Publish Date: 
Wednesday, November 26, 2014 - 2:45pm

This is a review of the All Aboard Florida (AAF) Project Draft Environmental Impact Statement (DEIS) released on or about September 19, 2014 by the Federal Railroad Administration. The review is provided by the City of Stuart, Florida, and the comments included were approved by the Stuart City Commission on November 24, 2014.

1. Section – Positive Train Control (PTC) System: There is no discussion in the DEIS regarding the location or possible adverse effects to the City of Stuart or Martin County of any radio towers or monopoles required to be placed along the FECR right of way to accomplish the federally required “Positive Train Control,” or to provide a Wi-Fi amenity for train passengers.

2. Section – Existing Land Use: The City of Stuart is not recognized in this section of the DEIS as an “incorporated municipality,” nor are the existing land uses of residential, commercial, industrial and mixed-use considered.

3. Section 4.1.2 – Transportation: Under Subsection, Local Roadway Network, and Subsection, At-Grade Crossings, the DEIS essentially omits any known impacts to local roadways caused by the addition of 32 trains each day within the City of Stuart or Martin County. With Martin Health System’s major medical center facility east of the FEC right of way at approximately Mile Post 260, the DEIS fails to recognize any impact related to time delays or traffic delays associated with its proposed project.
a) To date, AAF has only submitted “30% complete” plans for Roadway Crossings only. As a result, it is impossible to accurately comment on the potential adverse effects of the roadway crossings or proposed construction within the FECR right of way, because the crossings and FECR right of way drawings are not complete. Of particular concern is the need for a pedestrian or multi-modal path crossing at each and every roadway crossing within the City.
b) AAF and FECR should be required to provide completely “sealed corridor” crossings within the City of Stuart, as a means of assuring the safe transit of 70-110 mph+ trains and vehicles at crossings. Based upon the combined use of the FECR tracks for both passenger and freight trains, public safety should be paramount, and the provision of “sealed corridors” by AAF should be the minimum required by the FRA.
c) AAF and FECR should be required to renegotiate completely new “Crossing Agreements” that recognize and include provisions for the increased costs associated with the double-tracking and “sealed corridor” aspects of the Agreements. Federal funding should be provided to offset the local costs caused by the crossing maintenance expenses. 

4. Section – Local Transit Service: In the discussion on local transit, there is no consideration given to the City of Stuart’s micro-transit system of downtown “courtesy trams,” which routinely cross the FECR at Colorado Avenue and St. Lucie Avenue throughout the day and evening. Similarly, there is no discussion or recognition regarding Martin County’s Transit system, or the Treasure Coast (bus) Connector with St. Lucie County.

