Date: 12/31/2020
Re: I-35 Capital Express Central Project
To: Project Team
Transmitted via Email: My35capex@txdot.gov
Transmitted via Letter: 1608 W. 6th St., Austin, TX 78703

Reconnect Austin respectfully submits the follow comments to be documented during scoping and considered through the development of the I-35 Cap Ex Central Project.

Reconnect Austin is a grassroots groups of community leaders which has been working with neighborhood and community, elected official, the City of Austin, and TxDOT since TxDOT took over this project in November 2012. In those 8 years we have consistently advocated for a better I-35 in central Austin, throughout leadership changes at the federal, state, and local levels, changes in TxDOT leadership, changes in Austin District Engineers and I-35 Project Managers, and so many different TxDOT consultants we have lost count. Despite years of study and discussion, including a broad range of strong community input during the 2016 NEPA review, many of the same issues remain unaddressed.

Reconnect Austin and its members have participated in a variety of organized efforts to formulate a plan for I-35, including:

• Multiple community and neighborhood group meetings
• TxDOT’s Downtown I-35 Stakeholder Working Group and associated deep dives
• TxDOT’s I-35 Aesthetic Working Group
• Downtown Austin Alliance’s Mobility Committee
• Downtown Austin Alliance’s I-35 Taskforce
• Urban Land Institute Austin’s Transportation Committee
• Urban Land Institute’s Technical Assistance Panel
• City of Austin Bicycle / Pedestrian Advisory Council Active Mobility Working Group
• Cap Metro Project Connect MCCAC and PCAN
• OurFuture35 Scoping Working Group

Reconnect Austin has donated considerable time and expertise to reimagining the I-35 corridor and plans to continue to participate in this process. With that in mind, we offer the following 21 key concepts, which we believe must be addressed in 2021:

