Houston-Galveston Area Council
Posted:
Public comment period for the Draft amendments to the 2045 Regional Transportation Plan and the 2021 Transportation Conformity document closed on April 28, 2021 at 5:30 PM.
Total Number of Comments Submitted: 107
| Name | Organization | Submission Method | Date Submitted | View Comment/Response |
|---|---|---|---|---|
Michael Huffmaster |
N/A |
Email (Late Submission) |
04/29/2021 |
|
Ramona Neal |
Highway 36 A Coalition |
Email (Late Submission) |
04/29/2021 |
|
Antonia Dacus |
N/A |
Email (Late Submission) |
04/29/2021 |
|
Tony Frank |
National Audubon Society (Texas affilitation) |
Online |
04/28/2021 |
|
Jackie Hicks |
Gulf Coast Bird Observatory |
Online |
04/28/2021 |
|
Lynne Aldrich |
Gulf Coast Bird Observatory |
Online |
04/28/2021 |
|
Gary Clark |
Gulf Coast Bird Observatory |
Online |
04/28/2021 |
|
William Dickson |
Katy Prairie Conservancy / Gulf Coast Bird Observa |
Online |
04/28/2021 |
|
Peter Gottschling |
GCBO supporter |
Online |
04/28/2021 |
|
Jay Farris |
self |
Online |
04/28/2021 |
|
Niell Gorman |
University of Houston |
Online |
04/28/2021 |
|
Greg Whittaker |
Concerned Coastal Citizen |
Online |
04/28/2021 |
|
Mariel Sanchez |
Houston resident |
Online |
04/28/2021 |
|
Laura Robles Cisneros |
Self |
Online |
04/28/2021 |
|
JAMES WINN |
INDIVIDUAL and Supporter of the Katy Prairie Conse |
Online |
04/28/2021 |
|
Martin Hagne |
Gulf Coast Bird Observatory |
Online |
04/28/2021 |
|
Joseph Higgs |
Self |
Online |
04/28/2021 |
|
Abhinav Kumar |
Houston, Texas |
Online |
04/28/2021 |
|
Neal Ehardt |
Ehardt Industries |
Online |
04/28/2021 |
|
Timothy White |
Texas Citizen |
Online |
04/28/2021 |
|
Erin Eriksen |
Stop TxDOT I-45 |
Online |
04/28/2021 |
|
Scott Moorhead |
Audubon Texas |
Online |
04/28/2021 |
|
Oni Blair |
LINK Houston |
Online |
04/28/2021 |
|
Lauren A |
Self employed |
Online |
04/28/2021 |
|
Renae DeLucia |
n/a |
Online |
04/28/2021 |
|
Itay Porat |
Houston resident |
Online |
04/28/2021 |
|
Felipe Sanchez |
Self |
Online |
04/28/2021 |
|
Stephen Gast |
Katy Prairie Conservancy, Texas Audubon Society, H |
Online |
04/28/2021 |
|
Bridget Lois Jensen |
N/A |
Online |
04/28/2021 |
|
Myles Castellanos |
Self |
Online |
04/28/2021 |
|
Fabián Ramirez |
Meshed Consulting LLC |
Online |
04/28/2021 |
|
Joyce Tajonera |
Houston Resident |
Online |
04/28/2021 |
|
Samuel Russek |
none |
Online |
04/28/2021 |
|
Kathleen Christman |
self |
Online |
04/28/2021 |
|
Ben Stickney |
Self |
Online |
04/28/2021 |
|
Trent Epperson |
City of Pearland |
Online |
04/28/2021 |
|
Marlisa Briggs |
North Houston Association |
Online |
04/28/2021 |
|
Kristina Ronneberg |
Self |
Online |
04/28/2021 |
|
Garrett Line |
NA |
Online |
04/28/2021 |
|
Mario Castro |
Houston Citizen |
Online |
04/28/2021 |
|
Michael Moritz |
self |
Online |
04/28/2021 |
|
Benjamin Peters |
Individual |
Online |
04/28/2021 |
|
Juliet Childers |
Citizen |
Online |
04/28/2021 |
|
Katherine Webber |
None/Citizen of Houston |
Online |
04/28/2021 |
|
Chloe Allen |
Stop Tx Dot |
Online |
04/28/2021 |
|
Sabrina Perez |
Stop TXDOT |
Online |
04/28/2021 |
|
Charles Thompson |
myself |
Online |
04/28/2021 |
|
Simone Kern |
Houston resident |
Online |
04/28/2021 |
|
Susan Graham |
Stop TxDOT I-45 |
Online |
04/28/2021 |
|
Texas Jackson |
Former Mayor City of Prairie View, Texas |
Online |
04/28/2021 |
|
Jennie Rohrer |
Self |
Online |
04/28/2021 |
|
Jeanette Rash |
Zone One Auto/Fast Tow/Tow and Go Operations Manag |
Online |
04/28/2021 |
|
William Wilson |
self |
Online |
04/28/2021 |
|
Bess Wilhelms |
SELF |