5. Section 4.1.3 – Navigation: The adverse effects of 32 additional train crossings on a single-tracked trestle bridge built in 1925 are not clearly or fully recognized, stated, or considered in the DEIS.
a) The DEIS shows an average daily vessel count of 157 vessels passing through the draw span at Mile Post 260.93 along the St. Lucie River. Actual counts of vessels by the Martin County Engineering Department show a count of 243 vessels per day.
b) It has been learned by the Martin Metropolitan Planning Organization (MPO) that there are no publicly reported inspection records for the trestle bridge over the St. Lucie River, indicating that neither the FRA nor the FDOT has any public record of the condition of this 90 year old bridge.
c) The existing bridge and trackage in its original 1925 configuration with a proposed 32 additional trains crossing the span each day for a potential of over 50 freight and passenger trains per day has not been adequately considered in the DEIS. A comprehensive study of the need to replace the bridge or construct a tunnel under the St. Lucie River should be considered and required by the FRA and USCG. 
d) Stacking: The All Aboard Florida AMEC model video presentation indicates that boats will “stack” in a single file manner while waiting for the bridge. However, the tidal currents do not flow in a perpendicular manner to the bridge. The channel through which boats must pass to go under the railroad bridge runs in a diagonal path to the river and as a result when boats are attempting to wait for the bridge when it is down, simply adjusting the throttle from forward to reverse will not control the boat because of the sheering effect of the current. The current pulls the boats in a diagonal direction which cannot be controlled by the throttle. If there are multiple boats in a stacking position it will be impossible to respond to the current properly. In addition, when there is a northeast wind which is the “prevailing wind” in the area, with an outgoing current, the operators of the vessels will have a very difficult time engaging the current as it cannot readily be observed.
e) Navigation: The Okeechobee Waterway is regularly used as a barge and transport channel for the marine industry. Included in this most frequently, is the movement of construction barges. According to the Ferrara Group, (a $4,000,000 per year industrial marine construction business located on the South Fork of the St. Lucie River). They regularly move marine barges under the US1 Roosevelt Bridge, through the State Road 707 Bridge, and the FECR trestle bridge. Unfortunately, the boats that push these barges are somewhat difficult to operate and slow to react, and are not able to stack at the bridge while waiting for the trestle to go up or down. In addition, when it has been determined the trestle bridge is going to be lowered, a tug boat is required to begin its stopping procedure as far away as Frasier Creek, to be able to stop prior to impacting the bridge. Once the bridge re-opens it can take in excess of 30 minutes for the barge to resume navigable speed and clear the trestle bridge. Therefore, if the gaps between openings are less than 30 minutes it will be impossible for these barges to navigate the opening.
f) Open Span Width: The width of the trestle bridge opening is very narrow (40 feet). The model video contemplates boats passing in both directions in an expeditious manner. This will be impossible as large fishing boats cannot pass in both directions at the same time. This will become very complicated when multiple boats are “staging’ on either side of the opening during closures. If a barge is attempting to navigate the opening during a limited time, all other boats will have to wait. But they can’t just “stack” and wait for the barge to pass as they will be in the way. It is imperative that this opening is widened.
g) The FRA and FDOT should require a double-tracked trestle, and a much wider clear span opening as broad based safety and convenience measures for marine and vehicular uses.
h) The DEIS does not take into account the designation of the St. Lucie River as an Emerging Strategic Intermodal System (SIS) facility.
i) The DEIS does not take into account the federal designation of the St. Lucie River channel in the area of the trestle bridge at Mile Post 260.93 as the “Okeechobee Waterway,” which regardless of the SIS designation, is nonetheless the cross-Florida navigable link for vessels going from the Gulf of Mexico to the Atlantic Intracoastal Waterway, or the Atlantic Ocean. Sec. 33 CFR 117.317 Okeechobee Waterway currently designates the railroad bridge at Stuart as “not constantly tended” and “normally in the fully open position.” 33 CFR 117.8 Permanent changes to drawbridge operation, requires that anyone seeking to change the operation of a drawbridge must first submit letter of request to the Coast Guard’s District Commander supporting or justifying the requested change. If the District Commander decides that a change is warranted, he or she will begin rulemaking to implement the change. The DEIS provides no indication that a request to permanently change drawbridge operations at Stuart has been submitted to the Coast Guard nor is there any discussion of whether such a request is likely to be granted. 

6. Section – Noise and Section - Vibration: While there is an extensive section on “noise,” the effects are considered in a very broad and conclusory way. For instance, most of the data is at the county level. Within the City of Stuart, the FECR right of way bisects the historic downtown for about 4000 feet, with many buildings within the 150 foot Area of Potential Effects (APE), and yet there is no investigation shown, or consideration given, to any adverse effects attributable to additional noise, especially in the early morning and late evening time frames. The same condition is true for vibration. Vibration is currently experienced with the existing freight service. Along Dixie Highway south of the downtown for about 2 miles to Monterey Road there are single family residences on the east side of the railroad right of way. North of the St. Lucie River trestle bridge, at about Mile Post 260.3, there are 200 multifamily units (Harborage Condominium) immediately adjacent to the railroad right of way. At Stuart City Hall, 121 SW Flagler Avenue, Stuart, FL 34994, on most days, vibration is noticeable and can be felt, when freight trains pass by within 150 feet of City Hall. It is typical to watch “ripples” in a cups of coffee or water on desks in City Hall as trains go by. With the addition of 32 additional trains, AAF has not proposed any noise or vibration mitigation measures in the Stuart area. The only discussion of vibration in the DEIS for the N-S Corridor has to do with farmland (see page 4-47).

