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Nearly every afternoon I travel down Highway 190 East and then Waterwood Parkway to The Holy Trinity Wilderness Cathedral.

Nearly every afternoon I am saddened by the sight of the carnage in the roadways. Deer, Opossums, Raccoons, Dogs, Cats, Coyotes, Owls, Vultures, Turtles, Terrapins, Songbirds, and other of God’s precious animal children.

The sight of the lifeless and bloodied bodies of these innocent creatures of God takes me back to the early 1950’s when our family first moved from Missouri to East Texas. I had been raised to respect and love all of God’s creatures both great and small from the tiniest firefly to the fattest and longest snake.

Anytime we saw a poor plodding Terrapin in the highway we would stop and move the child of God to safety on the far side of the highway. My sisters and I loved our pet eight foot long Indigo Snake which lived in a doll house for a few days before releasing her into the wild where she belonged.

When I was around four years of age I vividly remember peering into the window of the doll house to look for our marvelous snake. She mistook my nose for a mouse and gave it a pretty snappy little bite but I was even then never afraid of her nor held the marks on my nose against her.

When I was six I started First Grade in Huntsville, Texas, known worldwide as “The City of Death”. My classmates would brag about the animals their fathers had fun running over in the highway and the animals they had killed on a wholesale basis while hunting at any time of the year. It made me sick. (Times and attitudes have progressed very little here in the last half century.)

Now that America (which was once beautiful), has been subdivided, crisscrossed, and fragmented with highways and roadways, God’s little animal children have even less of a chance to survive to care for their own children.

We can and must stop the carnage. There is no excuse for not building highways which have animal corridors so that God’s little creatures can travel from one side of the highway to the other without being killed.

Many of our freeways are now designed as virtual death traps where there are no barriers at the sides of the freeway but a huge concrete wall greets any animal, which dares to venture across, spelling almost certain doom.

Following are examples of what I have to witness on a daily basis as I travel the highways of E. Texas:



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July 23, 2005

George H. Russell wrote:

Excellent comments Brandt. Please visit my web site at

Perhaps the biggest stupidity in this project is that America's enemies will have an easy target to sever communications, pipelines, rail, electric, truck, and auto transporation with just one bomb. Who could miss blasting away at a target that could be seen from the moon?

Another problem is the diminishing supply of fossil fuels which will make this idiocy obsolete very shortly.

All truck and auto, and passenger traffic could be moved at 300 mph on elevated high speed trains in a corridor less than 50 feet wide. Electric cables and pipelines could be buried beneath the elevated rails. Wildlife could pass freely beneath. Farmers and ranchers could pass underneath at any point.

Our idiot Governor is a dupe of Saddam and others.

George H. Russell

P.S. My comment on mitigation lands given to USFS etc. is that they be maintained basically as wilderness with NO LOGGING!!!

Brandt Mannchen wrote:

July 23, 2005

Mr. Ed Pensock, Jr., P.E.
Director of Corridor Systems
Texas Turnpike Authority Division
Texas Department of Transportation
P. O. Box 14428
Austin, Texas 78761

Dear Mr. Pensock,

Enclosed are additional scoping comments from the Houston Regional Group of the Sierra Club (HSC) for the Tier One draft environmental impact statement (DEIS) for the proposed I-69/Trans-Texas Corridor (I-69/TTC) project from the Texas Department of Transportation and the U.S. Department of Transportation (TxDOT/USDOT).

1) Display Board Information Hand-out – The HSC appreciates that TxDOT/USDOT provided copies of the display boards to each person who visited the I-69/TTC meetings. This is an improvement from past meetings where no such hand-outs were available to the public. In the past if you wanted a copy of the display boards you would be charged many dollars. Thank you for this improvement.

2) DEIS Availability and Charge – The HSC requests a copy of the Tier One DEIS when it is complete. We would like a hard copy but if a copy is not available without charge then we request a copy via CD. We are very concerned that in the past TxDOT/USDOT has charged over $100 for a hard copy of DEISs when Section 1502.9, it states, “However, if the statement is unusually long, the agency may circulate the summary instead, except that the entire statement shall be furnished to: (c) Any person, organization, or agency requesting the entire environmental impact statement, (d) In the case of a final environmental impact statement any person, organization, or agency which submitted substantive comments on the draft. If the agency circulates the summary and thereafter receives a timely request for the entire statement and for additional time to comment, the time for that requestor only shall be extended by at least 15 days beyond the minimum period.”

3) Pace of Tier One DEIS Process – The HSC is also concerned about the speed of the Tier One DEIS process. The green and white I-69/TTC brochure states that, “The findings of the Tier One DEIS will be presented through a series of public hearings – tentatively scheduled for Spring 2006.” For such a complicated and large project that has the potential to do an incredible amount of environmental damage this timeframe is far too short to adequately analyze, assess, and evaluate all reasonable alternatives and consider all environmental, social, economic, and Quality of Life impacts including those that affect the health, welfare, environment, and safety of the citizens of Texas and the Houston area. Slow down and do the job right!

