Tuesday, March 25, 2008

Deadline for mailed and online public comments on TTC-69: Friday, April 18, 2008


Citizens for a Better Waller County
Copyright 2008

The following information is provided by Citizens for a Better Waller County (CBWC) as a guide to citizens in how to respond and provide input to the Texas Department of Transportation (TxDOT) in regards to the Draft Environmental Impact Statement (DEIS) for the proposed Trans Texas Corridor/I-69 route (TTC-69). The information contained herein is not intended to be an exhaustive list, and recommendations found here are the recommendations of CBWC.

First, it is important to understand what is the DEIS? Prepared jointly by Texas Department of Transportation (TxDOT) and Federal Highway Administration (FHWA), the purpose is toidentify the “best route” for the TTC-69 taking the following factors into consideration:

– Avoid resources protected by law or regulation
– Minimize inclusion of other natural resources
– Minimize the potential for social and economic effects
– Minimize the potential to affect existing infrastructure
– Allow a buffer from development around protected resources
– Provide space for transportation system connections
– Consider local and regional planning objectives

The DEIS is over 1000 pages. The easiest way to access the document is through TxDOT’s website by clicking HERE.

You can also request either adisk or paper copy at cost of printing at 1-866-554-6989. (Disk is less than $5, but a full paper copy is about $300). Copies are also available at most public libraries in the area.

TxDOT is currently receiving public comment and input on the DEIS through April 18, 2008.


Official comments from the public that are “on the record” can be done in any one of three ways:

I. PUBLIC HEARING: A series of public hearings were held throughout various cities along the TTC-69 route and have since been completed March 4, 2008

II. ONLINE: You can submit comments online through TXDOT’s website by clicking HERE.

However, there are limitations.
  • First, you are limited to 1000 characters for your comments.
  • Second, the online form DOES NOT contain a box to check to indicate that you don't support any TTC route with the "I Oppose the TTC-69" and "I Support the NO Action Alternative". If you are opposed to the TTC-69, you should make sure you state that you want the “NO ACTION ALTERNATIVE”, which means the TTC-69 should not be built – anywhere. Period.
III. IN WRITING: Written comments may be submitted by mail or at the Public Hearings. There is no limit on the length of written comments. If you submit by mail, the mailing address is TTC-69 P.O. Box 14428 Austin, TX. 78761. Again, we recommend that you include the language that you support the “NO ACTION ALTERNATIVE”. Written comments must be submitted by March 19, 2008.

Again, we recommend that any comments you give to TXDOT in this format should begin or include the fact that you support the “NO ACTION ALTERNATIVE”.



Additionally, it is best for each member of a household to make comments individually rather than making a comment as a household unit.

TxDOT is required by law to respond to every comment or objection to the DEIS that falls within the categories of issues that the DEIS is designed to address. These issues include factors such as environmental, historical significance, social and economic impacts, natural resources,and transportation issues.

It is best if your comments are focused on these areas.

In order to be effective, it is EXTREMELY IMPORTANT to try to focus on “technical” objections to the DEIS.

CBWC has prepared the following “laundry list” of technical objections to the DEIS to assist citizens in making effective comments on the DEIS. This list is not exhaustive or inclusive of every objection. We welcome any suggestions or additions to this list. ALWAYS INCLUDE THE STATEMENT THAT YOU SUPPORT THE “NO ACTION ALTERNATIVE

The list below are example arguments to make against the DEIS. IF you are submitting your comments in writing, please do not just copy these. Write your comments in your own words and in your own order. Add other concerns and issues you may be aware of specific to your property. At the end, state your name and location of property that might be affected by the TTC.

Natural Resources
1. The current DEIS does not contain any mitigation for loss of agricultural land or evaluation of such impact. Agricultural land is a natural resource that is not easily
replaceable. Because of the resource requirements necessary to create viable agricultural farms and ranches (fertile soil, location, climate, acreage),agricultural land that is destroyed by the TTC-69 will not be replaced. As a natural resource, this must be taken into account and lost agricultural land must be mitigated (i.e. replaced) by TXDOT.

Agriculture is the state's second largest industry and employs about one out of every
seven working Texans. Every agricultural producer feeds 129 people in this country.
Loss of agricultural land at a time when the state of Texas and the U.S.A is experiencing enormous population growth should be taken into consideration. The DEIS does not do this.


2. Threatened and endangered species are known to be in area and are not reflected in DEIS documentation, and habitats suitable for the existence and recovery of these species are prevalent in the area and must be protected.