7. Section 4.3 – Natural Environment and Section 4.3.1 – Water Resources: In Table 4.3.1-2 Surface Waters Classifications and Impairments in the N-S Corridor, there is no mention of the St. Lucie River. Failing to include it may not affect the outcome of the study. Rather it shows a lack of thoroughness and accuracy. In Table 4.3.4-2 Floodway Crossings within the Project Study Area, it inaccurately describes the St. Lucie River as being in Palm Beach County (see page 4-77).

8. Section 4.4.1 - Communities and Demographics: The City of Stuart, and all of Martin County have been excluded from consideration and analysis in the DEIS. There is no specific review of the City of Stuart or Martin County included in the review. In Sections and, the City of Stuart is not even mentioned as a municipality in which the FECR is located, and neither the City of Stuart, nor Martin County, is included in Table 4.4.1-1. The City of Stuart has federal Census Tracts which are designated as Low to Moderate Income” (LMI) tracts in the East Stuart, Eldorado Heights and Woodlawn Park neighborhoods. As a result they may be disproportionately affected by the expansion of service by AAF along the FECR right of way. No consideration or investigation has been made in the DEIS of this issue. 

9. Section 4.4.2 - Environmental Justice: All Aboard Florida (AAF) may disproportionately impact the safety of Stuart’s low income and minority populations, particularly at grade crossings in East Stuart. 
a) East Stuart is in the Community Redevelopment Area (CRA) of the City, and includes low income and significant minority populations. J.D. Parker Elementary School is a federal Title I school in East Stuart, which has a 75.56% ratio of Free and Reduced Lunch recipients.
b) A “sealed corridor,” necessary for 110 mph trains, would direct pedestrians to grade crossings that are unsafe for walking. An “unsealed corridor” would be particularly hazardous for the East Stuart CRA community members who often walk across the tracks, rather than walk or bicycle to a roadway crossing. Many Stuart CRA residents do not own automobiles, and are forced to walk or bicycle as their primary means of transportation. The same could be said of remaining Martin County CRAs, including but not limited to the Rio CRA, the Golden Gate CRA and the Hobe Sound CRA areas, which lie on either side of the FECR tracks. This issue could easily lead to charges of discriminatory practices by AAF and FECR, and therefore should be mediated and remedied.
c) Stuart and Martin County were not considered or included in the analysis sections of the DEIS for the AAF Project; specifically in Sections 4.4.1 Communities and Demographics, and Affected Environment.

10. Section 4.4.3. - Economic Conditions: All Aboard Florida (AAF) may disproportionately impact the labor force and general employment patterns in the City of Stuart, particularly in and around the historic downtown, and the industrial areas to the south of the downtown.
a) Built around the FEC Railway, beginning in 1894, the City of Stuart’s major employers are Martin Health System (Martin Memorial Medical Center) and the Martin County School Board. Each of these facilities are located east of the FEC corridor, while the populations centers where their workers reside are west and north for the FEC corridor, meaning that multiple crossings will be necessary for those healthcare and school workers, each day. The economic impact of the AAF project on the City of Stuart has not been taken into consideration.
b) The DEIS acknowledges the $90 million annual boating industry impact in Martin County, but then makes no conclusion as to the impact of AAF on that industry. In light of the fact that no significant physical improvements are proposed for the 1925 St. Lucie River trestle bridge, the DEIS should study those effects in exhaustive detail.
c) The City of Stuart has a growing boating and eco-tourism industry focused on the St. Lucie River and the Indian River Lagoon. As the “Sailfish Capital of the World,” Stuart prides itself in developing capacity for the tourism industry. Additional marinas, and marina slips, a mooring field, a hotel, additional restaurants, and other amenities around the St. Lucie River could be severely affected by a 1925 trestle bridge that is in the “down” position for as much as 9 hours per day.
d) The City of Stuart is relying upon the written promise by AAF and FECI not to adversely affect or remove the vehicular parking (leased by the City from FECI) within the historic downtown of Stuart. However, there is no mention of this in the DEIS. 
e) Without an AAF station stop in downtown Stuart, the City will receive all of the negative economic impacts, with very little, if any, economic benefit. Those negative impacts are estimated to include increased vehicular traffic congestion; interference with boating patterns and boating safety; additional noise; reduced air quality, additional train vibration; and loss of property values along the FECR right of way.
f) Stuart has continually maintained its position that since the AAF trains must slow down to navigate the trestle bridge across the St. Lucie River, and the two sharpest curves on the N-S Corridor, the AAF passenger trains should stop in Stuart, before any other communities are considered.

