By Bruce Melton, PE
(Based on official comments to the NEPA process meeting of August 26, 2014 and delivered to TxDOT/CTRMA on September 6, 2014)
On August 21, Austin City Council voted unanimously asking the Texas Department of Transportation and Central Texas Regional Mobility Authority (TxDOT/CTRMA) to fairly evaluate a non-elevated and non-tolled parkway for their Federal Environmental Impact Statement (EIS) for the Oak Hill US290/SH71 transportation improvements. This resolution responds to recent TxDOT/CTRMA actions revealing that only elevated frontage road concepts financed through tolling could advance for detailed analysis in the EIS.
Local residents named the project the “Oak Hill Parkway” at one of TxDOT/CTRMA’s first public workshops for the EIS process in the fall of 2012, reflecting their desire for a highway that would protect the original character of Oak Hill and the unique natural environment where Williamson Creek meets the Edwards Aquifer Recharge Zone adjacent to the Convict Hill Quarry and the last remaining “oaks” in what was once the thriving downtown of Oak Hill.
Over the last two decades, this highway project has required the removal of 26 businesses and a church in this area. In 2007, the Federal Highway Administration required TxDOT to formally update the dated EIS for the project initially completed in 1988.
The Fix 290 Coalition, a group of over 40 organizations and businesses and 2,800 petition signers in Oak Hill, advocates for a more environmentally and community sensitive design than the elevated 12-lane concepts TxDOT has suggested for over 20 years. To do this they propose the use of a classic “parkway” concept that would minimize frontage roads like can be found in the design of MoPac (Loop 1) between Ladybird Lake and RM 2222. The Capital Area Metropolitan Planning Organization (CAMPO), defines a parkway as a “freeway without frontage roads.” Other roads can certainly be called a “parkway,” but in the classic engineering definition of the term, a parkway lacks frontage roads.
The City Council resolution reflects community displeasure at seeing more environmentally and community friendly concepts being dropped from further consideration early this summer by TxDOT/CTRMA. The Resolution cites National Environmental Protection Act (NEPA) EIS requirements to “Rigorously explore and objectively evaluate all reasonable alternatives… [and] Devote substantial treatment to each alternative considered in detail…”
History of TxDOT/CTRMA Efforts to Include “All Reasonable Alternatives”
In May 2013, TxDOT released their alternative concepts for this project as per EIS requirements. These alternatives did not include a concept that reflected a “parkway” design and resulted in considerable comments from the community requesting that a parkway alternative be considered for what TxDOT/CTRMA has labelled as the Oak Hill Parkway.
In August 2013, TxDOT/CTRMA began working with Fix290, in what TxDOT/CTRMA has labelled as community design workshops, to add a parkway alternative into the EIS process. What Fix290 suggested was that, what they considered to be the best parts of the other alternatives be combined, and that in areas where businesses had been removed and access could otherwise be provided without frontage roads, that frontage roads in these areas not be included in a design concept. This alternative was labelled as the sixth alphabetically in the series as Alternative F.
In March 2014, TxDOT/CTRMA announced that tolling would be the finance mechanism for this project.
On June 26, 2014 this community design subcommittee work culminated after several iterations of design as officials from TxDOT/CTRMA announced that the “parkway” alternative had been disqualified from further consideration.
After hearing from numerous community residents and Fix290 members, that the decision criteria used to disqualify the parkway alternative was biased, TxDOT/CTRMA decided to perform further evaluations and to reconsider their decision by August 2014.
On August 26, at another community design workshop held coincidentally five days after the unanimous City Council Resolution, TxDOT/CTRMA announced that the decision on a parkway alternative would be delayed even further, until at least the middle of September.
Possible Bias in the Decision Process
The possible bias in the June 26, 2014 decision to disqualify a parkway alternative was evaluated by TxDOT/CTRMA over the summer. Results and implications of this reevaluation were presented at the August 26 community design subcommittee workshop and are summarized below:
Congestion…Eight of the nineteen decision from the June 26, 2014 decision criteria dealt with congestion. After modeling CAMPO traffic projections for the year 2035, TxDOT/CTRMA concluded that a parkway alternative (Alternative F) did not pose significantly different amounts of regional congestion than the two alternatives chosen to continue with the EIS evaluation process on June 26 (Alternatives A and C).
However, this modeling did show a significant increase in congestion on the eastbound lanes of US290 at “Y” (the 290/71 intersection). The TxDOT/CTRMA stated reason for this congestion appears to be unfounded; it was because of the left side entrance ramp inbound from SH71 and the weaving that vehicles had to accomplish to get to the William Cannon exit 500 yards east on US290. When viewing the animation of the modeling, where real-time congestion can be seen like a time lapse satellite movie, the congestion appeared to begin to decrease before this left entrance ramp from SH71. Further observation showed a bottleneck west of the SH71 entrance where three lanes were reduced to two, obviously creating the congestion.