Federal Endangered Species in the Waller County Area
Houston Toad (amphibian)
Attwater’s Greater Prairie Chicken (bird)
Interior Least Tern (bird)
Red Cockaded Woodpecker (bird)
Whooping Crane (bird)
Red Wolf (mammal)
State Endangered/Threatened Species in the Waller County Area
American Peregrine Falcon (bird)
Artic Peregrine Falcon (bird)
Bald Eagle (bird)
Peregrine Falcon (bird)
White-faced Ibis (bird)
White-tailed Hawk (bird)
Wood Stork (bird)
Blue Sucker (fish)
Creek chubsucker (fish)
Louisiana Black Bear (mammal)
Alligator Snapping Turtle (reptile)
Rare Species
Henslow’s Sparros (bird)
Sharpnose Shiner (fish)
Plain Spotted Skunk (mammal)
Southeastern Myotis Bat (mammal)
False Spike Mussel (mollusks)
Pistolgrip (mollusks)
Rock Pocketbook (mollusks)
Texas Fawnfoot (mollusks)
For an current list of rare, threatened, and endangered species in Texas by county, visit the Texas Parks & Wildlife website by clicking HERE.

This list does not include endangered plant species. For a list of endangered and
threatened plants in Texas, click HERE.

If you have any of these animals or plants present on your land, or you know of their
existence in the area, it is important to note these facts, and if you can, document it and provide such documentation to TXDOT in writing if possible.

3. The current DEIS provides no assessment of impact for the loss of land currently under state approved wildlife management land programs.

4. The current DEIS makes no mention of the unique threats to the areas such as the
Blackland’s Prairie, which Texas Parks and Wildlife calls “the most degraded of Texas’s 10 ecological regions”.

5. Waller County is already in a non-attainment area, Zone 5, for air quality (in other words, Waller County is already in an area that has been classified by the EPA as having a serious air quality/pollution problem). The current DEIS does not take into consideration how the increase in truck and auto traffic will affect Waller County’s classification. The increase in traffic along with higher speed limits will increase carbon emissions in the area.

6. The current DEIS does not take into consideration the impact of the TTC on water quality and flooding issues in the Waller County area. There are areas in the northeast quadrant of the area that are in the 100 year flood plain and would require additional drainage/ flood control attention. The current DEIS does not take this into consideration.

Also, the current watershed from this area flows into Harris County. Harris County has a "no net increase" rule in relation to discharge to its streams and water sheds. The
hydrology of the TTC in Waller County will totally disrupt the current hydrology in such a massive scale that it will exhaust what few capital resources the county has. The DEIS does not address who will be responsible for correcting the hydrology or sheet flow across the county in the form of distention or retention along either side of the path of the TTC, and how much additional land may be required for this purpose.

7. There is no consideration in the DEIS of incremental environmental effects (more fuel use, more greenhouse gas, loss of land for agriculture, loss of trees, energy and materials to build etc.) of a longer “loop” path around Houston vs. going straight through Houston and not building a loop

a. Proposed loop must be evaluated against using existing Houston corridors
b. Proposed loop must be evaluated against improved Houston infrastructure, such
as adding additional lanes to Sam Houston Parkway or Grand Parkway
c. Houston roads are only congested approximately 5 hours per day on business days
(i.e., roads are relatively uncongested about 85% of the time)
d. The DEIS does not take into consideration what the effect of higher speed limits
on the TTC-69 will have on greenhouse gases, carbon emissions, pollution, etc.
8. There is no consideration in the DEIS of the environmental impact of truck-hauled
cargo/containers as opposed to use of existing rail lines instead of new-build roadway.

9. The current DEIS does not give any consideration to the detrimental effects from noise and light pollution on areas that are currently pristine and unaffected by such issues.

Social & Economic

10. The population density figures used in the current DEIS are outdated and incorrect. The DEIS uses figures from the 1990 census. These figures are not accurate and as a result, the impact of the TTC-69 from a social and economic standpoint are grossly underestimated.

11. The current DEIS does not take into account unique land usage issues, such as the
residential airpark in Brookshire, Sport Flyers, the Waller County Country Club has both a golf course and a residential airpark, the Soaring Club of Houston (an educational facility that is also home to an auxiliary Civil Air Patrol unit), Cimmaron Ranch, a private airstrip, the Fish Farm, and many others such as Camp Allen in southern Grimes County. Using the mitigation angle, these locations would be unable to "rebuild" in other locations in the county due to unique geographical considerations. The DEIS shows only Intercontinental and Hobby in their discussions of airports.