11. Section 4.4.4 - Public Health and Safety: All Aboard Florida could have significant safety issues for the City of Stuart, including, but not limited to, a lack of pedestrian and bicycle at-grade crossings, and a lack of FRA Class 6 trackage within the City of Stuart, lack of fencing along the FEC right of way, (except as already placed by the City of Stuart with a lease from FEC), and of course, the physical condition of the historic trestle bridge, built in 1925, which crosses the St. Lucie River with a lowered (bottom) elevation of +7 feet MSL.
a) It has been revealed by FECR that there are no publicly reported inspection records for the 1925 trestle bridge over the St. Lucie River, indicating the FRA and FDOT have no public record of the physical condition of this 90 year old bridge. So, issues of metal fatigue, concrete pier spalling, or wood rot, are all unknown to the public.
b) As a “first responder” to emergencies, the City of Stuart is concerned about its responsibilities in the event a train wreck occurs along the FECR right of way within the downtown or on the 1925 St. Lucie River trestle bridge. 

12. Section 4.4.5 – Cultural Resources: The AAF project will have adverse effects on the cultural resources of the City of Stuart:
a) As defined in Section 4.4.5, and as noted in Table 4.4.5-10, the Florida East Coast Railway trestle bridge across the St. Lucie River at MP 260.93 (built in 1925, not 1938 as stated) is itself a historic structure which should be considered for preservation or replacement as part of the Environmental Impact process.
b) In Section 4.4.5-2 Designated Cultural Resources, the City of Stuart, which celebrated its Centennial in 2014, was not consulted regarding its historic resources. The FECR tracks run through the historic downtown for approximately 4,000 linear feet. Historic structures within that area include:

The Lyric Theater (c. 1926 & Nat’l Register of Historic Places)
59 SW Flagler Avenue
Stuart, Florida 34994

Parks-Atwood House (c. 1903)
151 SW Flagler Avenue
Stuart, Florida 34994

Geo. W. Parks General Merchandise Store (c.1901) now the
Stuart Heritage Museum
161 SW Flagler Avenue
Stuart, Florida 34994

Feroe Building (c. 1913)
73 SW Flagler Avenue
Stuart, Florida 34994

East Coast Lumber & Supply Co. (c. 1902)
416 SE Flagler Avenue
Stuart, Florida 34994

Woodmen Hall (c. 1914)
217 SW Akron Avenue
Stuart, Florida 34994

There are other significant historic places and structures in the City of Stuart that upon additional investigation can and should be cataloged, in addition to those shown in Appendix 4.4.5.B3. With the exception of Woodmen Hall which is approximately 300 feet, each of the other buildings mentioned above is a scant 100 feet away from the FECR right of way, that is, within the Area of Potential Effect (APE), which also means the preparer of the DEIS did not follow its own Methodology as stated in Section Notwithstanding the “consultation” process described on page 4-124 of the DEIS, no one discussed potential impacts with the City of Stuart.
c) The DEIS cites some historic sites in the N-S Corridor, but fails to specifically discuss any in Martin County. This is incredulous, and requires additional investigation and consideration. There are historic structures and places, in Jensen Beach, Golden Gate, Port Salerno, Hobe Sound, and Jonathan Dickerson State Park, all of which should be investigated and considered for adverse impact effects. Additionally, other jurisdictions were consulted, as shown in Table 4.4.5-2; however, none of the consulted jurisdictions were in Martin County.

