20 October 2014
Mr. John Winkle
Federal Railroad Administration
Room W38-31
1200 New Jersey Avenue, SE
Washington, DC 20590
Subject: All Aboard Florida Environment Impact Review Statement
Dear Sir,
The Board of Directors of the American Institute of Architects (AIA) Treasure Coast has
completed a review of the All Aboard Florida Environmental Impact Statement. Please
find the ten page review attached.
The membership of the AIA Treasure Coast includes the architects in the Treasure
Coast (Martin County, St. Lucie County, and Indian River County). The Treasure Coast
Counties are located between Palm Beach County (Gold Coast) on the south and
Brevard County (Space Coast) on the north. The Treasure Coast has 90 miles of
coastline along the Atlantic Ocean. In addition to the ocean to the east, there are
several barrier islands and the Indian River Lagoon which runs north from the Treasure
Coast though Space Coast. The Indian River Lagoon is North America’s most diverse
estuary with more than 4,300 species of plants (2,100) and animals (2,200), including
35 that are listed as endangered — more than any other estuary in North America. In
the Treasure Coast there is also a high percentage of lands that been preserved in their
natural state for future generations to enjoy. Most importantly, people are attracted to
the Treasure Coast because of the peaceful small town character throughout the
Treasure Coast. Many communities in the Treasure Coast were created before the
Flagler Railroad came through. Those communities are still vibrant small towns today
with many downtown community activities, events, leisure activities (fine dining etc.) and
prosperous businesses.
We find the proposed All Aboard Florida High Speed Rail to be a major threat to the
existing character and Quality of Life in the communities on the Treasure Coast. There
is no way to justify the damage that the proposed All Aboard Florida High Speed Rail
will do to the Quality of Life in the Treasure Coast.
We find the All Aboard Florida (AAF) Environmental Impact Statement (EIS) to be
severely deficient and flawed. The AAF EIS must be revised to become a complete
document addressing how AAF will affect the unique Character and Quality of Life on
the Treasure Coast and addressing all of the issues effecting the people and
businesses of Treasure Coast. Our attached ten page Review Comments include Four
Major Issues followed by a detailed discussion of each major Issue.
Page 1 of 12
The Major Issues include:
All Alternatives for High Speed Rail Must be Analyzed
The Effect on the People of the Treasure Coast Must Be Addressed
The Relationship with a National High Speed Rail Must Be Addressed
The Benefits for the Citizens of the Treasure Coast Must Be Stated
Bottom Line:
The All Aboard Florida (AAF) Environmental Impact Statement (EIS) is severely
deficient and flawed. The AAF EIS must be revised to become a complete all
inclusive document which addresses the major issues and concerns of the
people and businesses of the Treasure Coast.
A more complete all inclusive analysis will reveal at least one alternative which
will provide faster (220 MPH) and safer (100% Grade Separation) High Speed Rail
from Orlando to Miami and which causes no damage to the Economy in the
Treasure Coast and no damage to Quality of Life in the Treasure Coast.
All of the issues cited in our attached review should be specifically addressed
point by point.
I invite you to travel to Florida to make a visit to the Treasure Coast. I would be happy to
provide you a personal tour.
Please feel to contact me at 305 667 2009. I would be available to meet with you at any
time.
Respectfully,
Thomas T. Cooper AIA
Executive Director
American Institute of Architects Treasure Coast
Copy to:
Representative Patrick Murphy
Columnist Richard Campbell, Scripps Treasure Coast Newspapers
Page 2 of 12
All Aboard Florida Environmental Impact Statement
Review Comments by AIA Treasure Coast
The All Aboard Florida (AAF) Environmental Impact Statement (EIS) is
severely deficient and flawed. The AAF EIS must be revised to become a
viable document. Review comments list Four Major Issues followed by a
detailed discussion of each major Issue.
Major Issues
1. All Alternatives for High Speed Rail Must be Analyzed
The AAF EIS must not reject alternatives due to “AAF’s Specified
Determining Factors”. Paragraph 3.2.2.1 lists “Time of Execution” and
“Delay Initiating Revenue Service” as Screening Factors and thereby
eliminating the Florida Turnpike Alternative from evaluation.
2. Effect on the People of the Treasure Coast Must Be Addressed
The AAF EIS must address the effect of All Aboard Florida has on the
people and businesses on the Treasure Coast. Community impact must be
included in the EIS Analysis. People and businesses are part of the
Environment on the Treasure Coast. People are as important as animals,
birds and fish in the EIS Analysis.