Online |
04/28/2021 |
|
May Nguyen |
none |
Online |
04/28/2021 |
|
Chloe Cook |
self |
Online |
04/28/2021 |
|
Molly Cook |
self |
Online |
04/28/2021 |
|
Clair Hopper |
Citizen |
Online |
04/28/2021 |
|
Martha Beaudry |
Resident of Northside |
Online |
04/28/2021 |
|
Desiree Alejandro |
Individual |
Online |
04/28/2021 |
|
Texas Lynn |
Resident |
Online |
04/28/2021 |
|
TX Crocken |
Concerned Citizen |
Online |
04/28/2021 |
|
Harrison Humphries |
Air Alliance Houston |
04/28/2021 |
||
Jonathan P. Brooks |
LINK Houston |
04/28/2021 |
||
Mary Anne Piacentini |
Katy Prairie Conservancy |
Online |
04/27/2021 |
|
David Hagy |
American Council of Engineering Companies (ACEC) H |
Online |
04/27/2021 |
|
Tom Lambert |
METRO |
04/27/2021 |
||
Corbett L. Freeman |
N/A |
04/27/2021 |
||
Vivian Tan |
Resident of Cottage Grove |
Online |
04/26/2021 |
|
Drew Wiley |
Cottage Grove Civic Association |
Online |
04/26/2021 |
|
A.P. Thomas |
citizen |
Online |
04/24/2021 |
|
Feng Feng |
N/A |
Online |
04/23/2021 |
|
Katie Niemann |
Cottage Grove Civic Association |
Online |
04/21/2021 |
|
Robert Burke |
Cottage Grove Civic Association |
Online |
04/21/2021 |
|
Robert Pechukas |
Highway 36A Coalition |
04/21/2021 |
||
Henry Smith |
Resident in Cottage Grove |
Online |
04/20/2021 |
|
Rebecca Esser-Stuart |
Citizen |
Online |
04/20/2021 |
|
Ashley Chabaud |
N/A - Cottage Grove resident |
Online |
04/20/2021 |
|
Ryan Smith |
Self |
Online |
04/20/2021 |
|
Angela Kao |
Self |
Online |
04/20/2021 |
|
Claire Wrigley |
None |
Online |
04/20/2021 |
|
Clare Wrigley |
None |
04/20/2021 |
||
Alan Steinberg |
West Houston Association |
Online |
04/19/2021 |
|
Gary Basinger |
The Economic Development Alliance for Brazoria Cou |
04/19/2021 |
||
Veronica Davis and David Fields |
City of Houston |
04/16/2021 |
||
Andrew Bohac |
City of Needville |
Online |
04/15/2021 |
|
Glenn Venables |
N/A |
04/15/2021 |
||
Glenn Venables |
N/A |
04/15/2021 |
||
Glenn Venables |
N/A |
04/15/2021 |
||
Alexsovan Hory |
High School Student |
Online |
04/10/2021 |
|
Marc Anderson |
none |
Online |
04/10/2021 |
|
Elizabeth Jensen |
Referee PAC |
Online |
04/10/2021 |
|
Neal Ehardt |
N/A |
04/09/2021 |
||
Vernon Hegwood |
Costello, Inc. |
Online |
04/08/2021 |
|
Michael Huffmaster |
Blue Print Houston / Katy Prairie Conservancy |
Online |
04/08/2021 |
|
Jeffrey Wiley |
Greater Fort Bend Economic Development Council |
Online |
04/08/2021 |
|
Thomas Kirn |
Self |
Online |
04/08/2021 |
|
Tecky Surawijaya |
Harris County Resident |
Online |
04/07/2021 |
|
Judi Becker |
Myself |
Online |
04/07/2021 |
|
Oscar S |
Motorist |
Online |
04/05/2021 |
|
Nick Garner |
N/A |
04/04/2021 |
||
Heather Betancourth |
N/A |
04/04/2021 |
||
Stephen Livingston |
ExxonMobil |
Online |
03/30/2021 |
|
Jacob Powell |
Baytown City Council |
Online |
03/29/2021 |
|
Robin Yates |
Citizen |
Online |
03/28/2021 |
|
Fred Foreman |
N/A |
Email (First Round) |
01/07/2021 |
|
Tom Schmal |
N/A |
Email (First Round) |
01/07/2021 |
You need to step back, and look at the successful cities worldwide, and model them. If you look and listen, you will learn that your focus is off. You have one paragraph and only feigned attention given to what you call ‘Active Transportation.’ Until we invest heavily in and emphasize walking, biking, rolling as main means of transportation, we will continue this cascade of funding the self destruction of our species and planet. It is not safe to bicycle or ride a motorcycle in or around the Houston area. That needs to change. Thus plan only gives lip service to this need. Start over, folks.
