December 17, 2020
I-35 Capital Express Central Project
Attn: Project Team
1608 W. 6th Street
Austin ,TX 78703
Re: I-35 Central Project—Downtown Alliance Comments to Draft Purpose & Need
Dear Project Team:
The Downtown Austin Alliance represents over 900 property owners and 96,000 employees, and the length of our district’s eastern edge borders IH-35 frontage. We seek to protect and promote the value and vitality of downtown Austin. The reconstruction of IH-35 through the heart of this fast-growing city has the potential to create enormous economic, health, social, cultural and other positive impacts for Austin and the entire region. Despite making up only 0.5% of Austin’s land area, downtown Austin generates 9% of its property taxes, 11% of its sales taxes, and 47% of its hotel occupancy taxes, making downtown 20 times more valuable per acre than the citywide average. Downtown Austin is also the home of the State Capitol and State government, and the cultural heart of the region.
The future of this corridor and the design you ultimately adopt for the I-35 Capital Express Central Project (the “Project”) is critical to the economic vitality of our district and the commercial and cultural core of Central Texas. To ensure the Project supports the economic potential of our region, we respectfully request that you revise the October 10, 2020 draft Purpose and Need Technical Report to reflect the following:
- Co-design the Project with the community and include Our Future 35 community alternatives and the Downtown Austin Alliance ULI study recommendations—even in pre-engineering phases—as part of the full Environmental Impact Statement.
- Prioritize safe, local access and connectivity to, along, and across the I-35 corridor for all modes, ages and abilities to enable greater access to the urban core. Create a safe and integrated local street network at the surface level to ensure that all people, regardless of mode, can safely and efficiently get around.
- According to a 2015 study by the Texas Transportation Institute, 86% of the travelers on I-35 through Austin are local. Many of those travelers are Texans who live and work in the dense communities surrounding the highway—in downtown Austin, fast-growing east Austin, or the University of Texas. Their needs must be prioritized.
- Enable all surface roads to be designed as part of the city street network, providing both east-west and north-south access for all ages and abilities with separate facilities for bicycle and pedestrian mobility; mitigate traffic spillover into adjacent neighborhoods and communities.
- Study alternatives with a narrower footprint.
- Austin’s population will double by 2049. To continue to move more people in and out of central Austin, coordinate transit planning with the City of Austin and Austin Transit Partnership. Provide for optimal transit access to and from the Project and enhanced transit operability at the surface level.
- Design the Project to minimize fatalities and injuries within the Project limits for all transportation users.
- Use microsimulation tools to study and evaluate local traffic as part of the traffic modeling.
- Rectify the long-standing, disproportionate racial and economic impacts of the original I-35 project that persist in disparities today. This Project must heal past impacts to Austin’s People of Color resulting from its original construction, and not repeat such mistakes.
- Document and preserve the historic and cultural fabric of the community, including land, businesses, civic spaces, and housing with historic ties. Preservation is critical to avoiding the mistakes of the past.
- Mitigate long-standing disproportionate impacts by providing new or reclaimed lands (either as caps and/or repurposed right of way) for community uses that would be defined by a local, community-driven process.
- Conduct an equity assessment as part of the NEPA process.
- Conduct a human health and well-being impact analysis as part of the NEPA process that documents both existing and future impacts to physical and mental health (inclusive of our elderly, children, and health-vulnerable populations).
- Create a proactive plan to ensure the care of those currently experiencing homelessness near the Project.
- Advance an alternative that enables the safe physical reconnection of communities at the street or surface level without further displacement and results in welcoming spaces for everyone.
- Create all necessary solutions to ensure that People of Color (residents, businesses, institutions, organizations) are not further impacted by the construction of I-35. This includes mitigating the temporary loss of access for businesses and the loss of access to cultural institutions, educational institutions, parkland, greenspaces along our waterfront, cultural institutions, or other community amenities that result from the construction process.
- Shrink the footprint of the Project and fully evaluate and mitigate its environmental and community well-being impacts. Enable the transformation of the surface into public spaces that are integrated, walkable and vibrant—spaces for everyone that reflect the culture and quality of life that attract so many people to Austin. Moreover, mitigate the physical and mental health impacts of living and playing near highways and improve multi-modal access to schools and healthcare.
- Design to reduce vehicle miles traveled (or VMT) along the Project, which allows for the consideration of a variety of strategies to reduce transportation impacts on air quality and noise pollution.
- Provide a minimum of 90 days of public comment for all future comment periods. Proactively educate everyone about the Project so that all impacts of design/ engineering decisions and build alternatives are known and understood by the community.
- Create transparent reporting of methodologies, measurements, and analysis of impacts.
- Provide interim reports related to traffic modeling, climate change modeling, alternative designs, engagement outcomes, and other assessments.
President & CEO