13. Section - Affected Environment: The City of Stuart has water, reclaimed water, and sewer transmission lines which cross the FECR right of way from about MP 260 to MP 259, under agreement with FEC. These are not mentioned in the DEIS, and could be impacted by railroad construction.
a) There is no discussion in the DEIS of the current environmental condition of the FECR right of way. For instance, historically, railroad rights of way across the nation have had increased levels of arsenic and asbestos, primarily because of brake shoes used in earlier times. In addition, older passenger trains would dump human waste directly on the tracks. Also, over the years, there have likely been petrochemical spills on the FECR right of way. Upon reading the DEIS, there is no base line shown for any environmental issues related to prior use.

14. Table 5.1.3-3 -Summary of Projected Bridge Operations for the St. Lucie River Bridge: This table shows an increase in closure time, and therefore an impedance to navigation, of an additional 3.2 hours per day (average) during the week and 4 additional hours per day (average) on weekends. This is calculated using an additional 24 closures per day. Under the mitigation measures discussed below under Sec. 7.2.2, the City of Stuart urges a more meaningful mitigation of bridge related issues, including a replacement of the existing 1925 bridge with an increased open span width or a tunnel crossing of the St. Lucie River as an Emerging SIS (Okeechobee Waterway). 

15. Section - Essential Fish Habitat: Under any of the proposed scenarios, that is, “No Action” or “Alternatives A, C or E,” the DEIS fails to consider any impacts at the St. Lucie River. However, during the rehabilitation phase of bridge construction over the St. Lucie River, it is likely that temporary impacts to fish (and other marine wildlife) will occur. These impacts should be studied, known, and considered.

16. Table 5.3.6-1 Alternative A - Direct Effects to Potential Protected Wildlife Species Habitat (acres): This table indicates that no federally protected Florida Scrub-Jay habitat lies within the N-S Corridor (0 acres). Martin County, including the City of Stuart, has miles of Florida Scrub Jay habitat bordering or bisected by the FECR right of way. This impact should be studied and considered. The same situation exists along the FECR right of way for the Florida protected Gopher Tortoise (0 acres). USACE should review and amend its specific findings accordingly in Appendix 5.3.6‐B.

17. Table 5.3.6-2 - Alternative C - Direct Effects to Potential Protected Wildlife Species Habitat (acres): This table also indicates that no federally protected Florida Scrub-Jay habitat lies within the N-S Corridor (0 acres). Martin County, including the City of Stuart, has miles of Florida Scrub Jay habitat bordering or bisected by the FECR right of way. This impact should be studied and considered. The same situation exists along the FECR right of way for the Florida protected Gopher Tortoise (0 acres). USACE should review and amend its specific findings accordingly in Appendix 5.3.6‐B.

18. Table 5.3.6-3 - Alternative E - Direct Effects to Potential Protected Wildlife Species Habitat (acres): This table also indicates that no federally protected Florida Scrub-Jay habitat lies within the N-S Corridor (0 acres). Martin County, including the City of Stuart, has miles of Florida Scrub Jay habitat bordering or bisected by the FECR right of way. This impact should be studied and considered. The same situation exists along the FECR right of way for the Florida protected Gopher Tortoise (0 acres). Accordingly, USACE should review and amend its specific findings in Appendix 5.3.6‐B. While none or little of the existing FECR right of way has these habitats within the FECR right of way, the fact that the habitats are immediately adjacent and no consideration is given to habitat culverts or other wildlife transit methods are considered or proposed.