Thank you for your input. The 2045 RTP is made up of numerous plans including the Regional Active Transportation Plan, Regional Safety plan, Regional Coordinated Transportation Plan, Congestion Mitigation Air Quality Plan, to list a few. All these plans can be found in the appendix of the document. The direct link to the active transportation plan is (http://2045rtp.com/documents/plan/Appendix-H-Regional-Active-Transportation-Plan.pdf).
I am happy to see the proposed addition of the I-10 San Jacinto River Bridge. It has been struck by a barge multiple times in recent years. Each of these instances has caused months of extended commutes for residents that live on the east side of the river. I strongly encourage H-GAC to make this bridge replacement a high priority. Thank you.
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: TxDOT agrees that this bridge needs to be replaced. TxDOT is in the early phase of project development. TxDOT will work with the community and stakeholders including both the land and water side to identify design improvements that enhance mobility and improve safety for people and goods.
I am one of thousand of Harris County residents that commute I-10 on the East side of town every day. The fact that one of the largest and busiest interstates in the nation has been ground to a halt on multiple occasions in the past few years because of an extremely inadequate bridge at the I-10 San Jacinto River crossing. This bridge should be replaced with an elevated bridge that has structural supports outside of the barge traffic lanes to prevent strikes, and the bridge should be expanded to resolve the DAILY bottleneck that occurs with SPUR-330. Cars sitting bumper to bumper instead of moving smoothly are an enormous problem in Harris County, and this is one of the worst locations on a daily basis.
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: TxDOT agrees that this bridge needs to be replaced. TxDOT is in the early phase of project development. TxDOT will work with the community and stakeholders including both the land and water side to identify design improvements that enhance mobility and improve safety for people and goods.
I support all the proposed highway additions to the 2045 mobility plan. The West Loop express lanes project is the most urgently needed among the new additions. Year after year, the West Loop ranks as the first or second most congested segment of freeway in Texas.
In terms of the overall 2045 project listing, I'm concerned about a highway segment which experiences heavy congestion but is not slated for any improvements: The North Loop 610 between US 290 and Interstate 45 north. There is congestion on this segment throughout the day and I have recently been in congestion going eastbound on a Sunday afternoon. When a highway is congested throughout the day and on weekends, it means there is inadequate capacity. This segment is the sixth most congested freeway in Texas, according to TTI. The antiquated interchange at IH-45 is a major contributor to the eastbound backups. This interchange is slated for improvement with the NNHIP, but with the future of the NNHIP uncertain, this section of the North Loop needs to be studied separately for improvements. Most likely the addition of one additional lane in each direction is the most suitable improvement, and that could probably be done with minimal or no new right of way.
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: Thank you for your input.
Hello, I recently moved to 17116 Harper's Trace in Conroe and the traffic on 242 and Harper's Trace is terrible. It took me 30 minutes to go the mile from Harper's Trace to I-45. There are several new subdivisions in this area along with schools, HEB and various other businesses that have opened. The two lanes going east and west cannot handle the flow of traffic especially with the construction going on further east that has many big rigs adding to the traffic.
One thing that could be done in the meantime is to have the traffic lights going longer as they are close together only allowing 1-2 cars to be able to enter onto 242.
Thank you for listening.
Thank you for your input. Please see the response from TxDOT below.
TxDOT response: Thank you for your input. TxDOT is current developing schematic engineering and performing environmental clearance for SH 242 from I-45 to FM 1488. A virtual public meeting for this project is anticipated in fall 2021. In the meantime, we will have our Traffic Operations Section look into the signal timing along SH 242 to ease congestion.
MPOID 18722: SH6 corridor improvement between Clay and I10W needs to consider adding protected bike lane and sidewalk to connect Bear Creek, George Bush, and Terry Hershey parks.
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: Per FHWA and TxDOT guidance, all proposed projects are evaluated for sidewalk/bicycle accommodations.