3. Relationship with a National High Speed Rail Must Be Addressed
The AAF EIS must address how it relates to a National High Speed Rail
(220 MPH) from Boston assuming the Boston to Miami High Speed Rail will
have major express stops in New York City, Washington D.C., Charlotte,
NC, Atlanta, Orlando and Miami.
4. Benefits for the Citizens of the Treasure Coast Must Be Stated
Since a very large amount of Federal monetary support is required, the
AAF project must be considered a National project – not a local private
business project. The AAF EIS must address how the AAF Project benefits
all of the citizens of the United States and particularly the citizens of the
Treasure Coast. Who benefits most from this project?
Detailed comments on each of the Major Issues follow below:
Page 3 of 12
1. All Alternatives For High Speed Rail Must be Analyzed
The AAF EIS has been written as a sales tool to promote the financial plan
AAF thinks best for their interests. The EIS should be as a mechanism to
study and evaluate the environmental impact of different alternatives on the
communities that host the tracks of AAF. The AAF EIS must not reject
alternatives due to “AAF’s Specified Determining Factors”. Paragraph
3.2.2.1, which lists; “Time of Execution” and “Delay Initiating Revenue
Service” as Screening Factors and thereby eliminating the Florida Turnpike
Alternative from evaluation.
The time to achieve the best solution for providing High Speed Rail Service
from Orlando to Miami may take longer than the AAF Solution. However,
we are not aware of any deadline requirements being imposed by any one
or any organization for completion of High Speed Rail Service from Orlando
to Miami. Often it turns out the best solution to any problem requires more
time for a well thought out solution than taking short cuts to a lesser
solution. It would be inappropriate to commit funding support for any
proposed project that wasn’t thoroughly evaluated against all other possible
alternatives. The chart below shows a very simple evaluation of the Florida
Turnpike Alignment Alternative compared the AAF Alternative.
COMPARISON BETWEEN TURNPIKE ALIGNMENT
AND AAF/FLAGLER ALIGNMENT
Turnpike
Alignment
AAF Alternative
Quality of Life In the Treasure Coast Communities
No Impact
High Negative Impacts
Loss of Property Values in Treasure Coast
No Impact
20% Loss in Property Values
Business Survivability on Treasure Coast
No Impact
High Potential Impact
Safety at On Grade Crossings
No Impact
Many Accidents Each Year
Vehicle Delays at On Grade Crossings
No Impact
32 More Crossings Each Day
Major Boater Delays at St Lucie River Train Bridge
No Impact
32 More Crossings Each Day
Yes
No
235 Miles
265 Miles
220 Miles / Hour
110 Miles per Hour
1 Hour 30 Min
3 Hours
Cost of HSR Trains
Equal
Equal
Cost of HSR Track Construction
Higher
Cheaper
Time to Initiating Revenue Service (If Needed)
More
Less
Evaluation Factor
100% Grade Separation (Vehicles never meet trains)
Distance from Orlando Airport to Miami Airport
Train Speed
Time of trip from Orlando Airport to Miami Airport
Page 4 of 12
A review of the above comparison chart indicates that the benefits to the
communities of the Treasure Coast that are received from the Florida
Turnpike Alignment more than outweigh the financial benefits that are
received from the AAF / Flagler Alignment.
(Continues next Page)
Page 5 of 12
2. Effect on the People and Businesses Must Be Stated
The AAF EIS must address the effect of All Aboard Florida on the people
and businesses on the Treasure Coast. People and businesses are part of
the Environment on the Treasure Coast. People and businesses are as
important as animals, birds and fish.
Destruction of the Small Town Character / Quality of Life
The Treasure Coast consists of several small towns. The Flagler Railroad
goes through the heart of most of these towns and cuts the downtowns in
two. The proposed AAF / Flagler Alignment with 32 additional trains per
day (passing through the Treasure Coast 7:30 AM to 7:30 PM) means that
approximately 2.3 trains will be passing through the Treasure Coast per
hour or one train every 26 minutes.