12. Security. The current DEIS does not take into consideration the impact the TTC will have on state and national security. Currently, the Drug Enforcement Agency estimates that more than 9,300 commercial trucks, carrying everything from piñatas to electronics, pass through Nuevo Laredo into Laredo each day, according to U.S. Customs and Border Protection officials. As cargo shifts from Los Angeles to Mexico, it is expected to triple the amount of traffic moving from Mexico through the Texas Highway system. TJ Bonner, president of the National Border Patrol Council testified before Congress that less than 5 percent of the 6 million cargo containers entering the US each year are physically inspected by the US Customs and Border Protection agents. Additionally, US Representative McCaul’s report “A Line in the Sand”
http://www.house.gov/mccaul/pdf/Investigaions-Border-Report.pdf concluded, during
2005, of the 1.2 million illegal aliens apprehended by Border Patrol, 650,000 of those
were not from Mexico, and 650 individuals were from “special interest countries.”
“Special interest countries” are countries designated by our US Intelligence as countries that could export terrorists to the US to do harm. And, Federal law enforcement estimates that only 10-30% of aliens are actually apprehended, and only 10-20% of illegal drugs are seized. It seems that the economic growth supposed by the TTC system outweighs the danger to our national security and increases in drug and human smuggling.

13. The current DEIS does not give any consideration for loss of economic value for land currently valued by natural resource considerations only (tranquility, beauty, etc.) rather than agricultural value.

14. Residences, businesses, ranches, and farms within this study could suffer a loss in value attributed to what is known as economic and/or external obsolescence as a result of the TTC-69/DEIS process. Economic or external obsolescence is “an element of accrued depreciation; a defect, usually incurable, cause by negative influences outside a site”. Property located in and around these proposed or recommended paths will likely be impacted the greatest. Due to the design of the TTC-69 (size, lack of access, and lack of feeder roads), adjacent property is unlikely to benefit from the “commercial value” aspects of a typical highway and/or interstate. As a result, property values in the studyareas will suffer losses. This will also contribute to a decline in taxable revenue, which will impact school districts and county governments. The current DEIS does not contain any evaluation on how a project of this size, scope, and design (the nature of which has never been done before) will have on property values in the areas affected by it.


15. The heritage of Native American mounds known to exist in the area must be protected. The current DEIS does not take into account the locations of any sites that have Native American significance such as burial sites, mounds, etc.

16. The current DEIS does not take into consideration areas in Waller County that have
significant historical or cultural significance, such as historical sites, cemeteries
(especially unmarked family cemeteries), buildings that may qualify as historical sites, etc. If you have these types of items on your property, you must bring them to the attention of TXDOT.


17. The current DEIS does not contain any consideration or evaluation of what impact the TTC-69 will have on local transportation and mobility in this area. As currently
designed, the TTC-69 could seriously inhibit mobility between the east and west sides of Waller County, especially without few crossovers. The DEIS does not contain any
specific requirements as to which crossroads will get crossovers. Most of Waller County mobility occurs on farm to market roads. If these roads are not given access and crossover ability, Waller County mobility will be seriously damaged and the impact on Waller County from an economic and social perspective would also be significant. The current DEIS does not take this into consideration.

18. Researchers Peter Swan and Michael Belzer of Penn State & Wayne State University
presented statistics documenting the negative side effects toll roads have on secondary road networks to the Transportation Research Board in January. They have concluded that ...”when toll rates are set to maximize profit where congestion is not a significant problem (i.e. Waller County), they can introduce substantial inefficiencies in the overall road transportation network and actually increase congestion and safety hazards in other parts of the system that they do not own and control.” In other words, trucks will resort to local roads to avoid the tolls, thereby increasing the risk of accidents on local, rural roads. The current DEIS does not address increased safety hazards on local, rural roads.

19. The current DEIS does not contain any evaluation of the impact the TTC-69 will have on local government services, such as Emergency Medical Services, Fire Department
services, school districts, and emergency response times. If constructed with connections at 290 and I-10, the TTC-69 will impose an immense financial burden on county and city governments, and local school districts split by the project, as these entities will be forced to build new facilities and purchase new vehicles to provide services on both sides of the project. At the same time, the project will remove approximately 5,000 acres from the tax rolls of the county. The project does not address how local services and emergency response times will be maintained with less tax revenue.

20. For the purposes of justifying the need for a new “loop” around Houston, such a study must include:
a. Projections of traffic by year along each stretch of roadway
b. Breakdown by truck vs. automobile traffic
c. At both nodes where IH-69 splits from Houston directed corridor (i.e., Wharton
and Lufkin), percentage breakdown along each path
d. Quantification of environmental emissions for new “loop” road
The current DEIS not include such studies.


© 2008, Citizens for a Better Waller County: www.wallercountycitizens.org

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