In general, I support the expansion of FM 2920 (#18510) from 4 lanes to 6 lanes. However, I believe that the continuous left turn lane that is currently present, needs to changed. There should be medians and curb openings when needed. At present, there are no mechanisms to stop cross traffic from potentially causing an accident. A traffic signal at Foster Road and FM 2920 would also improve safety and allow for safer turning movements.
Thank you for your input. Please see the response from TxDOT below.
TxDOT response: TxDOT currently has a funded safety and access management project that will include raised medians on FM 2920. A virtual public meeting for the safety improvements, including the raised median, was held online beginning April 27, 2021. You can find more information, here: https://www.txdot.gov/inside-txdot/get-involved/about/hearings-meetings/houston/042721.html.
A public meeting for the FM 2920 widening project will be held in the Fall of 2021.
Thank you very much for the opportunity to comment. As the President and CEO of the Greater Fort Bend Economic Development Council, the 2045 Regional Transportation Plan is hugely important to the future planning of regional mobility, congestion mitigation, quality of life, safety and efficient movement of goods. We appreciate the effort.
Two projects we do not see on the list of projects in the 2045 RTP, which we believe should be included, relate to the continuation of an efficient and expanded transportation and freight route from Port Freeport to US 290. They involve a route from the Rosenberg\Needville\I69 area in Fort Bend County to Interstate 10 in Waller County (36A Southern Route) and a continuing piece from Interstate 10 to US 290 (36A Norther Route) in Waller County.
These routes are necessary for enhanced evacuation capacity given State Highway 36 is a primary evacuation route for Southern Brazoria County and for efficient freight movement as a means of current and future need identified by HGAC in their freight mobility efforts to route traffic outside the metropolitan core.
TXDOT is currently underway with a 2 to 4 lane expansion from Port Freeport to Rosenberg. This route needs to continue in an efficient path to Interstate 10 and to US 290 to provide maximum benefit of evacuation safety and efficient freight mobility movement.
HGAC knows well that planning is the key to ensuring the most effective routes at the most reasonable costs to achieve their goals. Doing so before development occurs expands options and reduces cost. For this reason, we have particular concern that the Southern Route be incorporated this year at minimum. The pace of development in Fort Bend County poses great risk to the future location of such a route and threatens to increase cost, should they not be undertaken now. 36a Southern Route provides the key connection from Port Freeport and Brazoria County to Interstate 10 and provides enhanced evacuation, safety, freight mobility and commerce throughout the region.
We highly encourage the inclusion of both 36A Southern Route and 36A Northern Route into the plan with particular emphasis on the Southern Route to extend mobility effort along State Highway 36 already underway from Port Freeport to Interstate 10.
With the groundbreaking today of Port Freeport Harbor Channel Improvement Project, ensuring that Port Freeport will be the deepest Port on the Gulf Coast and throughout the region, we need to have foresight to ensure transportation mobility is there as the Port grows among other benefits delivered by the two projects.
Thank you for the opportunity to comment.
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process.
Please provide assessment criteria for route alternatives consideration (pertains to 35 and 36A), or perhaps a TxDOT link
Thank you for your comment. Please see response from TxDOT below.
TxDOT response: While the specific evaluation criteria have not yet been established for the 36A study, these are the general steps and considerations in a feasibility study:
* Assess the need for the project
* Conduct feasibility analysis of the alternatives
* Analyze the impact of the project on the:
- transportation system - changes in travel time, safety, and vehicle operating cost
- social and economic effects - impacts to the community including the human environment, civil rights, and environmental justice, economic impacts/development, etc.
- natural systems - inlcluding air/water quality, endangered species, wildlife, greenhouse gasses, archeological, energy, and cultural and historically significant locations and structures.
While much more goes into the process, our ultimate goal of the study is to describe the potential outcomes of a given alternative so that our regional leadership can make an informed investment decision for the benefit of the region to move people and goods.
Thank you very much for the opportunity to comment. As a Harris County citizen, the 2045 Regional Transportation Plan is hugely important to the future planning of regional mobility, congestion mitigation, quality of life, safety and efficient movement of goods. We appreciate the effort.
I fully support the amendment to add 36A to the list of projects in the 2045 RTP. This route will provide an efficient and expanded transportation and freight route from Port Freeport to US 290. It involves a route from the Rosenberg\Needville\I69 area in Fort Bend County to Interstate 10 (36A Southern Route) and a continuing piece from Interstate 10 to US 290 (36A Northern Route) in Waller County.
