Re: I-35 Capital Express Central project

To Whom it May Concern:

We write in response to the latest revisions to Alternative 3 in the I-35 Capital Express
Central Project.

Before delving into detailed feedback about specific aspects of TxDOT’s latest proposals, we must state that this program is ill-conceived and badly premised on the mistaken notion that congestion relief is achievable and desirable, induced demand doesn’t exist, and that throughput is more important than other critical goals (see our previous letter). For decades, I-35 has severely impacted Austin and Central Texas in a host of ways; instead of TxDOT’s refusal to address the many impacts – beyond vehicle throughput – of its own infrastructure, the agency should be institutionally and financially invested in addressing all these aspects. That means, before spending billions on I-35, we should look into more effectively using existing facilities, such as SH-130, for non-local traffic and comprehensively study all design alternatives, including Reconnect Austin and Rethink35, for I-35 through Austin.

While I-35 should be rebuilt, this program is doubling down on a more than seventy year failed policy of highway expansion that has been fueling soulless sprawl, auto-dependency, inequity, and all the societal, culture, economic, ecologic, and physical ills that come from such including but not limited to traffic deaths, disconnected and incomplete communities, degraded natural areas, and pollution and greenhouse gasses.

TxDOT is wrong to value the illusory goal of congestion-relief at the expense of economic development, resiliency, climate action, safety, complete communities, and thinking about how best to move people around the city to their daily needs, wants, and desires. We think the objections (“this is Texas, people drive cars”) makes about as much sense as designing a city for 10’ people and saying “this is Texas, people like to use stilts.” TxDOT and other traffic engineers have put the car(t) before the horse; people use the mode you design for. If you design the city for cars – of course this will be the mode of preference – how could it not be? Freeways make for immiserating conditions for all other users and make everything other than a car a burden.

We, at CNU-CTX, advocate for an entirely different model of building places, one that has thousands of years of success in building communities that people love. While the car has a role to play in modern cities, planning for car capacity results in more cars which results in more planning for cars, which results in ever more cars. This is a cycle that we need to break and we need to break it now.

If we planned for cities built for people, the role of the highway would be to connect those cities to each other. But the city itself, should not and cannot be built on the premise than every active member of a household must have a working, funded, maintained, and fueled automobile just to be a functional person in society.

TxDOT needs to broaden its thinking beyond just moving cars to addressing all aspects that its facilities impact. TxDOT also needs to work with other agencies to ensure that its facilities are compatible with real places that people love and which make cities livable for all.

The updated Alternative 3 moves the project forward modestly, although its premise is still fundamentally ill-conceived. What follows are our feedback related to Alternative 3’s specific design elements:

1. Let the highway be the highway and design the surface lanes as city streets. We appreciate the
   moves towards creating a boulevard concept through some sections of the central city. However,
   connecting the frontage roads and signing them for 35 MPH is not enough. Surface features should be
   treated and function as normal city streets.

Here’s what we mean by that:

Surface streets should be multi-modal, designed for all users and be sensitive to the context of the area they are in. In dense downtown areas streets should have wide sidewalks for pedestrians, cyclists, users of scooters and other mobility devices. More than just spaces to pass through, downtown streets should also be comfortable and inviting places for spending time, and a wide spectrum of other activities that enrich a city’s civic life. Streets in these areas should be places for loiterers and buskers, lovers and friends, window shoppers, dog walkers, sketch artists, vendors, and cafe patrons. The reason our streets should accommodate all these people and activities (and more) is that streets are not mere thoroughfares for traffic – streets are also places. TxDOT’s primary error here is thinking that they cannot design places – but that is exactly what a street is. And if TxDOT cannot design them as such then they should turn it over to the City of Austin.

Design for 30MPH maximum. Streets should be places for people in addition to being traffic conduits. 35MPH is too fast for any downtown street; the maximum speed on any downtown street should be no more than 30MPH. Good streets should have buffers, such as on-street parking or trees (and not clear zones), between the pedestrian realm and traffic.

Prioritize safety over speed. USLIMITS2 from FHWA provides guidance and a calculator to determine appropriate design speeds in context. TxDOT should be using this guidance to prioritize the safety of all road users on surface level streets.

Include trees. No street in Austin should ever be built without a row of street trees between the sidewalk and the street. Species should be carefully chosen for health and longevity in urban environments and which create high and broad canopies under straight trunks providing shade during hot summer months and letting light through in the cooler winter months.

