CNU Central Texas Letter on I-35 Cap Ex Central DEIS

March 7, 2023

Marc D. Williams
Executive Director
Texas Department of Transportation
125 East 11th Street
Austin, Texas 78701

Tucker Ferguson, P.E.
Austin District Engineer
Texas Department of Transportation
P.O. Box 15426
Austin, Texas 78761-5425

Tommy Abrego, P.E.
I-35 Program Manager
Texas Department of Transportation
P.O. Box 15426
Austin, Texas 78761-5426

Heather Ashley-Nguyen
Transportation Planning and
Development Director
Texas Department of Transportation
P.O. Box 15426
Austin, Texas 78761-5425

To Whom it May Concern

Please find our previous letters dated March 22, 2022, September 23, 2021, October 20, 2020 and April 24, 2020 which we hereby attach to this letter and re-submit in their entirety as comments for the record. They contain many concerns we previously raised with this important project which we believe are still pertinent to this phase.

We certainly appreciate attempts by TxDOT to resolve issues with I-35 – a dangerous facility which causes daily consternation in this city. We recognize the opportunity to make this corridor a better one, and thereby make our city better and we applaud the time, energy, and efforts behind attempts to do so.

We believe that Austin, like all cities, takes the form of, and is largely shaped by, its transportation network. As such we can think of no more important and impactful ways that our city will be shaped in the next 50 years than by the two major transportation investments being made now: Project Connect, and the rebuilding of I-35. And we believe both these projects should be grounded in shared community wide values and adopted plans for how we want to grow as a community over the coming decade. We reference: the Imagine Austin Comprehensive Plan, the Austin Strategic Mobility Plan, the Climate Equity Plan, the Great Streets Master Plan, the Austin Transportation Criteria Manual. We agree with TxDOT that “No Build” is an undesirable and inadequate response to the problem that is I-35. And we embrace the generational opportunity before TxDOT and our community to shape our city for the coming generations.

That being said, we continue to believe that the preferred alternative presented (the so called Modified Alternative 3) is insufficient in ambition, and remains directly in conflict with stated and adopted plans for the city and as such we cannot support it at this time. In addition to the previous comments we have made and resubmitted herein we note the following defects in the Draft Environmental Impact Statement:

Widenings are an illusory solution to congestion. Modified Build Alternative 3 does not do enough to offset the damage of the existing corridor to the City nor the damage that will be caused by the induced VMT traffic and super-charged sprawl that will occur as a result of the highway widening. We note that in a recent article printed in the Austin American Statesman, TxDOT spokesperson, Brad Wheelis stated that this project’s aim is to reduce commute times for people who live in “places like San Marcos and Georgetown.” We don’t believe that marginally and temporarily improving long commutes for people who live a long way from Austin is sufficient justification for widening the freeway. However, to the extent it does ease the burdens, those commute times will be negatively impacted during the 8 planned years of construction and will inevitably increase as the freeway once again fills with traffic, because no highway widening project can solve the problem of induced demand. At what cost are we willing to get a little temporary relief from congestion for commuters?

The true scope of the impacts of this study are hidden by the partition of a much larger project. The DEIS purports this to be an 8 mile highway widening, but this hides the fact that it is part of an overall 66 mile highway widening project and that much of the data and analysis cannot be taken at face value since only a small segment of the overall project is being considered as part of this study.

The Purpose and Need statement is overly simplistic. Because the Purpose and Need Statement incorrectly states the problem, it is driving bad decisions and bad design. The statement fails to consider many other more important and competing needs of the city such as:

  • Growing as a compact and connected city
  • Being cognizant of the city’s impact on our ecology and climate
  • Creating walkable and complete communities that serve a diversity of people
  • Optimizing land use for return value to the community
  • Prioritizing health, safety, and welfare for all users and non-users of the facility
  • Creating a diversity of housing options in and near the most highly desirable parts of Austin
  • Healing the wound created by I-35
  • Not taking every opportunity to treat the surface elements as true urban places and not mere conduits for traffic.
  • It fails to note that the city has a desired mode split of 50/50 between cars and other means and makes no attempt to assist in that goal
  • Following our local Vision Zero goals and TxDOT Road to Zero goals to end traffic fatalities and serious injuries
  • Reducing pollution and greenhouse gas emissions to reach our Climate Equity Goals

At this time we cannot support moving forward with this project. We encourage reconsidering the various proposed community alternatives put forward by various groups active in this discussion, including Reconnect Austin and Rethink35. We believe Project Connect should be given priority in the project development and construction phasing. Constructing both projects concurrently will unnecessarily harm the community, and we believe Project Connect may obviate the pre-conceived ‘need’ to expand I35.

If TxDOT does move forward with Modified Alternative 3 we ask for the following revisions to make this a better project for TxDOT and a better project for Austin and Central Texas:

  • All surface features including bridges across and frontage roads should be designed as simple, regular city streets and avenues that conform to NACTO or Austin Transportation Criteria Manual standards. Clear zones designed to protect high speed traffic are completely inappropriate for city streets. All surface facilities should be designed for appropriate speeds in dense urban environments – no more than 30 mph. They should include features such as street trees, and on-street parking. They should be multi-modal uses wherever feasible. Lanes should be 10’- 11’ wide and there should not be more than 2 in each direction.
  • Main lanes should be below grade throughout the entire urban core and designed for speeds of no more than 55 miles per hour. This will allow for shorter and less disruptive ramping and creates more opportunities for connections across the corridor. Lower vehicle speeds are safer for all users.
  • Pedestrian crossings across the corridor should be at-grade. Elevated and tunneled pedestrian walkways are seldom used, involve cumbersome and circuitous routes and elevation change, and feel dangerous to many users due to isolation from other users.
  • Create a continuous cap between Lady Bird Lake and Airport Blvd. Support for caps should anticipate the possibility of a wide variety of potential uses which may include parks or multi-story buildings accommodating civic, commercial, office, or residential uses.
  • Increase the number of crossings across the corridor.
  • Replace the suburban-styled SPUIs at Riverside and Airport Blvd with conventional intersections or intersections that do not prioritize through and auto traffic at the expense of pedestrians, cyclists, and other users of the bridges.
  • Recommit to the pledge made to our community to rebuild the freeway “no higher and no wider”.

We implore TxDOT to slow this project down and get to a better and healthier resolution. We believe the City of Austin, TxDOT, and the community can reach an accommodation and that the time we spend working towards that now will pay off dividends for all of our respective communities for generations to come. We hope TxDOT will consider the spirit in which these comments are offered.

Very respectfully yours,

Mateo Barnstone, Director