Farm&City – Letter to TxDOT 12/20

Jay Blazek Crossley, Farm&City
Comments on the I-35 Capital Express Central Project
December 31, 2020

We need to fix I-35 in a way that reconnects Austin, equitably plans and allocates resources, gives top priority to ending traffic deaths, and does not add any non-managed lane capacity to the corridor. Please consider the following concepts in rewriting the draft Purpose and Need, Range of Alternatives, and Agency Coordination reports and plans.

The 20th Century is long behind us. We should rebuild the I-35 corridor with equity, sustainability, safety, and access as our top concerns, abandoning the failed practice of focusing on speed and long distance trips. The people of Austin deserve better and TXDOT has the opportunity to build something the people of Texas can be truly proud of at the State Capitol. The EIS process should question our old assumptions, should be transparent and collaborative with the public, and should use the best information, design standards, and modeling systems possible focused on improving safe access for people, not vehicles.

The Agency Coordination plan needs to be updated as such:

  • Key public involvement and stakeholder outreach efforts that will be undertaken throughout the project development and NEPA process include:
    • Development of a project webpage;
    • Mailed and emailed notifications to stakeholders;
    • Public meetings, including scoping meetings, open houses, and workshops; and a public hearing.
    • Comprehensive consideration of public input that allows for meaningful and significant changes to the project proposal.

Seriously consider the full Reconnect Austin vision

Highway lanes should be depressed as much as possible, with highest priority on the highest activity centers, starting with Downtown. A continuous cap should be built in a way that allows a walkable, urban boulevard on top of the freeway. We should restore the historic urban street grid and build a dense, urban fabric of buildings through an equitable growth strategy that incorporates affordable housing, gives power to historically marginalized communities to shape, but not block the growth of mixed-use, mixed-income community.

Use equitable scenario planning throughout the environmental process

The Texas Department of Transportation (TXDOT) should entertain meaningfully different investment scenarios, along with the single proposal to build 20 lanes put forward in the initial scoping draft. These must include at least one good version of the Downtown Austin Alliance / Our Future 35 proposal or Reconnect Austin, but should also include studying the concept of switching designations and removing the freeway entirely from the urban core – even though most believe this is a politically unviable solution.

Analysis in the Environmental Impact Statement (EIS) process should utilize multiple alternative growth forecasts, not just the single politically tainted Capital Area Metropolitan Planning Organization (CAMPO) growth forecast, which we characterize as “colonizing the future.” Analysis should meaningfully entertain the possibility of dramatically changing travel patterns, either by using better, more up to date travel demand models or simply by varying assumptions in the model to analyze different possible results. Every analytical process, design process, and scenario generation process should be equitably done with appropriate public input throughout, equitably seated focus groups, and a willingness to hear diverse concerns, instead of simply preparing to refute them.

The Federal Highway Administration encourages DOTs and MPOs to adopt scenario planning to yield better planning for the future, including through the report “Supporting Performance- Based Planning and Programming through Scenario Planning.”

The information on the potential for future traffic presented to the public in the draft scoping document is inadequate, and almost seems misleading. There are claims that are on their surface ridiculous, such as the proposal that tens of thousands of people would drive on I-35 at rush hour even if it took two hours to get from 71 to 290.

I asked at the beginning of this public comment period for the background methodology for the traffic projections to try to better understand and spread to the public a better understanding of what TXDOT was saying. I finally received some information several days before the public comment deadline, so I do not feel able to specifically critique these methodology. However, I plan to continue working on this to try to help TXDOT and consultants work toward a better system for analyzing future travel along this corridor and help make better decisions on how to best invest our transportation dollars to improve the lives of Texans. I am very grateful, however, for the TXDOT staff and consultants who tried to give me better information.

Overall, the adopted growth rates should be thrown away. A much better job of projecting potential future travel models should be done, as described below.

Meaningfully different investment scenarios

The National Environmental Protection Act (NEPA) requires that TXDOT consider meaningful alternatives in this process. The Range of Alternatives Draft Technical Report proposes a No-Build scenario and a single option of three feeder lanes, two managed lanes, and five main “free” lanes on each side, increasing to a total of 20 car-priority lanes from the current arrangement of between 10 and 14 car-priority lanes. This single option is proposed with three different designs, but all three designs include the radical expansion proposal.

The public deserves meaningful analysis of meaningfully different investment options. TXDOT’s funding is unfortunately hindered by requirements that most funds can only be spent on roads, but using these funds does not require adding car-priority lane capacity. There is growing recognition that nationwide and in Texas that the dream of ever expanding freeway capacity has failed. According to the Transportation for America report “The Congestion Con,” eliminating congestion is the wrong goal and instead state DOTs should focus on providing and improving access.