4) Early ROW Acquisition – The HSC is concerned that the green and white I-69/TTC brochure states, “Although typically ROW acquisition does not being until final environmental approval is obtained … limited amounts of ROW may be acquired earlier under special circumstances.” This is contrary to the President’s Council on Environmental Quality’s (CEQ) regulations which state in Section 1502.2(f), “Agencies shall not commit resources prejudicing selection of alternatives before making a final decision”. The HSC urges TxDOT/USDOT to fully implement CEQ regulations and the National Environmental Policy Act (NEPA).

5) Amount of Project Impact – The HSC is very concerned about the concept of I-69/TTC. If implemented as announced this system of transportation corridors will fragment the entire State of Texas and create a huge, unified, wildlife and vegetation migration barrier. The isolation that these 1200 foot wide and 100s of miles long corridors will provided is significant and sobering.

For instance, the proposal to have one segment just to the east and one segment just to the west of the boundaries of Sam Houston National Forest (SHNF) covers about 50 miles in distance, twice, from the Houston area to past the SHNF boundaries. The calculation of acreage lost and barrier size is as follows:

50 miles (east segment) + 50 miles (west segment) = 100 miles in length

100 miles x 5,283 feet = 528,300 feet in length

1200 feet (right-of-way width) x 528,300 feet = 633,960,000 square feet

633,960,000 square feet divided by 43,560 feet (one acre) = 14,553.71901 acres of potential habitat destroyed, degraded, or altered in the right-of-way alone.

This of course is a significant underestimate of the damage that this proposal will do just to the Houston to SHNF area segment. Many more acres will be destroyed indirectly due to cumulative and secondary development impacts. Many other acres will be directly and indirectly destroyed in other parts of South and East Texas due to the I-69/TTC right-of-way and secondary development impacts.

To say that the TxDOT/USDOT has a huge job, considering only environmental concerns, is an enormous understatement. It is of concern to the HSC that in the past the TxDOT/USDOT has not shown the leadership and environmental sensitivity on much smaller and less complicated projects. How TxDOT/USDOT fares with this endeavor, if it is approved, will determine its sincerity and willingness to do the will of the People of Texas?

Given these concerns and our inherent suspicion of what really drives this proposal the HSC has a number comments and recommendations that we request that the TxDOT/USODT not simply consider, but implement. If this proposal does go forward environmental damages must be minimized and reduced as much as possible.

There is no doubt that $100s of millions of dollars in mitigation will be required, both in land acquisition, and in pollution reduction to address some of the environmental impacts that this proposal would cause. If TxDOT/USDOT cannot comply with environmental laws and will not implement complete mitigation, including maintenance of mitigation for the life of the project, then citizens’ tax dollars must not be wasted in determining whether this proposal should be undertaken.
5) Mitigation Lands – A series of mitigation banks or areas should be designated that will receive land, money, and technical assistance regarding ecological, biological, and wildlife habitat preservation, protection, and conservation.

Some of these mitigation banks/areas, in no order of priority, are:

1) Sam Houston National Forest
2) Katy Prairie
3) Lake Houston State Park
4) Jones State Forest
5) Trinity River National Wildlife Refuge
6) The East and West Forks of the San Jacinto River and certain tributaries (Tarkington Bayou, Luce Bayou, Spring Creek, and Cypress Creek)
7) Cook’s Branch Conservancy – About 6,000 acres that the George Mitchell Family owns (has federally endangered Red-cockaded Woodpeckers (RCW))
8) Stephen F. Austin State Park
9) Huntsville State Park
10) Brazos Bend State Park

In particular, a linkage of the Jones State Forest RCW population to the SHNF RCW population is critical if the Jones State Forest population is not to be isolated by urban developed and slowly shrunk to extinction.

The acquisition of floodplain lands along the rivers and creeks mentioned above would not only serve as mitigation for some of the best wildlife habitat lost due to the direct and indirect impacts of this proposal but would also function of natural flood control areas and would link with Harris and Montgomery Counties efforts to protect parkland and the Legacy Land Trust’s efforts to protect important floodplain and upland forests.

Another concern that the HSC has about the I-69/Trans-Texas Corridor is the mitigation required for all types of wildlife habitat. Any unavoidable wetlands or forested habitat destruction, damage, or diminishment must be mitigated at least 6:1. Secondary development impacts must be revealed and mitigation provided for these impacts in the DEIS. The HSC recommends forested wetlands or forested habitat lost due to the I-69/Trans-Texas Corridor development be mitigated via buying land and donating it to the U. S. Forest Service as an addition to SHNF. The same mitigation ratio applies for prairie ecosystems since 99% of the original native prairie in the United States has been destroyed.
In at least two places the San Jacinto River floodplain will be crossed by the I-69/Trans-TTC in one segment. Any wetlands, aquatic, or forested habitat that is destroyed or disturbed needs to be mitigated at least 6:1. The HSC favors protecting the floodplain along the San Jacinto River so it will act as a wildlife migration corridor from SHNF to Lake Houston. We also support protecting the floodplains, wetlands, and forested wetlands of Spring and Cypress Creeks which the I-69/TTC will cross. Mitigation for all habitat lost due to direct and indirect impacts must be provided for via permanent wildlife land acquisition and protection.
6) Existing Sensitive Areas – TxDOT should identify as many sensitive areas in and near the corridors as possible and work with other agencies to acquire protective buffers of land so that direct and indirect (secondary and cumulative) environmental impacts are blunted.