1. TxDOT must address past racial injustice. I-35 was intentionally located next to redlined neighborhoods in East Austin, walling them off from other areas of the city. Widening I-35 and increasing the daily traffic will increase the negative and harmful impacts on these communities. I-35 should not be widened to benefit some while harming those who live adjacent to this highway. A full equity assessment is needed.
2. TxDOT must thoroughly document existing, and adequately model future, environmental impacts. Much of the air pollution, noise pollution, flooding, and poor water quality caused today by I-35 has gone undocumented. TxDOT should fully understand the existing conditions, and then model all future impacts. Vulnerable populations live near I-35 and are disproportionately impacted by the presence of I-35. Create transparent reporting of methodologies, measurements, and analysis of impacts. Both a full health impact assessment and a full environmental impact assessment are needed.
3. TxDOT must plan this project in coordination with the City of Austin, Cap Metro, and the Austin Transit Partnership. Austin voters went to polls on Nov. 3, 2020 and voted to tax themselves to pay for an expanded transit system. Project Connect is critical to moving people efficiently and any changes to I-35 should prioritize transit access, operations, and be designed to accommodate all future transit needs (including headroom for future rail).
4. TxDOT must use more accurate traffic modeling. Current traffic modeling is based on over-inflated projections. Projections from 2002, which predicted future traffic levels in 2020, are still substantially higher than current average daily trips (in 2020).
5. TxDOT must work to address travel demand. Plans focus solely on supplying more infrastructure. Highways are a supply and demand system. We have seen with COVID-19 stay at home orders that changing demand reduces congestion, doing so more successfully than adding free highway lanes. The TTI Mobility Investment Priorities Project, conducted with TxDOT direction, clearly modeled demand management strategies, which showed more success in alleviating congestion than only widening I-35. Demand management strategies to consider: never adding new non-tolled capacity, creating transportation choices, making the transit trip more beneficial and attractive than the driving trip, building more housing near job centers, as well as work from home (which has successfully eliminated congestion during COVID).
6. TxDOT must seriously study a designation switch with SH 130. In 2011 the Texas Transportation Commission appointed the I-35 Corridor Advisory Committee, which recommended redesignating SH 130 from Georgetown to SH 45 SE as I-35. This recommendation should no longer be ignored. Traffic will need to move off of I-35 for construction, this is the opportunity to move through trips permanently to SH130.
7. TxDOT must follow its Road to Zero policy. Annually 25% of traffic deaths in the entire City of Austin occur in the I-35 corridor. That is unacceptable. TxDOT should be doing everything within its power to lower the death toll, including lowering design speeds on the main lanes and on any remaining frontage roads outside of the urban core. Lower design speeds would save lives, reduce the overall footprint, and shorten entrance and exit ramps.
8. TxDOT must prioritize safety for all road users, protecting all human life in the transportation system, as called for in the Austin Strategic Mobility Plan. All highway lanes, roads, streets, boulevards, and bridges should be designed with safety as a real, measurable, and implemented priority. This includes safety for all road users and all modes in the corridor, significantly improving east/west connectivity.
9. TxDOT must allow the City of Austin to design all surface streets and roads. Surface streets and roads are urban transportation systems that need to serve all users and should be integrated into the city’s transportation network. City of Austin design guidelines and NACTO standards must be applied to surface level streets and roads.
10. TxDOT must consider all alternatives for I-35. NEPA allows the agency to consider and evaluate community alternatives. Any NEPA review should fully consider: ULI I-35 recommendations, Rethink35, and Reconnect Austin. The Reconnect Austin vision is outlined in our report – Reimagining I-35 – which is included with this submission.
11. TxDOT must provide real alternatives. The current alternatives, as presented, are very difficult to understand (the drawings are not dimensioned) and lack considerable detail. The community cannot make a carefully considered decision without a NEPA process that puts forward carefully considered alternatives, including those that have originated in the community: ULI recommendations, Rethink35, and Reconnect Austin.
12. TxDOT must address safety in meaningful ways. The Purpose and Need does not adequately address safety for all road users.
13. TxDOT must respect and follow local policy direction. The City of Austin has set strong policy direction for transportation and any transportation facilities within the city, including I-35, should follow that direction. Any future I-35 should help the City of Austin achieve it’s stated policies and goals for the transportation network. This includes policies outlined in:
    • Austin Strategic Mobility Plan
      • Mode split goals by 2039: 50% drive alone, 16% transit, 14% telework, 11% carpool/taxicab/other, 5% bicycle, 4% walk
      • Reduce the amount of time workers spend traveling between home and work
      • Build a transportation network that encourages social interaction
      • Promote a balanced transportation network
      • Promote economic growth for individuals and the city through strategic investments in transportation networks
      • Lower the cost of traveling in Austin by providing affordable travel options
      • Lower the risk of travel-related injury and promoting public health
      • Draw inspiration from forward-looking cities around the world, change the way
        we think about what is possible, and set an example for the rest of the country
    • Imagine Austin Comprehensive Plan
      • Public and private sectors work together to improve our air quality
      • Support public transit and a variety of transportation choices, while reducing sprawl, congestion, travel times, and negative impacts on existing neighborhoods