Texas Governor Greg Abbott publicly stated in a speech in San Antonio that the era of building out roadway capacity is drawing to an end noting that “the way people get around, the way people live is going to change. ” Farm&City examined data from the Texas A&M Transportation Institute’s annual report on congestion and found that the costs of congestion have stayed remarkably consistent since 1982, on average costing about $500 per person throughout the last 32 years, regardless of changing strategies and the heavily ramped up spending on roadway expansion in the last 20 years.

The EIS process should entertain TXDOT’s 20 lane proposal, but also should entertain other meaningfully different investment scenarios. Ideally, this would include a scenario that simply brings the current capacity to consistent layout throughout the project area of four “free” main lanes, two service lanes, and two managed lanes on each side, yielding a total of 14 lanes. Ideally, the EIS should also consider simply upgrading two lanes in each direction to managed lanes, while leaving two “free” main lanes, and two service lanes on each side.

The public deserves to understand the potential costs and benefits of truly different investment scenarios, not just a single proposal to build 20 lanes. All scenarios should be studied with modern safe design standards and be studied for optimizing transit, walking, biking, and short trip access along with concerns for long distance trips. Also, TXDOT should examine the potential for deploying the full Reconnect Austin vision with all scenarios.

Entertain alternative growth scenarios

According to the book Scenario Planning for Cities and Regions by Robert Goodspeed , the practice of adopting a single growth forecast for a metro region should be properly understood as “colonizing the future,” and undesirable and outdated planning practice. As we have so remarkably seen in 2020, the future can bring significant changes to our lifestyles and travel patterns. The Texas transportation decision making system needs to switch from the outdated forecasting planning model to a scenario planning regime that equitably considers reasonably possible futures.

The Austin area Regional Transportation Plan developed by CAMPO includes a forecast that proposes a radical sprawl strategy for the region. The Kinder Houston Area Survey indicates that about half the residents of Texas metro regions would like to live in walkable neighborhoods and about half want a big house and big yard even if it means they have to drive everywhere. The Austin region currently only provides for about half a million people – one fourth of residents – to live in walkable neighborhoods. This imbalance of supply and demand is the primary cause of displacement and un-affordability, and is in direct opposition to the comprehensive plan of the City of Austin, Imagine Austin, and the previous regional planning process, Envision Central Texas.

The CAMPO 2045 forecast continues this radical strategy by allocating most expected growth to greenfield development of low-density, car-dependent neighborhoods, yielding an expectation in 2045 that 3 million residents will live in sprawl, while only 1 million will be able to live in walkable neighborhoods able to be served effectively by public transportation. Farm&City has documented the significant problems with the CAMPO forecasting process as well as the Texas State Demographer projections in the “Allocation Game” report advocating for instead using an equitable scenario planning process.

TXDOT should use at least two alternative regional growth forecasts along with the CAMPO 2045 growth forecast to understand the costs and benefits of meaningfully different investment scenarios in not just one, but multiple possible future land use scenarios. This should include a neutral scenario that simply allows every Transportation Analysis Zone to grow at the regional rate of growth, as well as an equitable Transit Oriented Development growth scenario that allows for at least half of the region’s residents to live in healthy, walkable, low-carbon lifestyle neighborhoods with high quality transit.

Equitable decision-making process

The Texas transportation decision making system is radically inequitable with women, black, indigenous, and people of color, as well as people with disabilities underrepresented throughout the boards and commissions that decide how and where to spend our public funds. TXDOT itself has made very meaningful strides in diversifying its workforce and putting Robert Goodspeed, “Scenario Planning for Cities and Regions: Managing and Envisioning 5 women and BIPOC into leadership roles, but the Texas Transportation Commission remains without a single BIPOC and only one woman. A cursory glance at people listed as serving on the various commissions that TXDOT has seated in the long history of studying what to do on I-35 shows a similar problematic inequitable system.

TXDOT should actively work to change the Texas transportation decision making system and ensure diverse representation in all decision making bodies, focus groups in the development of the I-35 project.

Meaningfully Entertain Changing Travel Patterns

The draft Purpose and Need document includes wildly ridiculous proposals about future travel behaviors. On page 5, a chart shows projections that by 2025, it could take 131.6 minutes to travel from SH71 in South Austin to 290 in North Austin on I-35 during the afternoon rush hour. This is a clearly impossible scenario. Tens of thousands of people are not going to drive on I-35 at the same time if they can only drive 3.6 miles an hour for over two hours. The travel demand modeling used to prepare these outlandish claims is clearly seriously flawed. Norm Marshall has documented the many flaws in this system from a professional travel demand modeling point of view.

The people of Austin deserve better analysis that presents actual useful potential future scenarios for how people may travel in the future. TXDOT should entertain the idea that people may drive less in the future, that people may shift to using public transportation, walking, and biking, or simply making shorter trips. The travel demand modeling system should be smart enough to entertain these possibilities, but the one used so far in this process is clearly not.