7) Transportation Mode Integration – In addition to the transportation modes that TxDOT/USDOT has proposed for I-69/TTC it is time to integrate a pedestrian (hiking) and bicycling network so that people can cross Texas without using cars or trucks. A landscaped and or naturally preserved buffer of land where bikers and hikers can move makes sense. This buffer would provide scenic enhancement of the corridor, noise abatement, and nonpoint source water pollution control of I-69/TTC.

8) Cumulative Effects Analysis – In the past TXDOT/USDOT has failed to conduct realistic and complete cumulative effects analysis.

At minimum, an adequate cumulative effects analysis must:
1) Identify the past, present, and reasonably foreseeable actions of TxDOT/USDOT and other parties affecting each particular aspect of the affected environment

2) Must provide quantitative information regarding past changes in habitat quality and quantity, water quality, resource values, and other aspects of the affected environment that are likely to be altered by TxDOT/USDOT actions

3) Must estimate incremental changes in these conditions that will result from TxDOT/USDOT actions in combination with actions of other parties, including synergistic effects

4) Must identify any critical thresholds of environmental concern that may be exceeded by TxDOT/USDOT actions in combination with actions of other parties

5) Must identify specific mitigation measures that will be implemented to reduce or eliminate such effects

The NEPA and the CEQ require that analysis, assessment, and evaluation of cumulative impacts be conducted. Please see Chapter 1508.7 and 1508.8 of the CEQ regulations which are binding on all federal agencies to implement.

Please also see the CEQ’s January 1997 document, “Considering Cumulative Effects Under the National Environmental Policy Act.” It is clear that the NPS has an affirmative duty, a statutory duty, and a regulatory duty to carry out cumulative impacts assessment.

The TxDOT/USDOT in the past has attempted to short-circuit this required duty. TxDOT/USDOT should use the CEQ’s “Considering Cumulative Effects Under the National Environmental Policy Act” to conduct a cumulative impacts assessment. Some of the especially important quotes from the CEQ document include:

a. On page v, “Only by reevaluating and modifying alternatives in light of the projected cumulative effects can adverse consequences be effectively avoided or minimized. Considering cumulative effects is also essential to developing appropriate mitigation and monitoring its effectiveness.”

b. On page v, “By evaluating resource impact zones and the life cycle of effects rather than projects, the analyst can properly bound the cumulative effects analysis. Scoping can also facilitate the interagency cooperation needed to identify agency plans and other actions whose effects might overlap those of the proposed action.”

c. On page vi, “When the analyst describes the affected environment, he or she is setting the environmental baseline and thresholds of environmental change that are important for analyzing cumulative effects. Recently developed indicators of ecological integrity (e.g., index of biotic integrity for fish) and landscape conditions (e.g., fragmentation of habitat patches) can be used as benchmarks of accumulated change over time … GIS technologies provide improved means to analyze historical change in indicators of the condition of resources, ecosystems, and human communities, as well as the relevant stress factors.

d. On page vi, “Most often, the historical context surrounding the resource is critical to developing these baselines and thresholds and to supporting both imminent and future decision-making.”

e. On page vi “… the consequences of human activities will vary from those that were predicted and mitigated … therefore, monitoring the accuracy of predictions and the success of mitigation measures is critical.

f. On page vi, “Special methods are also available to address the unique aspects of cumulative effects, including carrying capacity analysis, ecosystem analysis, economic impacts analysis, and social impact analysis.

g. On page vii, Table E-1, “CEA Principles … Cumulative effects analysis …Address additive, countervailing, and synergistic effects … Look beyond the life of the action.

h. On page 1, “The range of actions that must be considered includes not only the projects proposal but all connected and similar actions that could contribute to cumulative effects.

i. On page 3, “The purpose of cumulative effects analysis, therefore is to ensure that federal decisions consider the full range of consequences of actions … If cumulative effects become apparent as agency programs are being planned or as larger strategies and policies are developed then potential cumulative effects should be analyzed at that times.

j. On page 3, Cumulative effects analysis necessarily involves assumptions and uncertainties, but useful information can be put on the decision-making table now … Important research and monitoring programs can be identified that will improve analyses in the future, but their absence should not be used as a reason for not analyzing cumulative effects to the extent possible now … adaptive management provisions for flexible project implementation can be incorporated into the selected alternative.”

k. On page 4, “The Federal Highway Administration and state transportation agencies frequently make decisions on highway projects that may not have significant direct environmental effects, but that may induce indirect and cumulative effects by permitting other development activities that have significant effects on air and water resources at a regional or national scale. The highway and other development activities can reasonably be foreseen as “connected actions.

l. On page 7, “Increasingly, decision makers are recognizing the importance of looking at their projects in the context of other development in the community or region (i.e., of analyzing the cumulative effects) … Without a definitive threshold, the NEPA practitioner should compare the cumulative effects of multiple actions with appropriate national, regional, state, or community goals to determine whether the total effect is significant … Cumulative effects results from spatial (geographic) and temporal (time) crowding of environmental perturbations. The effects of human activities will accumulate when a second perturbation occurs at a site before the ecosystem can fully rebound from the effect of the first perturbation.”

m. On page 8, Table 1-2, lists 8 principles of cumulative effects analysis. A summary of summary of these principles includes:

1) Cumulative effects are caused by the aggregate of past, present, and reasonably foreseeable future actions.

