Farm&City – Letter to TxDOT 04/21

Comments on Public Scoping Period #2 for the I-35 Capital Express Central Project
Jay Blazek Crossley,
April 9, 2021

Thank you to TxDOT staff, leadership, and consultants for all the work on the proposal for fixing the broken I-35 freeway in the City of Austin. In particular, I am profoundly appreciative that the second draft of the Project Purpose and Need Statement gave broad parity in terms of analyzing and addressing the problem of traffic crashes to discussions of the perceived problem of congestion.

Evaluation criteria must be sensitive to reasonable alternative future growth scenarios

The Capital Area Metropolitan Planning Organization regional growth forecast process is flawed, as is the standard practice in Texas MPOs. The model uses the circular logic of sprawl, baking the induced demand of freeway expansions and lack of safe multimodal access into a believe that the region will continue the destructive, costly, inequitable process of developing new car-dependent neighborhoods that are destroying the Hill country.

An explanation of the many flaws of the CAMPO growth forecasts can be found in the linked report Allocation Game: The regional growth forecasts of the CAMPO 2045 Regional Transportation Plan.

Every level of evaluation where travel demand models and regional growth forecasts are a factor in the analysis should entertain the possibility of meaningfully different regional growth forecasts and travel demand model methodologies.

Improvements can be made in travel demand models, regional growth forecasting processes, long range plans, and public processes for major projects. The outdated practices of forecasting a single potential future & building our transportation investments based on that one vision for the future would never be accepted in business, but this is what we do with the $25 billion a year state & local governments spend on roads & public transportation in Texas.

Equitable scenario planning is a suite of practices to consider reasonable future scenarios through community planning processes. Instead of adopting a single official forecast, TXDOT and MPOs would adopt multiple reasonable future scenarios. Investment scenarios and individual projects can then be judged by the costs and benefits expected in multiple scenarios. Entertaining multiple future scenarios bakes resiliency into the transportation planning system, while helping understand the complex tradeoffs of our choices.

TXDOT’s current travel demand modeling system produces illogical results and is incapable of handling the ever more complex needs of the Texas transportation system.

These three sources can help guide TXDOT staff and consultants on how to fix this problem.

Farm&City Report: Allocation Game

Robert Goodspeed, Scenario Planning for Cities & Regions

Norm Marshall’s critique of TXDOT Austin’s Travel Demand Modeling for I-35 Central

Speed kills

Speed is killing Texans and killing people along this stretch of I-35.

There is an error in the Purpose and Need Statement. It insinuates that narrow lane widths are a deficiency. In the context of one of Texas’ most thriving downtowns, narrow lanes of 9 and 10 feet and occasionally 11 feet when absolutely necessary for bus or freight are the safest way to design streets. The deficiency in the current arrangement of I-35 is that it is haphazardly designed for high speeds. This should be corrected.

Every element of this project should begin with safe design speeds for the urban context. All surface elements where there is any possibility of interaction between pedestrians and people driving vehicles should be designed as downtown urban streets with 25 mph design speeds.

There is no public benefit to anyone traveling through downtown Austin at a speed greater than 45mph, while there is significant suffering as a result of high design speed inappropriately used in this setting today. The controlled access freeway and managed lanes should be designed to provide consistent, safe access at 45mph. This can be achieved with narrow lanes, curves, use of green elements, artwork, and creative engineering.

Meaningful Alternative Scenarios

Currently TXDOT is proposing three different designs of the same proposal. While community design proposals are being considered as a separate outside of the NEPA alternatives process.

Shirley Nichols told us on a Reconnect Austin meeting unequivocally that TxDOT is now open to considering community alternatives in this scoping process through the summer. Diverse members of the community are begging for TXDOT to consider meaningful alternatives to the one alternative presented so far, but so far, no meaningful alternative other than no build has been added to consideration.

TXDOT must not proceed with simply considering three slightly different design options for a single investment proposal. Many people like this proposal to double car-priority lane capacity on this freeway, and maybe it will prove to be the option that the people of the Austin region want, but this will not be a successful EIS process without at least one, but preferably several meaningfully different investment proposals to be fully considered in the process.

