December 30th, 2020

Susan Fraser
Mobility 35 Program Manager
Texas Department of Transportation (TxDOT)
Austin District
my35capex@txdot.gov

Susan,

Thank you for the opportunity to provide input on the I-35 Capital Express Central Project during the Virtual Public Scoping Meeting that concludes on December 31st, 2020. We request the following background and input be incorporated in TxDOT’s I-35 Capital Express Central Project before it advances to the next step in the NEPA process. We will have further input in the future regarding the project as it continues to be developed.

Background

The Red Line Parkway Initiative (RLPI) is a 501(c)(3) nonprofit organization founded in 2017 that empowers diverse communities to enjoy, develop, and enhance the Red Line Trail and Parkway corridor to serve Central Texas mobility, recreation, parks, arts, affordability, social equity, physical & mental health, public space, and economic needs.

The Red Line Parkway is a proposed linear park and public space along the planned Red Line Trail, extending 32 miles from Downtown Austin to Leander. Our vision is a thriving, inclusive, multi-functional parkway that provides convenient, enjoyable, car-free access to transit, parks, public art, and other urban, suburban, and rural destinations. It is poised to become an iconic & welcoming Austin destination, creating the backbone of a metro-wide urban trail network connecting Austin’s urban centers.

We are working closely with local jurisdictions to plan, fund, implement, and activate the Parkway. The Red Line Trail and Lance Armstrong Bikeway, which provides the trail backbone of the Parkway, are part of the Austin Urban Trails Plan and Capital Metro’s 2007 Rails-with-Trails Study.

The segment of the Red Line Parkway that crosses I-35 near 4th St. is concurrent with the Lance Armstrong Bikeway. Pre-pandemic, the segment typically carried 3000-4000 people each day. The segment of the Parkway that will cross I-35 near 43rd St. is not yet in place. Once the 32-mile Parkway is completed, we project over 10,000 users each day at both of these I-35 crossings, based on
completed trails in cities with similar activity areas.

The Parkway is interlinked with the I-35 Central corridor at the two intersections with I-35, i.e. at 4th St. and near 43rd St., but also in how people will access origins & destinations using both the Parkway and the I-35 corridor. As a result, the quality of pedestrian, bicycling, and transit access along the entire I-35 Central corridor are critical to the Parkway.

Input on draft Coordination Plan and Schedule

We request the following to be incorporated into the project Coordination Plan and Schedule:

1. In order to ensure that stakeholder needs and interests are met, we ask that TxDOT work closely with the following stakeholders during all phases of the project, including scoping, planning, design, and implementation, and opening:
   • Red Line Parkway Initiative,
   • Active Mobility Working Group for the I-35 Capital Express Project, currently facilitated by RLPI,
   • Our Future 35,
   • Reconnect Austin,
   • Rethink35,
   • NCINC,
   • Walk Austin,
   • Bike Austin,
   • People United for Mobility Action, and
   • Austin Outside.
2. We request that all future public input periods provide at least 90 days for public comment in order to allow for the degree of public input that is commensurate with a project of this scale. This will help facilitate conversation among stakeholders to help provide consensus on project parameters.
3. The information provided for this project thus far (and for most or all TxDOT projects) is not adequate for the public to understand the project, its context, and how to meaningfully provide input from an informed position. For a genuine NEPA process, it is essential to proactively educate the public about the project so that all impacts of design & engineering decisions and build alternatives (including prominently requested alternatives not included by TxDOT for consideration) are known and understood by the public. TxDOT should publicly describe previously unstated motivations for each of the project alternatives, for why some alternatives are considered and others are not, and for more specific design choices, e.g. locations of entrances and crossings, and cross-section widths for paths.
4. The project should be codesigned with the local community, and include Our Future 35 community alternatives (ourfuture35.org), the Reconnect Austin recommendations (reconnectaustin.com), the Rethink35 recommendations (rethink35.com), and the Downtown Austin Alliance ULI study recommendations (February 2020)—even in pre-engineering phases—as part of the full Environmental Impact Statement.
5. City of Austin’s adopted plans should be assumed to be at least as valuable as TxDOT’s interests in evaluating and determining the various project parameters.
6. Given the existential threat to our country and state presented by climate change, and the significant contributing impact of both the existing I-35 corridor and proposed I-35 Central project toward climate change, we request that the following agencies be invited as additional Participating Agencies:
   • U.S. Department of Defense,
   • U.S. Department of Homeland Security, and
   • Texas Department of Public Safety.
   • Federal government leadership has recognized the national security threat imposed by climate change resulting from greenhouse gas vectors, such as I-35. Example source: The Center for Climate & Security: bit.ly/3rpeZW5 The military and armed police are mechanisms of last resort. This project should avoid increasing the need or alert levels of those forces.