2) Cumulative effects are the total effect, including both direct and indirect effects, on a given resource, ecosystem, and human community of all actions taken no matter who has taken the actions.

3) Cumulative effects need to be analyzed in terms of than specific resource, ecosystem, and human community being affected.

4) It is not practical to analyze the cumulative effects of an action on the universe; the list of environmental effects must focus on those that are truly meaningful.

5) Cumulative effects on a given resource, ecosystem, and human community are rarely aligned with political or administrative boundaries.

6) Cumulative effects may result form the accumulation of similar effects or the synergistic interaction of different effects.

7) Cumulative effects may last for many years beyond the life of the action that caused the effects.

8) Each affected resource, ecosystem, and human community must be analyzed in term of its capacity to accommodate additional effects, based on its own time and space parameters.

n. On page 19, “The first step in identifying future actions is to investigate the plans of the proponent agency and other agencies in the area. Commonly, analysts only include those plans for actions which are funded or for which other NEPA analysis is being prepared. This approach does not meet the letter or intent of CEQ’s regulations … The analyst should develop guidelines as to what constitutes “reasonably foreseeable future actions” based on planning process within each agency … In many cases, local government planning agencies can provide useful information on the likely future development of the region, such as master plans. Local zoning requirements, water supply plans, economic development plans, and various permitting records will help in identifying reasonably foreseeable private actions … These plans can be considered in the analysis, but it is important to indicate in the NEPA analysis whether these plans were presented by the private party responsible for originating the action. Whenever speculative projections of future development are used, the analyst should provide an explicit description of the assumptions involved … NEPA litigation … has made it clear that “reasonable forecasting” is implicit in NEPA and that it is the responsibility of federal agencies to predict the environmental effects of proposed actions before they are fully known.

o. On page 23, “Characterizing the affected environment in a NEPA analysis that addresses cumulative effects requires special attention to defining baseline conditions. These baseline conditions provide the context for evaluating environmental consequences and should include historical cumulative effects to the extent feasible.

p. On page 29, “Lastly, trends analysis of change in the extent and magnitude of stresses in critical for projecting the future cumulative effects.

q. On page 29, “Government regulations and administrative standards … often influence developmental activity and the resultant cumulative stress on resources, ecosystems, and human communities.

r. On page 31, “Cumulative effects occur through the accumulation of effects over varying periods of time. For this reason, an understanding of the historical context of effects is critical to assessing the direct, indirect, and cumulative effects of proposed actions. Trends data can be used … to establish the baseline for the affected environment more accurately (i.e., by incorporating variation over time) … to evaluate the significance of effects relative to historical degradation (i.e., by helping to estimate how close the resource is to a threshold of degradation) … to predict the effects of the actions (i.e., by using the model of cause and effects established by past actions).”

s. On pages 38-40, “Using information gathered to describe the affected environment, the factors that affect resources (i.e., the causes in the cause-and-effect relationships) can be identified and a conceptual model of cause and effect developed … The cause-and-effect model can aid in the identification of past, present, and future actions that should be considered in the analysis … The cause-and effect relationships for each resource are used to determine the magnitude of the cumulative effect resulting from all actions included in the analysis … one of the most useful approaches for determining the likely response of the resource … to environmental change is to evaluate the historical effects of activities similar to those under consideration.

t. On page 41, “The analyst’s primary goal is to determine the magnitude and significance of the environmental consequences of the proposed action in the context of the cumulative effects of other past, present, and future actions … The critical element in this conceptual model is defining an appropriate baseline or threshold condition of the resource.

u. On page 43, “Situations can arise where an incremental effect that exceeds the threshold of concern for cumulative effects results, not from the proposed action, but the reasonably foreseeable but still uncertain future actions.

v. On page 45, “The significance of effects should be determined based on context and intensity … Intensity refers to the severity of effect … As discussed above, the magnitude of an effect reflects relative size or amount of an effect. Geographic extent considers how widespread the effect might be. Duration and frequency refers to whether the effect is a one-time event, intermittent, or chronic.

w. On page 45, “Determinations of significance … are the focus of analysis because they lead to additional (more costly) analysis or to inclusion of additional mitigation (or a detailed justification for not implementing mitigation) … the project proponent should avoid, minimize, or mitigate adverse effects by modifying alternatives … in most cases, however, avoidance or minimization are more effective than remediating unwanted effects.”

y. On page 51, “different resource effects that cumulatively affect interconnected systems must be addressed in combination.”