These routes are necessary for enhanced evacuation capacity given State Highway 36 is a primary evacuation route for Southern Brazoria County and for efficient freight movement as a means of current and future need identified by HGAC in their freight mobility efforts to route traffic outside the metropolitan core. Again, as a Harris County resident, providing a route that bypasses Houston would greatly improve local mobility as well.
I highly encourage the inclusion of both 36A Southern Route and 36A Northern Route into the plan with particular emphasis on the Southern Route to extend mobility effort along State Highway 36 already underway from Port Freeport to Interstate 10.
With the groundbreaking of Port Freeport Harbor Channel Improvement Project, ensuring that Port Freeport will be the deepest Port on the Gulf Coast and throughout the region, we need to have foresight to ensure transportation mobility is there as the Port grows among other benefits delivered by the two projects.
Thank you for the opportunity to comment.
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
When learning about each project being funded for widening a road or constructing a new one, I've not been able to find information on its expected capacity. What I'm looking for is a measure of expected capacity/cost, say at 5 and 10 years following project completion. Also, given this area's high fatality rate on the roads, I've been looking for projects that are focused on that particular issue (none are labeled as such).
Thank you for your input. The 2045 RTP is made up of numerous plans including the Regional Active Transportation Plan, Regional Safety plan, Regional Coordinated Transportation Plan, Congestion Mitigation Air Quality Plan, to list a few. All these plans can be found in the appendix of the document. The direct link to the active transportation plan is (http://2045rtp.com/documents/plan/Appendix-H-Regional-Active-Transportation-Plan.pdf). We will take you comments into our consideration for the 2030 RTP development process.
For all road and transportation improvements, please use low glare lighting fixtures that are full cutoff that properly aim the light down and out of the eyes of drivers, pedestrians, and from going into the windows of homes/businesses. This will greatly help safety and allow lower wattage bulbs that will conserve energy. Use smart lighting that can automatically dim based on time of day or motion and conserve even more energy. Also please use low temperature lighting (2700-3000K) to avoid the adverse affects on the environment and people's melatonin levels while still maintaining a high CRI value for safety.
Thank you for your input. Please see the response from TxDOT below.
TxDOT response: TxDOT's is continuously evaluating new tools, technologies, and techniques to improve safety. Thank you for your comment.
2045. When we reach 2045, how do we want to picture ourselves moving around the Houston area? Our current strategy of actively accommodating only the car is simply unsustainable. We need to stop this car-dependent urban sprawl. Hurricane Harvey's impacts were worsened because we live in a concrete jungle. As a teenager, who only recently received his driver's license, I found it so difficult, dangerous, and inconvenient to go anywhere without a car. I'm sure parents want to see their kids become independent adults, but how can I and other kids become independent adults when we have to depend on our parents to take us everywhere because we can't drive. It is not only kids; senior citizens like grandparents are too scared to drive so they depend on their adult children to take them everywhere; the disabled are also neglected. For instance, how do you expect someone who is tied to a wheelchair or someone else who is impaired drive? By properly and actually putting plans into reality, we can embrace multi-modal transportation so everyone has the freedom of mobility. Everyone talks about the freedom the car brings but not many people talk about the freedom of NOT having to use a car. Even though I consider myself a car enthusiast, being interested in cars ever since I was five, I would much rather have the choice and the peace of mind of being able to walk, bike, use public transport, or other modes of transportation. What many don't know or seem to understand, when you provide alternate modes of transportation, you alleviate pressure on others. People who would rather use public transport or walk can do, and by doing that, traffic that must use the roadways such as commercial trucks have the room to do so. Economically, regions that are not car dependent have much more comprehensive and thriving economies. Look at New York, Tokyo, and London. They are all global cities, and what do they have all in common? Multi-modal transportation systems. They are walkable, bikeable, and public transport friendly. The backbone of the economy are small businesses. What small businesses need the most is foot traffic, but that is quite hard to attract when people are stuck in their car whizzing by to head to the nearest McDonald's. The car-dependent Houston area is heaven for these huge corporations since no matter where you go, there will be fast food. There will be these big box stores. When people think about food, they think about fast food here. I would love it if people thought about their local bakeries instead. Speaking of local, multi-modal transport is great socially. It encourages social interaction. As a teen without access to a car since I can't drive, I was stuck home in our car dependent suburbia. Every time I simply wanted to go to my friend's house who only lived five to ten minutes away by car, I've always felt stressed and worried for my safety since drivers are ruthless and our infrastructure and the way we design the places we live are all centered around the car. There is a reason why parents always drive their kids to school or other places because it really is dangerous to go anywhere without a car. With mental health