services. Accordingly, these should be applied to the many varied interests adjacent to the rail tracks to determine impact.   
Throughout this process our local governments have been denied the ability to provide local knowledge through recognition of their jurisdictional authority.  The governments of Sebastian, Vero Beach and Indian River County each submitted a separate application to become a designated Cooperating Agency and each was denied that status.  The result is the absence of local knowledge. Conducting public workshops did little to factually address this matter. Some examples follow. 
The FEIS now gives us information about the projected closure of 2 at-grade crossings in the City of Vero Beach.  This threatens to place a major disruption to the historic road grid which provided for the City's downtown development and which remains essential. The planning of roads takes many years and any crossing closure requires careful coordination with the City of Vero Beach and the County's Metropolitan Planning Organization (MPO) to avoid massive disruption to vehicular travel in Vero Beach.  Such coordination includes consideration of law enforcement, fire-rescue and other vital services.  
The absence of local knowledge also includes the minority community of Gifford which will be greatly impacted by the proposed expansion of rail services. Gates must come down with sufficient lead time to avoid collisions and this disproportionately affects the people of Gifford as there are only two eastbound roads, both crossing the rail tracks, connecting the entire community to US 1 and beyond. Federal desegregation requirements will also impose disproportionately longer bus routes for Gifford students.  It is incumbent upon AAF to recognize and mitigate such adverse effects.     
A Cooperating Agency status was also denied to the active archeological excavation, "Old Vero Ice Age Site".  We expect the County's Historic Properties will be accurately represented through Section 106 but the Ice Age site requires separate action. The information being gleaned from this highly significant site has potential World Heritage recognition.  A professional, detailed examination of the site and a non-traditional measure of noise and vibration are required to assure the site will not be damaged by any and all expansion activity.  
References to less vehicle congestion, enhanced mobility for elderly and handicapped citizens apply to the more populated areas south of Indian River County where there will be scheduled Stops. That is clearly to their benefit. Quite the opposite is true in our areas.  It will be the elderly and the handicapped citizens, in addition to all vehicular travel, that will be burdened with the expansion of rail services because the passenger trains will pass through our county without stopping. Environmental justice demands greater acknowledgement of these burdens.
We understand many of our concerns will be addressed through the various permitting processes and there will be additional surveys for wildlife, all of which first require the 90 Percent Plan. Further, we realize federal standards for rail safety are being updated based on recent adverse rail incidences and we fully expect AAF and the expanded freight services will have compliance with all new standards. That is not the point of this response.  
Our concerns involve the health, safety and well-being of all our communities which have been given only scant  consideration in your documents. This correspondence addresses the failure of the FEIS to comply with NEPA concerning impact to Indian River County as evident in the lack of the 90 Percent Plan and the examples I have presented above.
We respectfully request that a Record of Decision be delayed until Indian River County is presented with the 90 Percent Plan and impacts are identified, analyzed and, where indicated, mitigated. We ask you to also include a time for public comment following release of that Plan and prior to the Record of Decision.  
I appreciate this opportunity of providing a response to the FEIS and thank you very much for your attention to this correspondence. Please do not hesitate to contact me for any clarification or assistance.   
With sincere regards,
Honey Minuse, Chair
Indian River Neighborhood Association
For the Train Impact Coalition (TIC)
List of Participants:                                          
Penny Chandler, Indian River County Chamber of Commerce
Beth Mitchell, Sebastian Chamber of Commerce
Joe Idlette III, Gifford Progressive League                                 
Ruth Stanbridge, Indian River County Historical Society
Vicky Gould, Main Street Vero Beach
Randy Old, Vero Man Ice Age Site
Sandra Rawls, Vero Man Ice Age Site
Bill Aufiero, Vero Man Ice Age Site
Rebecca Rickey, Heritage Center
Nick Schaus, Barrier Island liaison (IRNA)
Robert Schaedel, Architect
Judy and Jim Gallagher, Sebastian Property Owners Association
Carol Barry, Sebastian liaison (IRNA)
David Hunter, Barrier Island liaison (IRNA)
Mary Kiernan, Sebastian liaison (IRNA)
Karen Disney-Brombach, Indian River County School Board elected official
Jane Schnee, Friends of St. Sebastian River
Tom Gruber, Engineer
Buzz Herrmann, Friends of St. Sebastian River
Jeff Luther, Indian River County Sheriff's Department
Barbara Hoffman, Cultural Council
Sam Zimmerman, Indian River County Planning and Zoning Commission Chair
Bill Cannon, Canaveral Groves
John Debus, Treasure Coast Progressive Alliance
Sue Olson, Micco Homeowners Association
Chelle Woods, Micco Homeowners Association
Jan Black, Micco Homeowners Association
Andrea Coy, Sebastian, City Council Member
Joe Griffin, Sebastian City Manager
Frank Watanabe, City of Sebastian
Cynthia Watson, City of Sebastian
Peter O'Bryan, Indian River County, County Commissioner
Dylan Reingold, Indian River County, County Attorney
Kate Cotner, Indian River County, Assistant County Attorney
Amelia Graves, Vero Beach, City Council Member
Jim O'Connor, Vero Beach City Manager
Monte Falls, City of Vero Beach
Dan Dexter, City of Vero Beach
Dan Lamson, Executive Director, Indian River Neighborhood Association
Honey Minuse, Indian River Neighborhood Association