The TxDOT/USDOT must utilize the CEQ document to the maximum extent possible so that a full and legal cumulative impacts assessment is conducted. There must be specific quantitative cumulative impact assessment for any past, present, and reasonably future foreseeable action in the EIS.

9) Need and Purpose for I-69/TTC – TxDOT/USDOT must clearly justify qualitatively and quantitatively the need and purpose for I-69/TTC. TxDOT/USDOT states that:

1) Faster and safer transportation of people, goods, and commodities will occur. This needs to be documented and not simply be an assertion that cannot be proved. How much faster will commodities be transported? How much safer will commodities be transported? What specific commodities will be helped or hurt? What specific goods will be helped or hurt? How much faster will people arrive at their destinations? How much safer will people be? Which people will benefit? Which people will not benefit? Which people will pay? Which people will not pay or will pay less than their fair share?

2) Relief of congested transportation facilities. Which transportation facilities? How many transportation facilities? How much will congestion lessen on each transportation facility? Where are these transportation facilities? Will congestion worsen due to I-69/TTC on any of these or other transportation facilities? When will I-69/TTC become congested? What is the total build-out in passenger vehicle lanes, dedicated truck lanes, high-speed passenger rail, freight rail, commuter rail, water utilities, electric utilities, petroleum utilities, communication utilities for I-69/TTC? How long will congestion improvements last for each transportation facility affected by the I-69/TTC?
3) Provide alternative hazardous material routes. Which hazardous material routes will be provided an alternate route? Are these routes congested now? What is their accident record? What will be the projected accident rate for I-69/TTC when it is congested? How much will the accident rate for hazardous material routes be affected by I-69/TTC? Will I-69/TTC increase hazardous accident rates or overall incident seriousness by concentrating their numbers close to developed areas and transportation areas?
4) Accomplish the goals established by federal and state legislation. What state and federal legislation is referred to? Who benefits from the legislation? Who does not benefit? What are these goals? Are they supported by the People? What effects will implementation of these goals have on Quality of Life, environment, health, welfare, and safety of the People? How much will it cost to implement these goals? Who will pay? Who will benefit? How will international trade be improved? What international trade will be improved? What international trade will not be improved or will deteriorate? What will be the social, environmental, and economic impacts of this? How will interstate trade be improved? What interstate trade will be improved? What interstate trade will not be improved or will deteriorate? What will be the social, environmental, and economic impacts of this? How will “economic vitality” be “sustained and enhanced”? What is the definition for “economic vitality”? What is the definition for “sustaining and enhancing economic vitality”? Who will be the winners? Who will be the losers?

These are only some of the questions that TxDOT/USDOT must answer in the EIS about the need and purpose of I-69/TTC.

10) Regional Impacts Including Air Pollution – The Tier I EIS must comprehensively determine the environmental, social, and economic impacts, beneficial and negative, that will occur in Mexico, Laredo, Rio Grande Valley, South Texas, East Texas, and the Texarkana/Shreveport areas due to I-69/TTC.

In particular air pollution health, welfare, environment, and safety impacts, from the standpoint of regional ozone, regional haze, and regional particulate impacts, must be fully assessed.

11) Failure to Require EISs for Tier Two Proposals – TxDOT/USDOT does not commit to implement the National Environmental Policy Act (NEPA) in a legal manner. The segments of I-69/TTC will be “major federal actions significantly affecting the quality of the human environment”. However TxDOT/USDOT does not commit to preparing an EIS for each segment of I-69/TTC. Rather it commits to preparing “several environmental processes/documents”. This means that TxDOT/USDOT will attempt to avoid its responsibility to prepare EISs by using environmental assessments (EAs) instead. This is not legal. The HSC opposes any effort to use EAs to avoid TxDOT/USDOT’s responsibilities to conduct EISs.

Further TxDOT/USDOT does not fully explain how many and where all the linkages are that will allow access to the I-69/TTC proposal from other nearby areas like Houston. TxDOT/USDOT attempts to ignore the connection that the Grand Parkway has with this proposal by saying the Grand Parkway alignment will be “determined by a separate and ongoing environmental process”. However, the TxDOT/USDOT does not state that the Grand Parkway uses its linkage to I-69/TTC as a purpose and benefit.

What TxDOT/USDOT does say is that the Grand Parkway will not be determined “as part of the I-69/TTC Tier One environmental study process”. TxDOT/USDOT does not say that the Grand Parkway will not be considered in a Tier Two environmental document. Therefore the linkage between these two proposals must be considered and fully explored in the I-69/TTC EIS including cumulative, direct, indirect, and secondary development and environmental impacts.

12) Next 20-50 Year Transportation Needs – The I-69/TTC hand-outs state that one purpose is to “Address anticipated south and east Texas transportation needs for the next 20 to 50 years. The EIS must also analyze what the environmental impacts will be due to the next 20-50 year transportation needs and how these needs are linked to I-69/TTC.