Safety Issue… Modeling was performed to evaluate emergency vehicle access in the case of a complete blockage of the main lanes by comparing emergency vehicle travel times between Alternatives A, C and F. Obviously, where frontage roads are limited, a complete blockage of the main lanes would likely increase emergency vehicle travel time. However, no evaluation of a complete blockage of the frontage roads was performed. In this instance, where Alternative F has 18 access ramps to the main lanes and Alternatives A and C have only 13 and 12 respectively, the alternative with the greater number of access ramps to the unblocked main lanes would have better emergency vehicle access. (Ramps are counted from Scenic Brook to Joe Tanner; Scenic Brook westward is identical across all alternatives.)
More questions remain however. TxDOT/CTRMA did not provide a modeling experiment design, so it is impossible to evaluate “why” emergency vehicle access is worse with Alternative F.
In theory, Alternative F has about 40 percent fewer frontage roads than Alternatives A and C, but half of the frontage roads for alternative F are two-way, whereas all of the frontage roads for Alternative’s A and C are one-way. These two-way frontage roads significantly increase connectivity and by definition, would increase emergency vehicle travel time.
In addition, emergency vehicle access was not compared to the main existing comparable route in the region—MoPac between ladybird Lake and RM2222. This stretch of roadway has no frontage roads at all. A judgment based on a roadway with significantly fewer frontage roads than Alternative F was not attempted.
Due Diligence in Design Evaluation…
Several major areas of the design of Alternative F appear to have been neglected in the standard design iteration process that takes place as a major roadway concept is developed.
The community members that worked with TxDOT to develop alternative F are not high-speed transportation experts. One of their members is civil engineer with 30-years of experience that does include substantial roadway design, but these people are all volunteers and do not have the resources to deal with tens of thousands of dollars of conceptual design iterations.
Using the traditional conceptual design process, when a design flaw is encountered, other alternatives are evaluated to minimize or eliminate the flaw. Several major areas of conflict with the Alternative F concept appear to have been received little if any of this concept design iteration process as discussed below:
Congestion of Alternative F for the Eastbound lanes of US290, relative to the left entrance of US71 and the “Weave” across three lanes of traffic to make the William Cannon exit ramp (discussed in number 1 above): Two alternative solutions to this conceptual design element were not evaluated that include prohibiting the weave to the William Cannon exit with concrete traffic barriers, or having this movement from US71 enter the main lanes from the right.
Safety issues because of complete blockage of the main lanes (from number 2 above): The experimental safety modeling chose a location to completely block the main lanes that was just west of SH 1826 where a frontage road in the Alternative F concept does not exist for about a half mile. This modeling did not evaluate how emergency vehicle access time would change if this short section of frontage road was added back into Alternative F.
William Cannon depressed main lanes:
An elevated roadway creates significantly more noise, light pollution and physical division of community than a road at grade or depressed (excavated below grade). Most of the TxDOT/CTRMA design alternatives show the main lanes of US290 excavated below grade at almost all of the major intersections on US290 west of William Cannon. The reason that TxDOT/CTRMA did not depress US290 at William Cannon was because the road cannot drain by gravity and pumps are required. The Central Texas Region of TxDOT does not have any depressed roadway sections that cannot drain without pumps. But these circumstances can be found in Houston and are feasible and in this instance would allow for all of the suggested alternatives to depress the high speed lanes below grade resulting in substantial noise, light, aesthetic barrier and reduced costs implications.
Removal of businesses east of William Cannon and north of US290:
The initial sketch submitted by the community design subcommittee for this intersection showed no changes to the businesses north of US290 and east of William Cannon, but TxDOT/CTRMA created an access ramp that required the removal of all of these businesses. None of the other alternatives require the removal of these businesses.
Disappearing US290 east access Ramp at Scenic Brook:
The second iteration of Alternative F showed an access ramp from the Scenic Brook overpass on US290 to the main lanes eastbound. This access ramp has disappeared without explanation. If there are design criteria that cannot be met with this access ramp, braided access ramps like were used at two other locations in other alternatives for this project can be used to provide this access.
Old Bee Caves Road two-way access:
the community design subcommittee suggested an access to Old Bee Caves road from the east via the William Cannon intersection, in addition to the access from the west so that two-way traffic could move freely to Ola Bee Caves Road, but without explanation this access has never been included in any of the Alternative F concept iterations.