Input on draft project Purpose and Need

We request the following to be incorporated into the project Purpose and Need:

1. Prioritize safe local access and connectivity to, along, and across the I-35 corridor for pedestrians, cyclists, transit riders, people with disabilities, the elderly, people with health vulnerabilities, children, students of all ages, and individuals who are experiencing homelessness. Create a safe, local street network at surface level to ensure that all people driving cars and all vulnerable road users can safely and effectively get around. Ensure that over 90% of streets that currently touch I-35 will have full I-35 crossings, and look for opportunities to allow for new future streets to connect across I-35 in areas with large block size, especially north of Airport Blvd. and south of Riverside Drive. Focus on how people can access needs, rather than maximizing speed.
2. Include car-free connectivity across I-35, i.e. pedestrian, bicycling, trail, and transit connections across I-35 that do not encounter mainlane or service road traffic. This includes:
   • All I-35 roadway lanes, including both mainlanes and service road lanes, should go below the Red Line Parkway at both Red Line crossings, which are next to 4th St. and near 43rd St. Each of these crossings are expected to have over 10,000 pedestrian & bicyclist crossings each day, based on trail volume on existing similar trails.
   • The Airport Blvd. & I-35 intersection design should take into consideration a future Hancock transit station for the Gold Line and/or the Red Line by creating a superior pedestrian and bicycling crossing, including putting both the I-35 mainlanes and the intersection of Airport Blvd. & I-35 service road underground and providing plaza, park, and building opportunities on the surface.
   • The Ann & Roy Butler Trail on both the north and south edges of Lady Bird Lake should continue to have car-free connectivity across I-35 and its service roads.
   • The future Bergstrom Spur trail and transit corridor, immediately south of Ben White, should be provided with car-free connectivity for pedestrians, bicycling, and transit users across I-35 and its service roads.
   • The Tannehill Branch, a creek that crosses I-35 between 51st St. and US 290 West, should be daylighted and include a car-free pedestrian and bicycling creekside trail connection across I-35 and its service roads.
3. Rectify longstanding disproportionate racial and economic impacts exacerbated by the original construction of I-35. The project must help rectify past impacts to Austin’s People of Color that resulted from its original construction, and not repeat the same mistakes. The project should include mitigation funding for both I-35’s past impacts and this project’s new impacts.
4. Facilitate economic sustainability & resiliency in alignment with equitable outcomes. Create walkable, mixed-use, and equitable transit-oriented development along I-35. Close socioeconomic gaps between communities and stop or mitigate displacement. In collaboration with the public, evaluate the benefits that could result from making new land made available for housing, businesses, parks, and other local community needs as a result of shrinking the surface footprint of the roadway lanes. Conduct a full equity impact analysis for this corridor and nearby communities.
5. Reduce the footprint of the project and fully evaluate and mitigate its environmental and community well-being impacts, from the local scale to the global scale. This includes physical and mental health impacts such as nature-deficit disorder, respiratory disorders, premature death, access to schools and healthcare, and traffic violence. This evaluation should also include air and water quality, noise pollution, impacts to wildlife & endangered species, loss of parkland, access to parkland, loss of farmable land, climate change, heat island effect, and drainage & flooding impacts resulting from the project. The project should provide mitigation funding for these impacts, including debts owed to future generations to reverse these negative impacts.
6. Ensure that the project is in compliance with existing local plans, including but not limited to plans of the City of Austin and Capital Metro. The public has already approved plans by the City of Austin and other local government entities, such as the Austin Strategic Mobility Plan (ASMP) and the voter-approved Project Connect, among others. TxDOT should help accomplish those plans. TxDOT and NEPA evaluators should not rely solely on the local jurisdictions to voice concerns about compliance with their respective jurisdictions’ plans, but rather TxDOT and NEPA evaluators should publicly cite any noncompliance with those plans, and then include solutions to bring their I-35 project plan into compliance.