Assumptions used in the travel demand modeling process should be questioned and allowed to vary. Along with meaningful alternative investment scenarios, and alternative regional growth forecasts, TXDOT should study variations in travel behavior and present the public with a matrix of potential costs and benefits.

Use modern, safe, multimodal design for all elements of the project

Crashes cost the people of the Austin region more than congestion. On average, Austin families have been losing a loved one seven times a year on the Central section of I-35. The Purpose and Need Statement must be substantially rewritten to center the public health crisis of traffic deaths and serious injuries as the top need to address and purpose of the use of these funds. Speed of travel should never overrule safety concerns in this process.

All elements of the project should use safe designs appropriate for a mixed-use, dense urban setting. Controlled access lanes should have a 45 mph design speed and any elements where there is potential interaction between people driving and people outside of vehicles should be designed as city streets to City of Austin design standards and 25 mph design speeds. Achieving steady 45 mph speeds through this core would be a significant improvement in travel time reliability and multimodal access over the failed facility we have today.

Need for the Proposed Project

Too many people die on I-35 main lanes and frontage roads in Austin. Too many people suffer serious injuries just trying to get back home from HEB or taking their kid to school and using I-35 in Austin. Too many people die trying to get across the freeway on foot where there is no safe way to travel East to West for miles, in the middle of one of the fastest growing cities in the nation. The problem of traffic crashes is by far a bigger problem than the perceived problem of congestion or the desire to slightly reduce long-distance travel time.

The correct number of people who should die on the newly rebuilt I-35 is zero. I don’t want any member of my family to die on I-35. I don’t want any member of your family to die on I-35. The Texas Transportation Commission adopted Minute Order 115481 on May 30, 2019, adopting a goal of ending traffic deaths statewide by 2050 and cutting traffic deaths in half by 2035. That minute order instructs the TXDOT Austin District to “develop and implement strategies required to reduce the number of deaths on Texas roadways by half by the year 2035 and to zero by the year 2050.” This is the main point of your work.

According to my analysis using the TXDOT CRIS public query system, at least 71 people have died in the central section of I-35 in the last ten years. The largest group of people who died were pedestrians in the main lanes. The next two largest groups were people in cars or trucks, equally on the main and frontage lanes.

I don’t think that the current proposal gets us to where we need to be on the road to zero. The primary need for this project is to eliminate traffic deaths and serious injuries. The Purpose and Need Statement should be wholly rewritten to make this clear. The current draft includes several pages trying to convince the public that congestion is a big problem on this freeway, but does not in any manner address the families that suffer from traffic crashes on I-35. This is terribly misguided.

TXDOT and TTI have unfortunately continued the misleading practice of publishing a comprehensive report on the costs of congestion and over-emphasizing that perceived problem. Yet, traffic crashes cost the people of Texas much more than congestion. Using the National Safety Council methodology – which is used by the FHWA as well as TXDOT in its annual report on traffic crashes, the economic costs of crashes are much higher than the reported costs of congestion. Using the NSC comprehensive costs methodology – which includes years of life lost and pain and suffering, the costs of crashes for the people of Texas rises dramatically to over six times as high as the costs of congestion as noted in several Farm&City publications.

It is shameful not to establish in this scoping process that traffic crashes are a much more significant problem than congestion and the primary focus of the purpose of this project.

Urban Street Design Guidance

According to TXDOT, building freeways without frontage roads “improves mobility on state highway corridors, increases safety of freeway travel, extends the operational life of the existing road, and reduces highway construction and maintenance costs. ” This entire project should be designed without frontage roads as exist today. Any element of the project that is not access controlled – i.e. freeway or managed lanes – should be designed as urban, multimodal city streets, not frontage roads.

TXDOT should work with the City of Austin to use the City’s design standards for all non-access controlled elements of the project. Design considerations for all non-access controlled elements should take guidance from both the North American City Traffic Officials (NACTO) guidance and American Association of State Highway Transportation Officials (AASHTO) guidance.

If there are to be any slip lanes, all pedestrian crossings should be raised crossings. Raised pedestrian crossings should be considered for all crosswalks in the project.

At a bare minimum the project should include a safe pedestrian crossing at least every 1/2 mile. Ideally, crossings should be safe, multimodal, complete streets designed to safe, slow urban design speeds. However, if necessary, pedestrian bridges or tunnels could be used to fill in gaps to ensure a safe crossing every half mile. From Lady Bird Lake to 290, the project should seek to completely restore the historic urban street grid, with a safe, complete street at regular block lengths wherever there is a street that used to intersect and cross East Avenue.

Safe Design Speed

Speed kills.