One point that has been made in conversations with the community is that the highway carries NAFTA traffic and that it must accommodate large trucks. Certainly we do not dispute that with regards to the main lanes. However, when trucks depart the main lanes and enter the city streets the expectation can and must be that they will do so at appropriate speeds and on appropriately scaled streets. If trucks are accessing our city streets, then the frontage roads can be built to those same standards.

Restrict the boulevard to no more than 11’ lanes and and no more than 2 lanes in each direction. TxDOT should use NACTO standards in designing the surface streets, which should include all frontage roads, bridges across the freeway, and any other surface facility.

Create a pedestrian-friendly environment. Sidewalks should be wide and accommodate purposefully planned street trees. There should be space allotted for sidewalk furniture and pocket parks. Crossing distances should be kept short and utilize bulb outs when possible. Turns should be made at right angles, and slip lanes, free right turns, and such should be avoided.

2. Do not use SPUIs. The SPUIs at Riverside and Airport Blvd are inappropriate for urban areas. Such a design puts all other modes in peril or inconveniences them with long circuitous routes often involving grade changes that are difficult and uncomfortable for many to navigate. Conventional crossing at the surface with the main lanes depressed is the best option for crossing the corridor.

3. Make all pedestrian crossings at-grade. We appreciate and support the proposed at-grade crossing at Wilshire. With more thoughtful design of ramps, this section between Manor and Airport Blvd should be designed to accommodate a future cap. All other proposed elevated pedestrian crossings should be also designed to be at-grade connections with protected crossings across the frontage roads.

4. Make MLK a multi-modal bridge. Such a bridge should accommodate pedestrians on both sides of the bridge with protected crossings at the frontage roads.

5. Minimize Displacement. Stacking the boulevard and frontage roads over main lanes will significantly reduce the right of way needed for this project, minimizing the destruction of central Austin homes and businesses. Stacking will reduce crossing distances and the barrier created by I-35.

6. Create a continuous cap through downtown from the river to Airport Blvd. A cap should accommodate public spaces such as parks, trails, and plazas, or buildings with space for retail, office, civic uses, and housing. Footings for those caps should be designed to support the level of development the City of Austin and stakeholders deem appropriate for the existing urban context.

Highway caps mitigate the damage done to the urban environment by I-35. Caps should be integral to this project and paid for by TxDOT to provide necessary mitigation.

We are attaching our letter dated September 23, 2021 and make reference here to the other suggestions included within that letter but we would like to highlight the following:

7. Phase the project appropriately. Before a final design is chosen, the public must see a fully developed plan for what will happen to traffic during I-35 construction; such a plan must incorporate induced demand (as must any final plan for I-35 itself).

8. Use portal ramps rather than traditional ramping in the urban core. Best practice for highways in urban areas is the use of portal ramps, like those used for the Klyde Warren Park in Dallas. Portal ramps reduce the barrier of the highway and tell drivers exiting the highway that they are entering an urban environment.

In addition, Project Connect must be built before any I-35 construction begins. Project Connect is in the NEPA study currently headed for final design and will be under construction in approximately 5 years. That project should be finished first to give people viable transportation alternatives during I-35 construction. In Dallas, work on DART was completed before work began on SH-75 (the Central Expressway). A similar timeline must occur with I-35.

Project Connect was voted on by a substantial majority of the city. It is the expressed and desired will of the community to see this project completed as quickly and as efficiently as possible. We think the idea of engaging in both a highway project and project connect simultaneously is likely to result in a massive years long snarl. Don’t do that. Phase the projects in the way that makes the most sense, and give the community time, time enough to come to a consensus on the appropriate design for the freeway.

Making these changes won’t fix TxDOT’s wrong-headed premise for this project, but it will improve it for all users of this corridor (including the drivers) in the center city.

In an era of worsening climate change and with a new societal-wide emphasis on equity and redressing the enormous harms of highways, we urge TxDOT not to repeat previous mistakes but to bring new thinking to the Capital Express Central Project, making sure the project truly addresses the community’s many needs. As CNU’s Highways To Boulevards program and countless recent media articles have documented, communities across the country are rethinking highways. It’s time for the era of highway expansions to end.

Very respectfully yours,

Mateo Barnstone, Director

CNU-CTX