Input on draft Range of Alternatives

We request the following regarding the project Range of Alternatives:

1. None of the proposed build alternatives should be advanced to the next stage. Concerns regarding the proposed build alternatives:
   1. They include too many highway lanes for an urban core environment. Preferably no additional lanes are added–managed lanes, mainlanes, collector-distributor lanes, or service road lanes.
   2. There are too many roadway lanes at the surface for all alternatives, except Build Alternative 1 between MLK Blvd. and Airport Blvd.
   3. There should be no elevated sections or flyovers, except perhaps flyovers at the interchanges with US 290 East and with US 290 West, to be commensurate with the existing flyovers.
   4. Highway managed lanes or mainlanes should generally not be exposed to the surface.
   5. The pedestrian and bicycling accommodations should be provided via separate paths. I.e. instead of shared-use paths, the accommodations should be a sidewalk and a bikeway on each side of the corridor.
   6. Any alternative that includes controlled access lanes (i.e. any configuration other than a highway-to-boulevard conversation) should either cap those lanes or provide an adequate structure such that they can be capped in the future.
2. Notable alternatives should be advanced to the next study stage. These include:
   1. The Reconnect Austin configuration, described in general terms at ReconnectAustin.com.
   2. The highway-to-boulevard conversion configuration, described in general terms at Rethink35.com.
   3. Redesignating I-35 to another local highway corridor, e.g. Loop 1, US 183, or SH 130.
   4. These alternatives should be transparently evaluated alongside other project alternatives, based on the project’s Purpose and Need, other values described in the above input on the draft Purpose and Need, any other of TxDOT’s stated or previously unstated interests, and other prominently stated community interests, including equity, economic, environmental, mobility, and land use interests. These alternatives should be evaluated for the entire length of the project corridor. If the value of a configuration is significantly improved by including it for only a portion of the project corridor, then that configuration as a subset of the corridor should be presented as an additional project alternative. Though a given alternative may not be considered viable within TxDOT’s paradigm, it is critical that it is publicly and transparently evaluated so that all parties can fully understand the context among both preferred and nonpreferred alternatives.
3. For any Project alternative that proposes an increase in highway capacity, we request that TxDOT provide mitigation funding for pedestrian and bicycling improvements to local streets and trails within 5 miles of the project in order to mitigate the negative consequences of the resulting additional motor vehicle traffic on local streets and other TxDOT corridors. This is in addition to any pedestrian and bicycling improvements provided within this project’s corridor.
4. Any alternative that advances to the next study stage must be able to accommodate putting all roadway lanes (highway lanes, service road lanes, and boulevard lanes) below the surface at both Red Line Parkway & Capital Metro Red Line crossings and at Airport Blvd.

Further Input

1. We request that December 2020 input for this project from the Austin Pedestrian Advisory Council and Bicycle Advisory Council also be incorporated into the project.

Thank you for service and for considering this input. Please let me know if you have any questions, or to provide any suggestions to help us accomplish our goals.

Tom Wald
Executive Director
tom@redlineparkway.org
512-203-7626