being more important than ever, I felt frustrated and sad that I simply wanted to hang out with my friends to go eat, to go shopping, to be kids and have fun but since I had no car and can't drive anyway, I'm stuck at home. Also, we are experiencing an obesity epidemic. An environment where we can so easily go from our suburban home straight into our car, and pick up and eat fast food without ever getting out says a lot. People live busy lives and lots of time is spent commuting and being stuck in traffic staying in one place. There is little physical activity. No wonder why people have little time to exercise. When people of thinking of walking and biking, they usually think of it as recreational. Why not make it from point A to point B? Let people go from home to school, work outside of a car. I have a DREAM that one day I will be able to ride my bike together with my friends as our way of getting to and from school just like Dutch kids. Environmentally, we all know that climate change is real. We know that cars are contributing to this climate crisis. We all know the causes, effects and danger of air pollution, so why aren't we actively embracing the solutions? So what are the solutions? From the bottom up, this is what we need to do. We need to design our housing developments to be walkable, bikeable, and public transport friendly from the start. Currently, we are mass producing homes to accommodate for our population growth, but all of these new communities are completely car dependent suburbs; it will be hard to retrofit these communities into the multimodal dream that we dream of. We are currently mass producing car-dependent suburbs, so that means we can mass produce these homes the right way. Next, it is well known that highways wrecked American cities. Cutting through communities of color and creating blight. With the car and highways, people who could afford to leave the inner city and out into suburbs did. The people who did were typically white and this is where white flight came from. This left the poorer communities of color who were already disadvantaged to become even more disadvantaged. With new schools being built out in the suburbs, they were able to be financially supported through the influx of tax dollars and support of these new homes. With schools out in the suburbs where school quality is better, and education is power, no wonder why even in the 21st century that the inner cities tend to be communities of color and that the schools tend to be bad. Houston may be considered "diverse" but it is extremely racially segregated with the west being well off such as River Oaks and Memorial while the east such as the Third Ward and areas immediately east of Downtown tend to be the most deprived areas of the city. With no or the lack of or the dismal quality of schools, combined with less access to a car, the people in these areas are stuck in a toxic cycle with a difficult way out. My ideal plan is to create a transportation megahub of a city. Everywhere is walkable, cyclable, and have a huge bus network, tram network, mass rapid transit network, suburban rail network, regional rail network, intercity rail network, and finally a high speed rail network. Create a comprehensive, complex system where this is literally everywhere, connecting our region like never before. I feel we should complete the Grand Parkway loop and that is it when it comes to highway expansion. There is a phenomenon known for a LONG time called induced demand. The infamous Katy Freeway is the prime example of this. Taxpayers paid $3 billion dollars for even worse traffic. The Katy Freeway is now 26 lanes across at its widest point and still has gridlock traffic even having traffic worse before the reconstruction. Commuting times increased. Coupled with extremely heavy housing developments in the Katy area, the short term benefits of the expansion drastically shortened and we're back to square one. It is proven time and time again that we can not build our way out of traffic, so why are we still doing it? For instance, Interstate 45. It is proposed by TxDOT to expand I-45 North to even wider than it is now, but it seems like TxDOT did not learn their lessons that highway expansion does not solve anything, so why are we still pouring tons of taxpayer money into these unsustainable projects? TxDOT should not be so eager to go on a spending spree of highway construction because the T in transportation does not mean just cars. It means all modes of transportation including mass transit. Therefore, TxDOT should just shift all that money and into actually investing in solutions that actually work than those that don't. I propose that as the urban core of Houston, all of the highways inside I-610 should be removed. Many cities all around the world have experienced with freeway removal. And guess what? It actually caused traffic to be better while better connecting the communities within, drastically lowering air and noise pollution levels while beautifying the area. Look at San Francisco, with the earthquake in the 80s, the Embarcadero Freeway was removed since it was destroyed beyond repair; now the area is a vibrant, liveable place where people come spend quality time. Seoul's Cheonggyecheon was a freeway, now it is a exciting, livelty place like a park and has become one of the city's most famous places. As I wrap things up, to learn more and see these examples in action, check out BicycleDutch, Not Just Bikes, and Streetfilms on YouTube; these are channels that show all the great infrastructure that can be possible. Specifcally the first two focus on infrastructure in the Netherlands. My dream is to have infrastructure that rivals and best the ones found in the Netherlands such as biking infrastructure and Japan and its trains. I have a lot more that I want to say, but I will wrap it up here!
Thank you for your interest in the 2045 RTP. H-GAC appreciates you taking the time to express your concerns. These comments will be considered for the 2050 RTP.