13) Wildlife Corridors – TxDOT/USDOT must cover in detail in the EIS the need, location, and methods that it will use to establish wildlife corridors for I-69/TTC. The HSC recommends that TxDOT/USDOT read and follow “Road Ecology: Science and Solutions” by Richard T.T. Forman, et. al., published by Island Press. This book is an excellent source of the technology that is available. The HSC also recommends that TxDOT/USDOT confer with Canada and Florida about the projects they have implemented for wildlife corridors.

14) Population Projections – TxDOT/USDOT states that the need for I-69/TTC is to “Serve Projected population growth. The HSC is very concerned that TxDOT/USDOT will consider population projects as goals to meet. Trend is not destiny.

The HSC is very concerned that TxDOT/USDOT preordains what population will be in 2060. Instead of having a public debate about what population, Quality of Life, and state of the environment should be and that Texans and Houstonians want in 2060, TxDOT/USDOT use population projections that call for a doubling in size of Texas (from 21 million to 45 million) and in the Houston area (from 4,848,918 to 10,897,526).

Population projections are the very foundation of all planning, including water use, in Texas. TxDOT/USDOT does not know what Texans want. TxDOT/USDOT has not asked what Texans and Houstonians want. TxDOT/USDOT must tell Texans and Houstonians what more than doubling the population will mean for them, their children, and grandchildren regarding costs to air quality, water quality, noise, light pollution, traffic congestion, green space and parks, farmland, social services, quality of life, infrastructure, etc.

The Texas Water Development Board (TWDB) projects the population first; does not take into consideration what the environment and Quality of Life will be like before making this projection or even after this projection is made; does not determine what Texans and Houstonians want their environment and quality of life to be like before this projection is made; assumes Texans and Houstonians want more than a doubling of the population; and then plans for water use based on this more than doubling of the population.

Transportation demands implement a proposal that has made a policy decision without public policy debate and that is not backed by Texans and Houstonians. This policy decision decides what population growth Texans and Houstonians will endure and does not determine what population growth Texans and Houstonians want.

By not conducting this public policy debate the TWDB and TxDOT/USDOT ensures that construction of transportation infrastructure for 45 million people will occur and that we will, in all probability, utilize these facilities to grow to 45 million people in 2060. By conducting transportation planning this way TxDOT/USDOT implement the fallacy that “Trend is Destiny.” Texans and Houstonians are not preordained to have a continuing growth in population or a growth in population that is the size that TWDB and TxDOT/USDOT says we will have.
There are many public policy questions that must be answered by Texans and Houstonians before population projections are made. Some of these include:

1) What population do we want?
2) What population can we handle (so we do not exceed natural carrying capacities)?
3) Is growth in population good or bad?
4) Do we need growth in population?
5) Why do we need growth in population?
6) How much population growth should we have?
7) What quality of population growth do we want?
8) What can we do to reduce population growth?
9) Why don’t we reduce population growth?
10) How much immigration is good?
11) How much immigration is bad?
12) How can we control and direct population growth?
13) What methods can we use to control and direct population growth?
14) How can we implement birth control, sex education, and family planning?
15) What level of economic growth do we want?
16) What level of economic growth do we need?

Without conducting a public policy debate on these and other questions first, the population projections presented are a fait acompli and Texans and Houstonians are not being allowed a fair opportunity to voice what they want.
These population projections also do not take into account how growth trends can alter what the projections say. For instance the trend (and policy issue) of moving into rural areas is not reflected in the population projections in several counties that are outer-lying to Harris County (Trinity County being an example). The trend (and policy issue) of companies moving out of the more urban or populated areas and taking jobs with them to more rural areas is also not addressed in the population projections. Do we want to encourage these trends or not? Why are we not debating these public policy issues before projecting population? Texans and Houstonians are locked out of the process that determines growth, population growth, and growth in transportation.

It seems obvious that the long planning time frame for transportation projects may cause projects to be built on speculation. This speculation in population growth and transportation use will then become fact. It is the HSC contention that when a population creates a transportation system that causes unhealthy levels of air pollution, noise, water pollution, and flooding then it has already exceeded the carrying capacity of the air, noise, water, and flooding sheds and that population is already greater than it should be.

The human population carrying capacity of each area of Texas needs to be determined, taking into account protecting sensitive areas and ecosystem needs, and then we need to plan so we do not exceed this population projection. This should be the goal of every transportation plan. We need a steady-state economy.

We need a full, public, debate to ensure that we get it right. By getting it wrong we ensure that we will degrade the environment that we rely on for all of our needs which means we will degrade our Quality of Life and reduce the carrying capacity for humans and especially for those who live after us. We reduce their options as we mandate transportation use now. We bring ourselves closer to ecological overshoot or collapse by not recognizing that humans are animals too and we are dependent on the same ecological principles as every other living organism. We cannot avoid this bullet.

The question needs to be asked: Do Texans and Houstonians want 45 million and almost 11 million people, respectively? The Houston area is already above its human carrying capacity. This is reflected individually and cumulatively by the following:

1) For air quality, the Houston area exceeds the ozone National Ambient Air Quality Standard and has high levels of toxic air pollutants.

2) For water quality, many bayous and other streams exceed their water quality standards.