19. Section 5.4.2 - Environmental Justice and Section 5.4.3 - Economic Conditions: Within the N-S Corridor, the DEIS concludes, “The Project would result in vibration impacts to 3,317 residential parcels along the N‐S Corridor, 820 (24.7 percent) of which are within environmental justice communities. All vibration impacts (including those within environmental justice communities) would be mitigated using ballast mats beneath rail lines, “frogs” at selected switch locations with nearby sensitive receptors, and special pile‐driving methods at selected locations near sensitive receptors during construction. There would be no disproportionate adverse impacts from vibration in environmental justice communities along the N‐S Corridor with the implementation of these measures.” (page 5-126, DEIS). There is no consideration given to the environmental justice (economic) effects of increasing the number of trains per day (32 trains). It is likely that property values will decrease for some extended period of time due to the impact. This economic impact should be studied and considered.

20. Section - Environmental Consequences: The detrimental effects on public safety due to the increased number and speed of daily train-roadway crossings proposed should be further considered. The City of Stuart continues to express its concern that in urban areas, such as the City of Stuart, a completely “sealed corridor” is necessary to provide for the safety of pedestrians, animals, vehicle drivers, and train passengers, from the inherent conflicts and hazards posed by 32 additional train-roadway crossings per day. This section is written in a conclusory manner, without adequate data shown.
a) The City proposes that upon receipt of “90% complete” drawings from AAF, a new, more complete environmental study be completed to look specifically at the possible adverse impacts upon the City of Stuart. 

21. Section – Constructive Use: This section deals with Section 4(f) properties under the USDOT Act of 1966 (publicly owned land of a public park, recreation area, or wildlife and waterfowl refuge of national, state or local significance), and Section 6(f) of the Land and Water Conservation Act of 1965 (other than the historic resources described in Section 5.4.5, Cultural Resources) (49 USC 303, et seq., 16 USC 460L‐460L‐11). The City of Stuart has no known Section 6(f) properties. However, there are two (2) major and one (1) minor 4(f) park properties, and several historic properties within the City. There is ample discussion regarding Jonathan Dickinson State Park in the DEIS, but no specific consideration is given to the Martin County recreation facilities, such as “Doc” Myers Park, and the Port Salerno Community Center, or to City of Stuart facilities such as Martin Luther King, Jr. Park, Sailfish Park, Kiwanis Park, Flagler Park, and the Heart of Haney Creek Preserve, all of which are within 150 feet of the FECR right of way.
a) According to the statement in this section of the DEIS, “Substantial impairment is determined to occur when there is a substantial diminishment of the activities, features, and attributes of the Section 4(f) recreation resources. This evaluation of constructive use of Section 4(f) recreation resources for the Project reviewed potential noise, vibration, aesthetics and access effects.” There is no discussion, evaluation or consideration given in the DEIS to the effects brought about by adding 32 new trains each day to these heavily used park facilities, and no mitigation is proposed.

22. Section - Environmental Consequences - Energy Use: The DEIS makes the point that although the AAF locomotives will use approximately 1.9 million gallons of diesel fuel each year, the savings for personal automobile use will be about 6.7 million gallons of fuel. This is a laudable savings, and the City of Stuart points out that this fuel ratio of AAF/ personal use could be increased even more by providing a station stop in Stuart, enabling Martin and St. Lucie County residents (as AAF passengers) to avoid driving to Orlando International Airport (MCO) and to West Palm Beach, Fort Lauderdale, and Miami.
a) A station stop in downtown Stuart would also enable foreign and other visitors (as AAF passengers) to take advantage of the maritime, recreation, cultural, and tourist attractions in the Stuart area, without the need of driving a personal or rental vehicle.
b) Perhaps more importantly, an AAF station stop in Stuart would help to mitigate the other negative economic and aesthetic effects of the Project, by providing direct access to the AAF rail system.