To the sponsor for each of the following projects: Does your project include sidewalks and protected bike lanes?
1. Hempstead Rd -- MPOIDs 18701, 18702, 18703, 18704, 18705, 18706
2. IH 10 E -- MPOID 18707
3. IH 10 W -- MPOIDs 18708, 18709
4. IH 610 E -- MPOID 18710
5. IH 610 S -- MPOIDs 18711, 18712
6. IH 610 W -- MPOID 18730
7. SH 288 -- MPOIDs 18713, 18714, 18715, 18716
8. SH 35 -- MPOIDs 309, 310, 18717, 18718, 18728
9. 36A South -- MPOID 18719
10. 36A North -- MPOID 18720
11. SH 6 -- MPOID 18721
12. SH 99 -- MPOIDs 18723, 18724, 18725, 18726
13. SL 8 -- MPOID 18727
14. IH 45 -- MPOID 16328
To H-GAC staff: What metrics did you use to select these projects for amendment? Are you prioritizing some projects that are unsafe by design for people walking and biking?
Thank you for your comment.
These amendments were not selected through a project selection process. They are being considered for inclusion in the long-range plan at the request of the sponsor (TxDOT) for the determination of regional air quality conformity. H-GAC uses Call for Projects process on a regular basis tentatively once every three years to select the projects for programming in the Transportation Improvement Program (TIP), the 10-Year Plan, and inclusion in the Regional Transportation Plan (RTP). Last Call for Projects Process was conducted in conjunction with the development of 2045RTP. All projects submitted through the 2018 Call for Projects (2018 CFP) were evaluated based on 50% score (100 points) given to its benefit/cost ratio and 50% score (100 points) given to various planning factors. The benefit-cost analyses were focused on reduction of crashes, delay and emissions. Please refer to 2045 RTP Appendix P for more details about "Call for projects evaluation criteria". Thank you again for your participation and comment.
Please see the response from TxDOT below.
TxDOT response: Per FHWA and TxDOT guidance, all improvement projects must consider bicycle and pedestrian accommodations. Sidewalks and bike lanes are not applicable for highway mainlane widening of a controlled access facility.
Hello,
I am writing to let you know that is absolutely imperative to include the I-10 Bridge project in the 2045 Regional Transportation Plan.
As you most certainly know, this bridge is artery that connects thousands of people from home to work and vice versa, and when it is closed indefinately it becomes a massive issue. It is NOT just a simple inconvenience. THOUSANDS of people added at least an hour per day to their commute because to the detours and additional traffic that other roads incurred.
This HAS to be number 1 on the 2045 Plan!
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: San Jacinto Bridge
TxDOT agrees that this bridge needs to be replaced. TxDOT is in the early phase of project development. TxDOT will work with the community and stakeholders including both the land and water side to identify design improvements that enhance mobility and improve safety for people and goods.
On the Regional Transportation Plan and Conformity Updates Public Meetings:
I am writing in support of project included in the 2045 Regional Transportation Plan to widen and reinforce the San Jacinto River bridge on Interstate 10. As a Baytown resident, worker, and City Council member I cannot stress enough how important funding this project is sooner rather than later. I-10 is a national transportation route that severely breaks down when the San Jacinto River bridge is compromised. Delays in commerce are common when this route down, as well as the ability for workforce to get to major industrial complexes. ExxonMobil and Chevron Phillips both have their largest domestic manufacturing plants in Baytown and many of their essential personnel commute from Houston. When the San Jacinto Bridge is not passable it greatly affects people's ability to get to work, affecting petrochemical manufacturing which, again, has a national ripple effect. Please consider not only funding this project, but do so now.
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: San Jacinto Bridge
TxDOT agrees that this bridge needs to be replaced. TxDOT is in the early phase of project development. TxDOT will work with the community and stakeholders including both the land and water side to identify design improvements that enhance mobility and improve safety for people and goods.
As an advocate for the development of regional transportation infrastructure from the Brazosport area to Hempstead and beyond, I fully support the amendment to add 36A to the list of projects in the 2045 Regional Transportation Plan. This route will provide an efficient and expanded transportation and freight route from Port Freeport to US 290. It involves a route from the Rosenberg\Needville\I69 area in Fort Bend County to Interstate 10 (36A Southern Route) and a continuing piece from Interstate 10 to US 290 (36A Northern Route) in Waller County.
