Environmental concerns on Oak Hill Parkway

Environment Texas

December 21, 2018

Re: Oak Hill Parkway

To: CAMPO Members, Austin City Council, Mike Kelly, Chris Herrington, Rob Spillar CAMPO Members, and Austin City Council Members and staff,

Our organizations share a collective concern about the Oak Hill Parkway project(US 290/ SH 71). We recognize and applaud recent efforts of the City of Austin and TxDOT to collaborate on this project, but also recognize that there is more to be done for the construction plan to be acceptable.

We urge CAMPO to postpone voting on the TIP amendment for this project until after the Austin City Council has had an opportunity to discuss and vote on its MOU with TxDOT. This letter details some remaining concerns about the project and additional features that may be added to that agreement. Given our serious concerns about the project design itself, we also ask that your agencies evaluate the “Livable Oak Hill” alternative.

CAMPO members received a correspondence dated December 12th, 2018 from City of Austin Transportation and Watershed Protection staff. This letter was a response to issues raised by Save Barton Creek Association (SBCA) in a letter to Austin City Council on October 29th, 2018 about the Oak Hill Parkway. SBCA, Environment Texas, Sierra Club Austin Regional Group Save Our Springs Alliance, and others expressed our concerns about the project at the December 10th CAMPO Meeting.

We are glad that TxDOT has been responsive to working with COA on an Memorandum of Understanding (MOU) for this project and future projects within the Austin District. We further appreciate that these negotiations have led to incorporating many of the environmental protections Save Barton Creek Association requested into this MOU.

We still hope the following additional measures might be incorporated into such an MOU.

• Limits on excavation, especially in the recharge zone of the Barton Springs Edwards Aquifer
• That this project either meet the City’s water quality standards for the Barton Springs Zone; or an agreement is reached about an alternative equivalent that TxDOT will contribute through upgraded water quality treatment facilities on other roads in the recharge zone and/or purchase of Water Quality Protection Lands. The alternative equivalent should fully offset the amount of impervious cover added by this project. 
• Avoidance of bottomland riparian habitat including trees along Williamson Creek near William Cannon and Old Bee Caves Rd intersections. 

We question whether this project as conceived by TxDOT is compatible with COA transportation and land-use policies. We hope that either the current MOU being considered, or a separate one, can define COA and TxDOT’s relationship in a way to ensure that this project and others are in alignment with such policies. For example, this plan appears incompatible with the “Oak Hill Activity Center” identified in the Imagine Austin Comprehensive Plan as well as the recently adopted “Project Connect Vision Plan” which shows transit-oriented development at the Y and 290. It is not in alignment with Austin’s Vision Zero policy, to prevent traffic deaths. The “shared use path” is not sufficiently safe or accessible enough to meet Austin’s goals of having an “all-ages and abilities network” of parkland or urban trails.

The potential connectivity for a variety of road users and the recreational opportunity presented by Williamson Creek are not valued in this plan. The “Livable Oak Hill” alternative created by Save Oak Hill shows how these community values can be preserved. For instance, the current TxDOT plan includes zero north – south connections across 290 for non-motorized users that could be considered part of an “all ages and abilities network.” The Livable Oak Hill identifies two such connections, as well as a third connection across 71, that would equitably improve the overall connectivity of the community.

We think it an unfair characterization that the project is “negotiated” and “collaborative.” It is remarkable that the “90 individual stakeholder meetings, 34 e-newsletters, 14 issue-specific workshops, six Open Houses, seven Virtual Open Houses, and a Public Hearing” TxDOT mentions have yielded no significant design changes since 1995. The one significant change is the large degree of excavation which is far worse environmentally.

Neighbors in the “Fix 290” and “Save Oak Hill” coalitions have been asking for an at-grade parkway for decades, which they visualized in the Livable Oak Hill Concept you’ve all received. Instead of six lanes of frontage road, the design improves connectivity through a local complete street, allowing residents to bypass the parkway for short trips. This design would include less impervious cover, preserve many more trees, protect Williamson Creek, and avoid excavation. In other words, it is considerably better for the health of the Barton Springs Edwards Aquifer and the wider natural environment.

We would like to understand how this community-driven design has been considered. The DEIS did not analyze the community’s parkway alternative. The October 12th response letter claims that “the design with a fully at-grade roadway showed significantly more impact to Williamson Creek and its floodplain and riparian zone.” This is because the at-grade alternative referred to here includes the same 12 lanes; This is not the community’s alternative.

In summary, we appreciate the effort of all parties to begin to discuss how to make this a better project. Despite the agreement to the watershed protections in the proposed MOU, we cannot support this project. 

We encourage further negotiations and continued conversations including a fair assessment of the community Livable Oak Hill alternative. We hope that the TIP amendment will not be approved until these issues are resolved. To that end, we suggest delaying a vote on the TIP amendment related to this project until an MOU between the City of Austin and TxDOT is finalized, and you are able to see what provisions are contained within it.

Sincerely,

Angela Richter, Executive Director Save Barton Creek Association

David Foster, State Director Clean Water Action

Luke Metzger, Executive Director Environment Texas

Roy Waley Sierra Club, Austin Regional Group

Bill Bunch, Executive Director Save Our Springs Alliance

Alan Watts, Save Oak Hill

Carol Cespedes, South Windmill Run Neighborhood Association

Tom Wald & Walk Austin Kathy Sokolic, Vision Zero ATX

Tony Catania, President Scenic Brook Neighborhood Association