Today, small walkable towns like Stuart, Jensen Beach, Vero Beach, and
Fort Pierce have very desirable downtowns where people go just for fun: to
walk around, to enjoy the waterfront, to eat outside at a fine restaurant, to
enjoy art shows in the streets, farmers markets, “dancing in the streets” and
other special community activities. These activities will all be ruined by
noise and vibration from AAF trains traveling through the center of the
downtowns every 23 minutes. Due to this damage to the small town
character, eventually people will stop coming downtown for these activities
and the businesses will suffer losses and eventually go out of business.
People will lose an excellent quality of life and the businesses will suffer.
Florida Turnpike Alignment for the Orlando to Miami High Speed Rail will
maintain the small town character and quality of life of Treasure Coast
business areas.
Vehicle Traffic Delays
32 additional train crossings per day multiplied by the number of individual
crossing points in the Treasure Coast creates thousands of unnecessary
traffic delays across the Treasure Coast daily. The total time delays across
the Treasure Coast will be very expensive for businesses and residents.
Many residents will have to cross the tracks two times to get to their
destinations and two times to return.
Page 6 of 12
Because the 32 additional trains cause thousands of delayed crossings
across the Treasure Coast, there is a good possibility that some
Emergency Vehicles will be delayed each day across the Treasure Coast.
These delays could cause loss of life.
The Florida Turnpike Alignment will not create on-grade traffic delays in the
Treasure Coast downtowns and at other major Treasure Coast train
crossings.
Boating Traffic Delays
Stuart is located almost exactly half way between Orlando and Miami.
There will be 32 additional crossings on the train bridge crossing the St.
Lucie River in Stuart.
If the All Aboard Florida train service begins at 6AM and ends at 9PM at
both Orlando and Miami, that means there will be 32 crossings in Stuart
between 7:30AM and 7:30PM. That time period is 12 hours long or 720
minutes long. 32 crossing in 12 hours is one train every very close to 2.3
crossings per hour.
It takes 17 minutes just for the train bridge to lower and raise again.
Assuming it will take 2 additional minutes for the train to cross the bridge, it
will take 19 minutes per crossing. 19 minutes times 32 crossings equals
608 minutes.
Of the 720 minutes available each day between 7:30 AM and 7:30PM, 608
minutes will be used for trains crossing the St. Lucie River (Okeechobee
Waterway). This leaves a total of 112 minutes between 7:30AM and
7:30PM for boat traffic movement. 112 minutes equals 9 minutes per hour
available for boat traffic. This is unsafe and unacceptable for boaters and
boating related business - even with a published schedule (the proposed
AAF Solution to this problem).
The Florida Turnpike Alignment will not create any boating delays on the
Treasure Coast and therefore, will not severely impact boaters in the
Treasure Coast Community.
Page 7 of 12
Effect on People and Businesses Summary
AAF will create extremely serious, costly, and dangerous problems for the
people and businesses of the Treasure Coast. People and businesses are
part of the environment of the Treasure Coast and should not be
damaged by the AAF Project. The EIS should be revised to include all
alternatives not just the selected financial alternative which is financially
best for AAF at the determent of the Quality of Life for the residents of the
Treasure Coast.
(Continues next Page)
Page 8 of 12
3. Relationship with a National High Speed Rail
The AAF EIS must address how it relates to a National High Speed Rail
(220 MPH) from Boston to Miami with Major express stops in Boston, New
York City, Washington D.C., Charlotte, NC, Atlanta, Orlando and Miami.
Alignment would follow I-95, I-85, I-75 and the Florida Turnpike. Secondary
stops (non-express stops) can be added such as Philadelphia, Baltimore,
Raleigh NC, Greenville SC, Gainesville FL, and West Palm Beach can be
added as demand dictates.
Properly designed 21st-century HSR trains traveling on 21st-century highspeed tracks can travel at speeds up to 220 miles per hour. Travel to Miami
from Orlando along the Florida Turnpike Corridor can take less than oneand-one-half hours. Also, the 21st-century HSR tracks would be 100
percent grade-separated (elevated), avoiding any conflict with people, cars,
or boats.
With a few exceptions, elevated High Speed Rail can be provided within
the existing right of way for the Florida Turnpike. See photo below.
Page 9 of 12
Elevated rails do not require costly grading for drainage. Also, all of the rail
components can be precast and pre-assembled at offsite locations, thereby
saving on-site construction costs.
America needs high-speed rail running from Boston to Orlando, serving the
East Coast States having a current total population over 120 million people.
Several European countries with smaller populations have excellent HSR
Systems. By 2050, America will have an additional 100 million people.