It seems possible that TxDOT simply has not received a concrete proposal in terms of numbers of lanes and configurations and this is the reason that so far only one alternative has been presented. Thus, I request that a meaningful alternative for I-35 that includes all of these details be considered as a full build alternative:

  • Design for the entire Reconnect Austin vision of a continuous cap and restored historic urban street grid from the Colorado River to north of Airport Boulevard
  • Establish two consistent through “free” car-priority lanes in each direction
  • Use 1 or 2 collector distributor lanes in each direction used where necessary and efficient
  • Establish two high occupancy toll managed lanes on each side tunneled
  • Use two surface lanes in each direction, designed as 25mph urban streets or combined into an urban boulevard
  • Design all surface elements to 25mph urban multimodal street standards
  • Design all limited access lanes to 45mph urban freeway standards
  • Add an additional multimodal street crossing between 51st and 290
  • Add an additional multimodal street crossing at Barbara Jordan
  • Add an additional multimodal street crossing at St. Edwards Drive / Royal Hill Drive.
  • Maintain a multimodal street crossing at Holly Street
  • Add as many as possible of historical multimodal street crossings at downtown urban block lengths.
  • Design high occupancy toll lanes to be optimized for bus transit, with direct connections at logical points, ready for AV/CV, and use toll pricing and high occupancy vehicle policies to maintain a consistent travel speed of 45mph for transit vehicles.

Opportunity for Equitable Transit-Oriented Development

The Austin region should plan for a majority of residents to have affordable options to live in walkable urban places connected by high quality transit. Cities and states across the country are using suites of equitable Transit-Oriented Development policies to allow dense development without displacement.

TxDOT should develop an eTOD policy and develop metrics to analyze investment scenarios based upon how well they facilitate this type of development.

Air Quality

The idea that TxDOT cannot do a meaningful comparison of air quality impacts in the evaluation criteria because there is a plan to only consider one investment scenario is absurd. Greenhouse gas emissions and human health impacts of particulate matter, ozone, and other air quality health impacts must be measured and must be used to evaluate meaningfully different investment proposals.

Analyzing the No Build Scenario with the flawed CAMPO region growth forecasts that themselves already assume the induced demand of widening this – as well as many other – freeways is not acceptable.

  1. There is a flaw in the air quality assessment
    • The flaws are:
      • Circular logic of forecasts.
      • Only considering one scenario (with different designs)
  2. AQ should be added back as an evaluation criteria
  3. AQ effects of different meaningful alternatives
    • This requires meaningful alternatives.
      • It could be done with just no build an the one proposal
    • Study emissions and impact on human health
      • At various points near and far from the project
    • Study climate emissions impacts
    • Allow regional growth forecasts to vary in this part of the process.
      • Allow community discussion group to do equitable scenario planning process to determine a set of alternative growth scenarios that includes official scenario.
  4. The TXDOT climate emissions study is clearly flawed, as it assumes the flawed regional growth forecasts used by Texas MPOs and ignores TXDOT’s actual role in increasing future vehicle miles traveled and potential climate emissions.

Suggestions on optimizing the community input in the VOICE process

  1. Can it be meaningful? Will concepts from these groups have the possibility of implementation? What are the limits on that?
  2. Will TXDOT be facilitating a community discussion or engaging in discussion itself, like we’re doing today? I really appreciate the extraordinary opportunity to meaningfully discuss and even argue with TXDOT staff and consultants. But that often means that my suggestion is refuted by TXDOT staff or a consultant immediately after I say it. If VOICE is to be a community discussion, then this is inappropriate and TXDOT should instead serve as a facilitator, while figuring out how to provide information but not refute people in that process of developing community visions.
  3. Can this be iterative and include statistically valid surveys? All in person or Zoom community input processes have selected groups on all sides who get to the table. But it is possible to do statistically valid surveys of the people of Austin for a couple thousand bucks. However, if you could combine the community visioning process with statistically valid surveys and allow the community visioning people to come up with questions to ask the 2 million people of the Austin region, that could be very powerful.

Statistically valid public opinion polling

A set of evaluation criteria should be added that ask the 2 million people of the Austin region what they think about the investment proposals through statistically valid public opinion polling such as is done with the Kinder Houston Area Survey.

The questions should be developed by the participants in the VOICE process with guidance from TxDOT and public opinion polling experts.

This should be an iterative process where various elements of the project are tested, refined, and tested again.