3) For water absorption capacity, major floods occur every year in human occupied areas.

4) For transportation, congestion is found on most major roads.

5) For groundwater capacity, there are falling groundwater levels in many places, activated faults, and subsidence.

6) For surface water capacity, overuse of surface water has led to importation of surface water across river basins.

7) For protected park and ecological lands, Houston is far below standards for park acreage/1,000 people.

8) For farmland, farmland use and acreage is decreasing in many counties.

9) For quiet, noise is so high that noise barriers are being erected on many highways.

10) For wildlife habitat, wetlands acreage is decreasing.
When will the TWDB and TxDOT/USDOT address the problem of exceeding Houston’s human carrying capacity?

15) Serve Projected Increases in Freight Movement – TxDOT/USDOT must answer many questions about this need including, What are the projected increases? How were they derived? How realistic are the assumptions made for the projections? What freight will increase? What freight will decrease? Should freight movement be encouraged using roads or rails due to the instability of supply of foreign sources of oil?

16) Preserve a Corridor that Can Accommodate Future Transportation Needs - TxDOT/USDOT must answer many questions about this need including, What are the future transportation needs? When will these needs arise? Who benefits from these needs? Who does not benefit?

17) All Reasonable Alternatives – In the past TxDOT/USDOT has been loath to give other alternatives, other than highway construction, fair analyses in EISs. This needs to change with the Tier One and Two EISs for I-69/TTC.

The President’s Council on Environmental Quality (CEQ) NEPA implementing regulations requires that alternative analysis on “all reasonable alternatives” be conducted. In Section 1502.14(a) of these rules CEQ states, “Rigorously explore and objectively evaluate all reasonable alternatives”. Such an “all reasonable alternatives” analysis would include alternatives with a mix of transportation options including fewer highway lanes and no toll roads. TxDOT/USDOT must not ignore alternatives that provide a mix of protective strategies.

18) Quantitative Assessment, Analysis, and Evaluation – TxDOT/USDOT must not only conduct qualitative assessment, analysis, and evaluation of environmental impacts to satisfy the clearly articulated CEQ requirements in Section 1502.14, that an EIS “should present the environmental impacts of the proposal and the alternatives in comparative form, thus sharply defining the issues and providing a clear basis for choice among options by the decision-maker and the public”.

Quantitative assessment, analysis, and evaluation are necessary to ensure that alternatives and environmental impacts are clearly defined and shown in the EIS. As stated in the CEQ NEPA implementing regulations, Section 1500.1(b), Purpose, “NEPA procedures must insure that environmental information is available to public officials and citizens … The information must be of high quality. Accurate scientific analysis … are essential to implementing NEPA”.

As stated in Section 1501.2(b), “Identify environmental effects and values in adequate detail so they can be compared to economic and technical analyses.”

As stated in Section 1502.8, “which will be based upon the analysis and supporting data from the natural and social sciences and the environmental design arts.”

As stated in Section 1502.18(b), about the Appendix, “Normally consist of material which substantiates any analysis fundamental to the impact statement”.

As stated in Section 1502.24, “Agencies shall insure the professional integrity, of the discussions and analyses … They shall identify any methodologies used and shall make explicit reference by footnote to the scientific and other sources relied upon for conclusions in the statement.”
The qualitative description of phrases used to describe environmental impacts or the protectiveness of an alternative does not provide the public with the degree of comparison required by the CEQ. TxDOT/USDOT must ensure that it quantitatively analyzes, assesses, and evaluates the I-69/TTC proposal during its alternative analysis and presents this in the EIS.

19) Identify Areas to Protect the Natural, Cultural, and Social Environments – The HSC supports a full analysis of this evaluation criteria.

20) Maintenance – TxDOT/USDOT must examine in the EIS the environmental, social, economic, and Quality of Life impacts of maintenance due to the implementation of each alternative of the I-69/TTC proposal. In addition, the EIS must consider the ability of TxDOT/USDOT to keep up with maintenance costs over the lifetime of the project.

21) Sprawl Inducement – TxDOT/USDOT must examine in the EIS the environmental, social, economic, and Quality of Life impacts of any induced sprawl that occurs due to the implementation of each alternative of the I-69/TTC proposal.

22) Dependency on Foreign Oil – TxDOT/USDOT must examine in the EIS the environmental, social, economic, and Quality of Life impacts of tying the United States and Texas to dependency on foreign oil sources due to implementation of each alternative of the I-69/TTC proposal. Will the proposal encourage the use of one/person/one car modes? Should the proposal get people out of their cars to reduce congestion? Can the proposal help TxDOT/USDOT, over the long-term, catch-up with its congestion reduction program or will I-69/TTC add to the backlog over the long-term?

23) Transportation Mode Competition - TxDOT/USDOT must examine in the EIS the environmental, social, economic, and Quality of Life impacts of the competition between each transportation mode that each alternative of the I-69/TTC proposal has (passenger vehicle lanes, dedicated truck lanes, high-speed passenger rail, freight rail, commuter rail, water utilities, electric utilities, petroleum utilities, communication utilities) against the other modes. Will the I-69/TTC proposal increase competition of highway use against rail use?

