U.S. Department Commander 909 SE 1* Ave Rm 432
i Seventh Coast Guard District Miami, FL 33131-3050
of Homeland Security Staff Symbol: (dpb)

Ss Phone: (305) 415-6989

United States Fax: (305) 415-6763
Coast Guard Email: Evelyn.Smart@uscg.mil

16591/AAF
02 June 2014

Charlene Stroehlen PE

Senior Associate Engineer

AMEC - Environment & Infrastructure
404 SW 140th Terrace

Newberry, FL 32669

Dear Ms. Stroehlen:

In March 2014, the U.S. Coast Guard received a draft copy of the Navigation Discipline Report
(NDR) for the AAF Passenger Rail Project from Orlando to Miami, Florida. The Coast Guard
reviewed and provided comments on the NDR on April 4, 2014. Since then a revised advance
copy of the NDR was given to the Coast Guard for a second review on May 8, 2014.

The Coast Guard agrees the revised NDR is more comprehensive than the first study and
provides useful data on current use of three major waterways with drawbridges along the AAF
corridor (New River in Broward County, Loxahatchee River in Palm Beach County, and the St.
Lucie River in Martin County). In Sections 2.6.2 and 6.0, the NDR addresses evaluation criteria
and a criteria matrix for assessing the No-Build Alternative and the Proposed Action’s impact on
identified navigation needs. While information on the impacts on navigation received from the
applicant will be analyzed, the Coast Guard will make the ultimate determination as to whether
or not the impacts on navigation are unreasonable.

The Coast Guard, in making a permit decision, must preserve the public right of navigation while
maintaining a reasonable balance between competing land and waterborne transportation needs.
We do so by taking a balanced approach to total transportation systems, both land and water
modes, in all bridge actions. At this time, we are unable to fully assess the potential impacts and
will require more information on the following issues prior to making a permit decision:

1. The impacts on navigation from the natural flow of these waterways, including currents
and water velocity fluctuations, while vessels await openings at these drawbridges,
remain unknown;

2. The affected drawbridges set the most restrictive vertical clearance on these waterways,
and a large percentage of vessels cannot transit the bridges in the closed position;

3. Any increase in the existing closure periods at the drawbridges spanning these waterways
may not provide for the reasonable needs of navigation;

4. The methodology used in the NDR may be sufficient to assess the waterways’ trends and
uses for purposes of making a navigation impact determination. However, the Coast


Guard is unfamiliar with the model and needs to evaluate the assumptions and data
therein.

Accordingly, additional study will be required to determine the reasonable needs of navigation
on these three waterways in the vicinity of the drawbridges. To advance the NEPA process, we
support including the NDR as an attachment to the DEIS as it informs the choice of alternatives
for analysis. The DEIS should note that the Coast Guard still must make a determination as to
the prospective impacts on navigation in the vicinity of the three drawbridges spanning the New
River in Broward County, Loxahatchee River in Palm Beach County, and the St. Lucie River in
Martin County and that the DEIS will be used to inform that Coast Guard determination.

If the Coast Guard determines the proposed AAF operating schedule unreasonably impacts
navigation on the New River, Loxahatchee River and St. Lucie rivers, it may be necessary for the
Coast Guard to amend existing bridge regulations and require modifications to those bridge
operations so that navigation is not unreasonably burdened.

(Miss) Evelyn Smart will continue to be the contact for your project.

By direction

Copy: Commander, Coast Guard Sector Miami (s, sp)
Commandant (CG-BRG), U.S. Coast Guard
Jose Gonzalez, FECI/AAF
Alex Gonzalez, FECI/AAF
Mr. Chris Bonanti, FECI/AAF