While these should not be the only decision making tool, they should have a measurable impact along with other evaluation criteria.

Inclusive design and planning for people of all abilities

Of course, TxDOT should strive to do an exemplary job of following the letter of the law on the American with Disabilities Act, ensuring that traditionally considered treatments, such as wide sidewalks and safe crossings make up a complete grid network of sidewalks for the entire project area when work is complete.

However, TxDOT should conceptualize this project through a much broader lens of total inclusion from the beginning. Navigating a wheelchair across the 51st Street bridge, where there is a great roundabout, raised intersections, and sufficient sidewalks remains a terrifying experience with people driving all around you at horribly dangerous speeds, long blank spaces and concrete wastelands between disparate developments designed with high speed egress for people driving way too fast on feeder roads.

Designing the core of the City of Austin around the dispersed thinking of car-priority lanes and car-dependency makes a huge gash across the Austin region that is not a nice place to be a pedestrian with a disability.

As noted by Michael Lewyn in the article “Cars, Transit, and the Disabled” published on Planetizen (, the disabled drive less than other Americans and deserve not just a sidewalk on the side of a monstrous freeway, but an entire world designed with their complete freedom to engage with other people, jobs, education, parks, and other amenities.

If the environmental process determines that controlled access car-priority lanes are necessary, as much as possible of them must be sunk in a way that the entire historic urban street grid can be rebuilt, as a safe, comfortable urban space, suitable for people in wheelchairs, children, the elderly, and people of all abilities. Spaces should be designed with seating, shade, safe pedestrian nighttime lighting, to yield human scale places for all of us.

Use lane miles to provide a concrete way to discuss the freeway expansion or not questions

TxDOT should analyze the total lane miles of controlled access lanes, surface street lanes, and ramps, etc, for the No Build scenario, the three design proposals for the single investment proposal, my proposal detailed above, and other meaningful design alternatives. This measurement will give the public an accurate understanding of how much capacity for traffic is being proposed and how much concrete we’re really talking about in each scenario.

The structural inequity of the Austin region’s transportation decision making system

The Capital Area Metropolitan Planning Organization does not equitably represent the people of the Austin region, with the people of Travis County denied equal representation. The race, ethnicity, and gender make up of the CAMPO Transportation Policy Board do not represent the people of the Austin region fairly. The various decisions, including the regional growth forecasts, the Regional Transportation Plan, and support for the proposal to expand I-35 were all done within this context of inequitable, undemocratic decision making which is a violation of Title VI of the Civil Rights Act.

Measure equitable access not crude long distance delay

Measuring travel time is a crude and relatively meaningless measure compared to what is possible with today’s computer power and a couple good GIS interns. Measuring travel time only barely captures the needs and desires of long distance commuters, a small minority of the people of the Austin region, who tend to be wealthier and whiter than the rest of the people of the Austin region. Instead, TxDOT should measure access using a methodology that allows for variations in benefits for different areas of the region, such as analysis based on Transportation Analysis Zones (TAZ).

I suggest using the methodology explained in “The Why and How of Measuring Access to Opportunity: A Guide to Performance Management,” a publication of the Governors’ Institute on Community Design, a partnership of the U.S. Environmental Protection Agency, U.S. Department of Transportation, and Smart Growth America.

TxDOT should present information on all meaningful investment and design alternatives in a way that can compare how people who live within a couple miles of the project, compared to people living north and south of the project.

The inequity of using crude travel time measures can be overcome by conducting similar analysis for people across the region by developing travel time opportunity zones for every TAZ in the region and analyzing how the proposed transportation investments might improve or impede access.

However, measuring how long it takes to drive 7 miles is also not actually getting at the human needs and desires adequately. Travel time analysis should be combined with density analysis of all the things that you can get to within a certain travel window, as explained in the one page report attached “How many jobs are in your opportunity zone?” that I wrote in 2007.

And of course, only measuring travel time by car or truck is inequitable and could be considered a violation of the Americans with Disabilities Act and Title VI of Civil Rights Act. People of color, low income people, and people with disabilities are less likely to own cars, more likely to use transit or walk to places, and if they do drive, drive less miles than wealthier or privileged people.