Very significant misconceptions, are widespread in the Oak Hill community, not only about Alternative F, but about Alternatives A and C as well. These misconceptions include:
- There is not 1.6 miles of continuous elevated roadway with Alt A:
There is actually 1.6 miles of continuously elevated roadway in Alternative C between Joe Tanner Lane and Scenic Brook on SH71 with. Alternative A has SH71 elevated for 0.5 miles from US290 to Scenic Brook.
- The elevated road is 60 to 80 feet high:
In 2003, there were two levels of interchange above grade at the “Y” that would be at least 50 feet above street level. Since then, the costs of excavation in limestone have decreased substantially because of the development of new rock excavation equipment allowing costs to be similar for rock excavation as elevated roadway construction. All of the TxDOT/CTRMA alternative use excavated main lanes depressed below grade to limit the total roadway elevation at any point to about 25 feet.
- Access ramps are not important:
Alternative F has 18 access ramps whereas alternatives A and C have 13 and 12. Access ramps are vitally important to community interconnectedness as well as emergency vehicle operation.
- Concept F does not have frontage roads:
Concept F has a reduction of 40 percent of the total of all possible continuous frontage roads and these reductions are almost exclusively in areas where all of the existing businesses have been removed or where access can be provided through other means. MoPac has no access roads between Ladybird Lake and RM 2222.
- Concept F closes Old Bee Caves Road: The first iteration of Alternative F published by TxDOT/CTRMA culdesaced Old Bee Caves Road. When it was pointed out by the community design subcommittee that the other alternatives did not, and that access to Old Bee Caves could be made similarly, TxDOT/CTRMA changed their alternative F to provide access.
- The direct access ramp to Granada Hills is preferable to a direct access ramp to the hospital:
In the correct version of Alternative F, where there is an on ramp headed east on US290 at Scenic Brook, an off ramp exits at SH1826. This was a management decision by the community design subcommittee that prioritized a direct access to SH1826 at the hospital. All of the TxDOT/CTRMA alternatives have a direct access from the frontage road at Granada Hills to the main lanes of US290 eastbound. Prioritizing the hospital access at SH1826 means that Granada hills residents will have to drive west on a two-lane frontage road for less than a half mile before they can make a direct access to the main lanes of US290 eastbound.
- Alternative F has no access roads west of Scenic Brook:
The one-way frontage roads west of Scenic Brook are identical in all TxDOt alternatives including Alternative F.
- Alternative F will remove Grandmother Oak:
None of the alternatives, including Alternative F remove Grandmother Oak at the northwest corner of US290 and William Cannon, nor any of the other heritage trees in the Becket Grove at this intersection.
- Alternative F is more detrimental to the Joe Tanner Grove than any other possible modifications to Alt A or C:
As drawn, Alternative F saves half or more of the Joe Tanner rove whereas none of the trees are saved with Alternatives A or C. However, TxDOT/CTRMA is aware of this oversight and has promised to evaluate alternative designs that would save as many of the trees as possible. These alternatives would be applicable to all of the proposed concepts including Alterative F.
The costs evaluation used in the June 26 decision process, where Alternative F was 23 to 37 percent less than the other alternatives, has been removed and TxDOT states that costs are not used in the determination of advancement of any particular alternative. This does not appear to be the way that NEPA regulations read:
40 CFR 1502.14 states:
(a) Rigorously explore and objectively evaluate all reasonable alternatives…
(b) Devote substantial treatment to each alternative considered in detail including the proposed action so that reviewers may evaluate their comparative merits.
(c) Include reasonable alternatives not within the jurisdiction of the lead agency.
A “rigorous” evaluation with “substantial treatment to each alternative considered in detail” does not completely disregard costs.
- Community access to the main lanes of US290 and SH71 was not a part of the Phase 2 decision criteria…
As per 40 CFR 1502.14, “Rigorously explore and objectively evaluate all reasonable alternatives” No evaluation of community (local access) travel time difference for local access between the different TxDOT alternatives was made to “objectively evaluate all reasonable alternatives.”
- Noise, Aesthetics and Physical barrier of an elevated roadway…
Noise, aesthetics and the physical barrier of an elevated roadway were not evaluated as per 40 CFR 1502.14.10)
Tolling was not evaluated for costs or congestion on frontage roads as per 40 CFR 1502.14. Unless tolling is disallowed as a finance mechanism, costs due to tolling relative to congestion of frontage roads is a significant consideration as tolling radically increases the traffic component on the frontage roads. As per CAMPO 2035, tolling increases frontage road congestion by 33 percent as drivers avoid paying a toll.)
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