      • Safe bicycle and pedestrian access with well-designed routes that provide connectivity throughout the greater Austin area
      • Ensure that growth is both fiscally sound and environmentally sustainable
    • Great Streets Master Plan
      • Create an environment that is safe, generous enough for multi-purpose use, and sheltered from the elements
      • Calm traffic movement in downtown; accommodate automobile traffic to downtown and discourage traffic through downtown
      • Recognize the primacy of the grid in the downtown and optimize its use
    • Vision Zero Goals
      • Zero annual vehicular-related deaths and serious injuries within Austin city limits
    • Austin Street Design Guide
      • All project elements that are not controlled access facilities should be designed as safe, multimodal facilities with target, posted, and design speeds of 35mph or less
      • NACTO guides, such as the Urban Street Design Guide, should also be used as additional design guidance for all elements of the project that are not controlled access facilities
      • All controlled access facilities should be designed with similar up to date design guidance, including the most recent AASHTO Green Book, with sufficiently low target, posted, and design speeds for a dense urban context and to allow seamless and safe integration with a safe, multimodal urban street grid
    • Austin climate goals as set forth in Austin City Council Resolution 20140410-024
      • Net zero community-wide greenhouse gas emissions by 2050
14. TxDOT must rebuild I-35 in a way that creates more vibrant, prosperous, and resilient
    communities. While creating a new design for I-35, TxDOT should simultaneously work
    with the City of Austin to create policies that:
    • Increase dense, walkable, mixed-use, and equitable transit-oriented development along I-35 from which people of all types of age, gender, skin color, income level, and physical ability can equally benefit and access.
    • Close socioeconomic gaps between different communities through tools such as value-capture programs to harness increased revenues from improvements to I-35 to help build local wealth, enhance and protect historic and cultural resources, and prevent displacement.
    • Provide bicycle and pedestrian infrastructure like street furniture, water fountains, and tree plantings to increase economic activity, improve environmental quality, and provide shade. Trees should be between fast‐moving cars and people to add safety and comfort for vulnerable road users.
    • Maximize socially, economically, and environmentally beneficial land use by evaluating how much land should be used for mobility right-of-way and how much should be used for other uses such as affordable housing, local businesses, and public space, such evaluation including the consideration of a road/highway diet and other land use measures.
15. TxDOT must provide a full economic cost accounting for all direct, indirect, and cumulative impacts identified in this scoping recommendation, including deaths and serious injuries, of the current I-35 configuration and of the various fully considered alternatives. A full economic impact analysis is needed.
16. TxDOT, the City of Austin, and other agencies must work together to:
    • Maximize safety for all transportation modes
    • Maximize street network connectivity, including equally facilitating east-west and north-south travel
    • Reform land use policies, including increased density and mixed-use zoning for neighborhoods
    • Implement Travel Demand Management strategies
17. TxDOT must collaborate with local and regional partners. On its own, TxDOT cannot deliver the project the business community and residents envision. TxDOT must work with local and regional partners, including the City of Austin, Capital Metropolitan Transportation Authority, the Capital Area Metropolitan Planning Organization, and organizations such as the Downtown Austin Alliance, the Austin Chamber of Commerce, and the Real Estate Council of Austin. All entities must work together to create a project that benefits the various interests and needs of stakeholders.
18. TxDOT must focus on access rather than speed. I-35 must be designed to serve Austin’s economy as much as it serves that of the region and nation. This means that any proposed improvements should prioritize local access to business and activity centers, including downtown Austin, the Capitol Complex, and The University of Texas, over the speed of vehicles and trucks moving through the region.
19. TxDOT must work closely with the University of Texas at Austin to maximize the opportunity to reconnect the university campus and create new buildable land for Texas’ flagship university.
20. TxDOT must recognize the opportunity to capture value in this corridor. There are approximately 136 acres of TxDOT right of way between Holly St. and Airport Blvd. This land represents an enormous opportunity to create valuable tax base and reconnect the city. That opportunity must not be ignored. The segment of I-35 from the river to Airport Boulevard must be capped. The cap allows the reintegration of Austin with East Austin, and also allows for the major problems of air and noise pollution to be adequately mitigated. By sinking the freeway and capping it through downtown and the upper decks, and by combining existing frontage roads into a civilized urban boulevard, we can create a human scale, walkable, mixed-use boulevard. By doing so, Austin would enjoy several billion dollars of enhanced tax base to pay for the cap with a tax increment bond. That bond would be easily paid off in less than 20 years, and the investments would flow from the taxes in perpetuity.
21. TxDOT must allow 90 days of public input after the publication of technical reports and other relevant project documentation for all public comment periods for the remainder of the environmental process. Information supplied to the public must be transparent and easy to understand by lay people. The public must be provided all interim reports related to traffic modeling, climate change modeling, alternative designs, engagement outcomes, and other assessments.

On this New Year’s Eve 2020 we want to extend our thanks for your attention to these 21 areas of concern. We look forward to working with your team in 2021 to fully realize this once in a lifetime opportunity to transform the I-35 corridor.