March 4, 2023

Chairman Bugg, TTC Commissioners, and TxDOT Officials:

After reviewing the draft environmental impact statement for the I-35 Capital Express Central project, the Downtown Austin Neighborhood Association (DANA) opposes the latest TxDOT plans for expanding I-35 through central Austin. We respectfully urge the Commission to choose the “no-build” option for now and instead begin developing alternatives based on community-proposed visions presented at Rethink35.com and ReconnectAustin.com.

Alternatives based on Rethink35 and Reconnect Austin would improve air quality and safety, reduce noise and vehicle miles traveled, slow climate change, unlock economic potential, and expand the tax base.

Additionally, we reiterate our view that:

• The highway’s footprint should be no higher and no wider than it is today, and should be narrowed to the greatest extent possible to reduce the barrier it creates and to shorten crossing distances, particularly for those traveling via active transportation modes.
• The I-35 corridor should be supportive of all transportation modes, with careful attention paid to active transportation. The bikeways and sidewalks along and across I-35 should be comfortable, safe, continuous, fully connected to Austin’s active transportation networks, and protected from traffic by a buffer of at least 20 feet.
• The surface level of I-35 should include as many crossings, for all modes of travel, as possible.
• Any surface level frontage roads should be designed to city standards and function as city streets, and should significantly improve safety for vulnerable road users.
• Street trees should be provided between the roadway and the active transportation paths.
• This project should bring improved access and usability to all parks and trails directly impacted, including Palm Park, Town Lake Metropolitan Park, Waller Beach, and the Butler Hike-and-Bike Trail.

Regarding air quality, we also urge TxDOT to include, not just impacts on carbon monoxide (CO), but also impacts on nitrous oxides (NO2), particulate matter 2.5 (PM2.5), and particulate matter 10 (PM10) in its evaluation of alternatives. It is especially important to minimize PM2.5, as the Environmental Protection Agency (EPA) will tighten its PM2.5 standards this year, bringing Austin into nonattainment. Further, we believe any analysis should include the long-term (20 – 40 year) impacts, not just short-term construction impacts, on greenhouse gas (GHG) emissions.

Impact analyses should also consider runoff into Lady Bird Lake during construction, compliance with the Clean Water Act, as well as potential measures to mitigate runoff.

As Austin proceeds with the design and implementation of the much-needed Project Connect transit system, if TxDOT elects to move forward with I-35 expansion, we encourage the Commission to delay implementation until the new transit system is in place. This system would provide convenient access to downtown for many during I-35 construction.

Thank you for your consideration of our input. We look forward to continued constructive involvement in future I-35 discussions.

Sincerely,

Board of Directors
Downtown Austin Neighborhood Association (DANA)