There is no room for additional Interstate highways and in many cities
additional traffic lanes cannot be added. Airplane capacity is maxed out, is
user unfriendly, and costly. High-speed rail (220 mph) from Boston to
Miami, connecting major cities (Boston, New York, Washington, Atlanta,
Orlando, and Miami) is the answer. America needs fast, efficient highspeed rail (220 MPH) from Boston to Miami. America should not strive to
do anything less than has been already accomplished in Europe and Asia.
It makes no sense to have high-speed rail running from Boston to Orlando
at 220 mph and then continuing to Miami at 110 mph, taking three hours on
19th-century tracks. The high-speed rail segment from Orlando to Miami
should follow the Florida Turnpike alignment. It is safer, faster, and not
disruptive to existing communities along the Atlantic Ocean.
(Continues next Page)
Page 10 of 12
4. Benefits for the Citizens of the Treasure Coast Must Be Stated
Since a very large amount of Federal monetary support is required, the
AAF project must be considered a National project – not a local private
business project. The AAF EIS must address how the AAF Project benefits
all of the citizens of the United States and particularly the citizens of the
Treasure Coast. Who benefits most from this project?
How do the citizens of the United States benefit from this Project?
All of the citizens of the United States could benefit from this project by
having the ability to travel by true High Speed Rail (220 MPH) from major
northern cities to Miami. However, the proposed AAF project is proposed to
run at much slower speeds (110 MPH) and takes more than 3 hours from
Orlando to Miami using the Flagler Railroad Alignment. It will take 1½ hours
using the Florida Turnpike Alignment.
How do the citizens of the Treasure Coast benefit from this project?
By searching for the word “benefits” in the EIS, the only reference to
benefits for the Treasure Coast is temporary construction jobs for new track
placement. However, the reality is that these jobs will probably go to
experienced track construction workers from outside the Treasure Coast.
At this point, it seems there are many more detriments for Citizens of the
Treasure Coast than there are benefits.
So, who benefits the most from the AAF Project?
Should the Federal Government be a banker for a project which will does
great harm to the communities in which it operates and provides no
benefits to those communities?
The greatest benefactors of AAF will be the hotels, tourist related
businesses, and perhaps a casino located at the AAF Train Stations
proposed for Miami, Fort Lauderdale, and West Palm Beach. The greatest
detriment of AAF will be the entire population of the Treasure Coast who
will bear the brunt of the environmental impacts and damages for Centuries
to come.
The single element that has the ability to completely alter the outcome of
this Potential Train Wreck is the location of the AAF High Speed Rail track
Page 11 of 12
alignment. The best alignment should be the rural areas of the Treasure
Coast using the Florida Turnpike Alignment. This places the High Speed
Rail System where it can move passengers the fastest, with the least
problems and no reduction in the Quality of Life in the existing Treasure
Coast Communities.
In an ideal world, a comprehensive planning approach to the
transportation issue would include all the issues discussed previously and a
generalized approach including:



Light Rail to the east, using exiting lanes in major roads, such as US1, either with
shared right of ways, dedicated right of ways or a combination. This would
provide fast efficient local travel internal to the Treasure Coast and could
eventually be connected in West Palm Beach to the Tri-Rail thereby providing
convenient passenger travel from the Treasure Coast to South Florida Cities.
High Speed Rail (220 MPH), like the Washington to New York Acela Line, to the
west, located west (along the Turnpike Alignment). This line should be connected
with the national system, should be extremely safe, with no negative impact on
existing small town communities.
Providing Intermodal transportation centers, like the Fort Pierce Inter-Modal
Transportation Center, in Stuart, Vero Beach and Port St. Lucie. Providing
smaller transportation centers in smaller communities such as Tradition, Hobe
Sound, Sebastian, Palm City, and others in the Treasure Coast.
Bottom Line:
The All Aboard Florida (AAF) Environmental Impact Statement (EIS) is
severely deficient and flawed. The AAF EIS must be revised to become a
complete all inclusive document which addresses the major issues and
concerns of the people and businesses of the Treasure Coast.
A more complete all inclusive analysis will reveal at least one
alternative which will provide faster (220 MPH) and safer (100% Grade
Separation) High Speed Rail from Orlando to Miami and which causes
no damage to the Economy in the Treasure Coast and no damage to
Quality of Life in the Treasure Coast.
All of the issues cited in our attached review should be specifically
addressed point by point.
Page 12 of 12