23. Section 6.4 - Description and Use of Section 4(f) Resources: This section describes, in part, the rationale for the replacement of the 1925 Bridge over the Eau Gallie River (Sec. 6.4.1). “The original railroad crossing of the Eau Gallie River in Melbourne, Brevard County, was constructed in 1925 as a fixed viaduct bridge with two tracks on an open deck. The bridge has 15 spans and is approximately 600 feet long. The substructure consists of steel bents on concrete piles, with cross‐ties between bents. At some point during its operating history, the railroad was reduced to a single active track on the eastern side of the deck. The western tracks were not maintained and are in a state of dilapidation and disrepair.” (Sec. The very next section describes its replacement. “ Proposed Use: AAF proposes to construct a new twin 575‐foot independent ballast deck bridge that will be located to the east of the existing railroad bridge. The existing bridge will be demolished. The demolition and removal of the existing bridge is necessary to protect navigation uses on the waterway, as determined by the U.S. Coast Guard (USCG). The demolition of the bridge is an adverse effect under Section 106 (see Section 5.4.5 in Chapter 5 for the finding of adverse effect) and therefore constitutes a use under Section 4(f). The bridge is within the FECR right‐of‐way and no property acquisition is required.”
a) The City of Stuart makes the same argument for the replacement of the 1925 vertical swing trestle bridge over the St. Lucie River. It should be noted that there is no discussion or consideration given in the DEIS for the replacement of the St. Lucie River trestle bridge with a new bridge or with a tunnel, nor is it even mentioned in this section dealing with the subject of 4(f) properties. While the St. Lucie River crossing is about twice as wide as the Eau Gallie River crossing, the St. Lucie River serves a much larger boating community, and it is similar to the Sebastian River crossing, although the St. Lucie River crossing is some 400 feet shorter than the 1,635 foot length of the Sebastian River crossing, which is also being replaced.
b) The St. Lucie River is a unique waterway, composed of the federal Okeechobee Waterway, which is an Emerging Strategic Intermodal System (SIS) (east and west), and which serves as a connector with the Atlantic Intracoastal Waterway (north and south), and the Atlantic Ocean. There is no other location on the east coast of Florida with this type of navigable water access. As a result, it is not reasonable to add 32 trains per day, without significant mitigation of the impacts this will cause to the recreational and commercial boating communities. 

24. Section 7.2.2. - Navigation: This paragraph is in the “Mitigation” section of the DEIS, and claims to resolve the issues common to the three (3) vertical swing bridge crossings (New River, Loxahatchee River, and St. Lucie River). The first six of the mitigation methods proposed involve “notice” of bridge closings through 1) scheduling, 2) internet app, 3) countdown horns, 4) contact with first responders, 5) coordination with local authorities during peak boating times, and 6) coordination of schedules through the USCG. At the New River, AAF proposes to place a “bridge tender” as a means of solving conflicts and interference with commercial boat traffic. The City of Stuart believes that all seven (7) of these mitigation measures are minimal, and almost ineffective, and don't reflect or compensate for the actual interference and damage that 32 additional trains will place on the commercial and recreational boating community. Additional measures should be studied and proposed, including but not limited to replacement of the 1925 trestle bridge over the St. Lucie River with a double-tracked, wide clear span bridge or a tunnel crossing under the St. Lucie River .

25. Section - Vibration Mitigation: Because of the proximity of a great number of historic structures to the FECR right of way within the City of Stuart, and particularly within the historic downtown of Stuart, AAF should be required to install “ballast mats” and other mitigation, for noise and vibration dampening throughout the approximately 2 mile length the FECR right of way transects the City.

26. Section 7.2.13 - Section 4(f) Resources: Mitigation of Sec. 4(f) resources is not proposed for the City of Stuart. The City believes the entire historic downtown on either side of the FECR right of way is within the Area of Potential Effect (APE), and deserves special consideration of the historic structures comprising the downtown which was built beginning in the 1880s.
a) The historic Lyric Theater (c. 1926) just completed a $1.5 million renovation. At least half of that cost (according to the Executive Director, John Loesser) was structural, and while no claims have yet been made, it is likely that vibration from the FECR right of way from 1926 to the present had a causative role.

27. Conclusion: Before permitting, AAF should be required to identify, quantify, qualify, and resolve all reasonable environmental, noise, vibration, air quality, environmental justice, maritime, and economic impacts from MP 259 to MP 263.