We have made terrible mistakes for decades in Texas, as in the rest of the country, with a focus on increasing the speed of travel. This emphasis on speed has failed, with congestion remaining steady in Texas and facilities like I-35 crawling to a halt on a daily basis, but the use of high design speed and culture of speed has had devastating results. During the pandemic, we saw dramatic decreases in vehicle miles traveled, yet traffic deaths remained at almost ten Texans dying in our transportation system every day. Many believe this is because of speed.

Our streets and highways have been designed with high design speeds, making people feel uncomfortable driving at safe speeds and training Texans to drive dangerously. The national traffic engineering and transportation policy world has clearly shifted to a demand to rethink and redesign for safe speeds.

The National Transportation Safety Board recognized the deadly problem of speed and issued Reducing Speeding-Related Crashes Involving Passenger Vehicles with recommendation on how to rethink our transportation system to end speed related death.

The Federal Highway Administration provides guidance to local and state governments provides on designing safely with appropriate design speeds in the “Achieving Multimodal Networks: Applying Design Flexibility & Reducing Conflicts” report.

The Governor’s Highway Safety Association calls for taking a series of key actions to prevent speeding related deaths, in their report “Speeding Away from Zero: Rethinking a Forgotten Traffic Safety Challenge. ”

The Florida Department of Transportation has adopted a context-sensitive complete streets policy that includes safe design speeds for urban freeways. This can serve as an exemplary model for TXDOT for completely rethinking the concept of speed and access for how to rebuild I-35 to better serve the people of Texas.

Most importantly, the Texas Strategic Highway Safety Plan calls for using “the concept of establishing target speed limit and road characteristics to reduce speeding. ” TXDOT should end the failed practice of focusing on increasing speed of travel, but instead focus on safe, reliable access. The difference between traveling through this central corridor between travel at 65 miles per hour and 45 miles per hour is three minutes. Reducing these trips by three minutes is in no way worth the costs of crashes and other costs of trying to achieve slightly faster travel.

Please do not prioritize speed of travel in any way above 45mph for any element of this project. Achieving consistent 45 mph flow for the managed lanes and main lanes of this project would be a significant improvement in access. Any speeds above that have no public benefit.

Design speeds to be used for each element of the project should be based upon the dense, mixed-use, urban nature of this area. According to NACTO guidance all surface non-access controlled elements should use design speeds of 35mph or less . According to the most recent AASHTO Green Book, design speed should be based upon target speeds based upon the context, in agreement with the guidance from NACTO. Design speeds for the main lanes and managed lanes should be set to 45mph for the entire project area.

The project should consider FHWA guidance on Self Enforcing Roadways and USLIMITS2 in the proposed design of the entire facility.

Additional Safety Considerations

Please optimize this entire project for transit. I propose using the amazing thinking happening at TXDOT Houston in the REAL project on how we should envision all freeways as having a network of connected managed lanes that include dedicated lanes that go exactly to the most dense activity centers. TXDOT should collaborate with Capital Metro to identify the ideal direct connections for transit and invest in those direct connectors as part of the project, while working with the City of Austin to dedicate city right of way to build a seamless network of managed lanes on and off the freeway with stations in the places with the most residents, jobs, and students.

Please change all rhetoric on this project to reflect the reality that traffic deaths are a much larger problem than congestion or speed of travel.

Please do not use the term “fast lane” to refer to the left hand lane of the main lanes.

This EIS process should fully use TXDOT’s new system safety analysis system developed by TTI. However, this project should go beyond that and include a full analysis of the potential for serious crashes given various design alternatives. There should be a safety section of the EIS that is equivalent to the air quality analysis found in many EIS documents. This should be done as part of a more comprehensive Health Impact Assessment for the project, along with an Equity Impact Assessment. The project team should meaningfully consider the FHWA’s proven safety countermeasures and deploy as many concepts as possible in this project.

Seriously consider not adding any new non-managed lanes

The Austin’s region’s radical expansion of car-priority lanes has failed, even though the region now has more lane miles per capita than any other large Texas metro. The travel demand models predicting ever increasing traffic have been proven completely meaningless based on TXDOT and CAMPO’s radical insistence on ignoring the concept of induced demand and maintaining the circular logic of the current system. While managed lanes – ideally managed with dynamic tolling to maintain 45 mph speeds for transit and HOV use – can provide access improvements, additional main and frontage lanes will provide no public benefit, but will impose significant costs, disproportionately borne by those living along the corridor.

Ideally, we should simply upgrade two lanes in each direction to managed lanes or consider converting the entire freeway to a tolled system, using credit-based congestion pricing scheme that has been studied extensively by Texas A&M Transportation Institute and the UT Center for Transportation Research. At the very least, there should be no additional non-managed lanes added to the project. Collector, distributor lanes should be incorporated into the project to improve traffic flow and safety, but these should replace existing free lanes, not be additional lanes.