Car travel time should never be used to plan billion dollar transportation investments with equivalent analytical muscle being used to understand improvements in access by all modes of travel. While in the past, this was too difficult to do, this is no longer the case. If TxDOT continues with car-centric analysis, the analysis itself should be questioned on these equity grounds as violations of Federal policy.

The Cost of Crashes

It is not acceptable to use “annual cost of delay” as a metric without using an equivalent treatment for other well known costs of various transportation investment alternatives. In the “Enhancing safety within the corridor, please add a line for “annual cost of crashes.” This cost should be developed using the National Safety Council estimation methodology as shown below. This methodology is also used by the Federal Highway Administration and TxDOT.

TxDOT must find reasonable ways to estimate crashes by severity in different future scenarios with different investment packages. This estimation methodology must be sensitive the variations in vehicle mines traveled (VMT), to include the direct correlation between increased VMT and increased crashes and severe crashes.

This analysis should incorporate reasonable scenario planning techniques that allow the regional growth forecasts and travel demand models to vary based on the known induced demand effects various investment packages will cause.

I ran my own query using the TXDOT CRIS system. My query did not match with the data presented in the Purpose and Need Draft Technical Report, I-35 Capital Express Central Project (March 2021) in Table 1: Capital Express Crash Severity Summary. My method was meant as a crude test to compare to the TXDOT numbers and because I was curious what the 2020 numbers were.

So I used the NSC methodology to estimate the costs of crashes along this stretch of I-35 Capital Express in the central project area, using both the TxDOT numbers from Table 1 and the numbers I retrieved from CRIS.

Using the TxDOT numbers from Table 1, the annual economic costs of crashes in 2018 on the people of the Austin region just in this section of I-35 was $35,158,300 in 2018. However, the NSC has two other methods. One uses just the total fat crashes to estimate total costs of crashes. Using this second method, the estimate of economic costs is $83,160,000. The third methodology incorporates pain and suffering and future years of life lost. The comprehensive costs of crashes along this stretch of highway in 2018 was $254,066,053.

Using the numbers I pulled from CRIS, the annual economic costs of crashes in 2018 was $90,483,400, or $118,800,000 using the method based only on fatalities, and $545,233,237.

This can be compared to the estimated costs of congestion presented by TxDOT. The Texas A&M Transportation Institute estimate is presented that congestion in the entire Travis County section of I-35 – representing not just the central project area, but also the north and south projects – was “more than $200 million.” The American Transportation Research Institute American Highway Users Alliance methodology is presented as estimating that the congestion caused by the “bottleneck” in downtown Austin costs about $73 million a year in lost value of time.

It must be noted here that it is highly inappropriate for TxDOT to publish data from a road spending lobbying entity, ATRI, in this public document. TxDOT should avoid lobbying the public in this document, but instead should seek to provide the public with good information and work with the public to develop the project that the people of the Austin region want, not what a national truck freight lobby wants. Of course, many people of the Austin region are employed in truck freight and the people of Austin enjoy the many benefits of truck freight. But TxDOT should not carry the water for this lobbying entity in this process. Let them submit their own public comments like the rest of us.

Seeing as crashes are such a bigger problem on this roadway than congestion, the Alternatives evaluation criteria must be revised to ensure that the costs of crashes in the proposals for rebuilding this roadway are included and given greater or at least equivalent weight to addressing the costs of congestion.

The Texas Transportation Commission adopted a goal to cut traffic deaths in half by 2035 and end traffic deaths statewide by 2050. The Capital Area Metropolitan Planning Organization Transportation Policy Board recently adopted commensurate measures for the Austin region.

The primary goal, the primary purpose and need of this transportation project should be to invest in transportation improvements expected to eliminate the scourge of serious crashes.

Metrics should not focus on reducing all crashes, but give a higher priority on eliminating traffic fatalities and serious injuries in particular, while reducing the total cost of crashes as much as possible. TxDOT must not make the grave mistake of using “crash rates” that measure peoples’ deaths against vehicle miles traveled in its process to decide how to fix this broken roadway. Measuring traffic deaths or crashes per VMT is a perverse measure that allows planners to imagine a future with just as many people dying in our streets, but with people driving more, a fictitious victory can be declared on the proposed reduced deaths per VMT.

The goal is to build something here that is a crucial element of a comprehensive approach to eliminating the rolling tragedy that is traffic deaths and serious injuries on I-35.