24) Road Kill - TxDOT/USDOT must examine in the EIS the environmental, social, economic, and Quality of Life impacts of due to increased roadkill caused by the I-69/TTC proposal.

25) Impacts on Katy Prairie and Protection by Katy Prairie Conservancy – The HSC is extremely concerned that TxDOT/USDOT proposes that the I-69/TTC run through the heart of the Katy Prairie. Several different alternative alignments go through the Katy Prairie and the HSC is opposed to these alignments since they will destroy a functioning prairie ecosystem that is being restored by the Katy Prairie Conservancy.

26) Sam Houston National Forest (SHNF) – The I-69/TTC corridor could pass within less than a mile to several miles of the boundary of federally owned property that makes up part of SHNF. The present boundary of this I-69/TCC segment is Wharton County on the south and the San Jacinto/Liberty County lines on the north. We request that the boundary of this segment of I-69/TCC be lengthened to the Trinity River or Shepherd, Texas.
The reason for this request is to ensure that the DEISs, both for Tier One and Two, will analyze and assess the impacts of all of the I-69/TTC that passes near all areas of SHNF that may be affected by the proposal. If the corridor is not lengthened the impacts to SHNF will be divided into two different DEISs that will take place at two different times and the entire, cumulative impacts, including direct and indirect impacts will not be assessed together.

The HSC is particularly concerned about indirect cumulative impacts like additional road widening, secondary development including sprawl, vandalism, visual pollution, noise pollution, air pollution, soil erosion, water pollution, incompatible land uses, conflicts with recreational and other uses, trash dumping, littering, poaching, illegal off-road vehicle use, forest fragmentation, and other problems near and next to SHNF.

Along the I-59 corridor, development just south of Cleveland, Texas is accelerating. Much of the right-of-way private land on the west side of I-59, between Splendora and Cleveland has been developed. In addition, a 12,000 acre area, just south of State Highway 105 to Splendora, has been developed in less than 10 years into ranchettes. I-69/TTC will accelerate this trend by making access easier and will spur counties to widen other roads because of increased population and traffic.

A good, hard, close look must be taken at secondary development and cumulative impacts. An example of how this can be done is the Westside Airport EIS where U. S. Fish and Wildlife Service estimated 40,000 acres would be impacted by secondary development. Oftentimes the major impact of a project like I-69/TCC is secondary development. These impacts can be estimated, using recent growth figures, to give a good ballpark idea of what level of development will be induced by the highway expansion and what the associated impacts are.

27) Grand Parkway – The HSC opposes all I-69/TCC proposals which link up to the proposed Grand Parkway. The I-69 feasibility study proposed that the east side of the Grand Parkway, from Baytown to I-59, go directly through Lake Houston State Park, the forested wetlands of the San Jacinto River floodplain, and other stream floodplains. The HSC opposes any I-69/TCC proposal which goes through the Katy Prairie or near Brazos Bend State Park.

28) Air Pollution From Mobile Sources and Secondary Development – The HSC is concerned about increased air pollution from mobile sources and secondary development. Several years ago, in SHNF, near Lake Conroe, vegetation damage due to ozone air pollution was found. We are concerned that the I-69/TCC will create more air pollution which will reduce visibility and harm forest vegetation. Air monitoring stations must be set-up near or in the corridor to determine the present air quality baseline so that the public can see what impacts the I-69/TTC will have on air quality.

Large numbers of diesel powered trucks, both from the United States and south of our border, will emit large amounts of volatile organic compounds, nitrogen oxides, particulates, and create ozone pollution in the corridor. Diesel air pollution has been linked to increased cancer and other health effects. A comprehensive health effects study regarding the direct and indirect (secondary) air emissions from the I-69/TTC must be prepared and used in the DEIS.

Fort Bend, Harris, Montgomery, and Liberty Counties are already in the Houston-Galveston Ozone Nonattainment Area. The I-69/Trans-Texas Corridor will make air pollution problems worse in the Houston-Galveston Ozone Nonattainment Area due to emissions that are directly emitted by motor vehicles and indirectly emitted due to secondary development and growth in the number of people living in our area.

29) Flawed I-69/TTC Feasibility Study Foundation – The I-69 feasibility study did not use environmental factors in the fatal flaws analysis. For instance impacts to state parks, threatened, endangered, or sensitive species, floodplains, wetlands, and SHNF should have provided a "go or no go" decision like the three factors that were used in the fatal flaws analysis. The HSC protests the unbalanced fatal flaws analysis that was used in the feasibility study for I-69/TTC and which served as a basis for the Tier One DEIS process.

The HSC appreciates this opportunity to comment. We request that we be kept on the mailing list and be contacted about any future meetings about I-69/TTC. We also request in additional information that is generated by this proposal as it becomes available. Thank you.


Brandt Mannchen
Chair, Forestry Subcommittee
Chair, Air Quality Committee
Houston Regional Group of the Sierra Club
Lone Star Chapter
5431 Carew
Houston, Texas 77096