These routes are necessary for enhanced evacuation capacity given State Highway 36 is a primary evacuation route for Southern Brazoria County and for efficient freight movement as a means of current and future need identified by H-GAC in their freight mobility efforts to route traffic outside the metropolitan core. With the groundbreaking of Port Freeport Harbor Channel Improvement Project, ensuring that Port Freeport will be the deepest Port on the Gulf Coast and throughout the region, we need to have foresight to ensure transportation mobility is there as the Port grows, among other benefits delivered by the two projects.
The 2045 Regional Transportation Plan is hugely important to the future planning of regional mobility, congestion mitigation, quality of life, safety, and efficient movement of goods. We appreciate the effort. TxDOT is currently underway with a 2 to 4 lane expansion from Port Freeport to Rosenberg. This route needs to continue in an efficient path to Interstate 10 and to US 290 to provide maximum benefit of evacuation safety and efficient freight mobility movement.
H-GAC knows well that planning is the key to ensuring the most effective routes at the most reasonable costs to achieve their goals. Doing so before development occurs expands options and reduces cost. For this reason, I have particular concern that the Southern Route be incorporated this year at minimum. The pace of development in Fort Bend County poses great risk to the future location of such a route and threatens to increase cost, should they not be undertaken now. 36A Southern Route provides the key connection from Port Freeport and Brazoria County to Interstate 10 and provides enhanced evacuation, safety, freight mobility and commerce throughout the region.
Needville’s location at the southern end of the potential 36A route is critical to our mobility requirements in the near future. We are seeing tremendous residential and commercial growth coming over the next 10 years and the need for efficient transportation from the port through our community is of critical importance.
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
The West Houston Association and our Regional Mobility Committee supports the amendment to add 36A to the list of projects in the 2045 Regional Transportation Plan. This has been proposed to involve a route from the Rosenberg\Needville\I69 area in Fort Bend County to Interstate 10 (36A Southern Route) and a continuing piece from Interstate 10 to US 290 (36A Northern Route) in Waller County.
The 2045 Regional Transportation Plan is an important tool for guiding the careful planning and analysis of projects related to regional mobility, congestion mitigation, quality of life, safety, and efficient movement of goods. Planning for this project needs to be inclusive of options for connectivity to Interstate 10 and to US 290 to provide thoughtfully contemplate benefits related to general mobility, economic development, environmental preservation, evacuation safety, and efficient freight mobility movement. Including this project in the RTP will allow for continued regional conversation on potential alignments for this project and will facilitate environmental reviews in a manner which is most appropriate to address and mitigate any potential project impacts while maximizing project benefits.
Thank you for this opportunity to comment.
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
I am a resident of Cottage Grove and have recently been informed of the I-10 Inner Katy Managed lanes project. After reviewing the project materials I am very concerned about all concepts proposed and the impacts they may have on my home and neighborhood.
I oppose all options TxDOT has presented, and I encourage H-GAC to not accept the addition of the TxDOT I-10 Inner Katy Managed Lanes project to the 2045 Regional Transportation Plan. TxDOT should reconsider the scale of this project and look at alternatives that will have less impact on the neighborhood.
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: The Inner Katy (I10) corridor from I610 to the Central Business District is a high-volume corridor in terms of passenger and freight movement with limited right of way for future improvements. METRO's Inner Katy BRT project will impact the State's right of way and the interstate facility; therefore, TxDOT initiated a corridor study to evaluate the future needs of the State's system in this segment of roadway. TxDOT is coordinating the corridor study with METRO's proposed Inner Katy BRT project to ensure a shared vision that doesn't prohibit future opportunities or improvements. TxDOT"s goal is always to avoid, minimize, and only then to mitigate possible impacts to the human and natural environment. TxDOT is committed to on-going stakeholder and public engagement as this project progresses over the years from the planning phase to design.
I am a resident of Cottage Grove and have recently been informed of the I-10 Inner Katy Managed lanes project. After reviewing the project materials I am very concerned about all concepts proposed and the impacts they may have on my home and neighborhood.
I oppose all options TxDOT has presented, and I encourage H-GAC to not accept the addition of the TxDOT I-10 Inner Katy Managed Lanes project to the 2045 Regional Transportation Plan. TxDOT should reconsider the scale of this project and look at alternatives that will have less impact on the neighborhood.
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: The Inner Katy (I10) corridor from I610 to the Central Business District is a high-volume corridor in terms of passenger and freight movement with limited right of way for future improvements. METRO's Inner Katy BRT project will impact the State's right of way and the interstate facility; therefore, TxDOT initiated a corridor study to evaluate the future needs of the State's system in this segment of roadway. TxDOT is coordinating the corridor study with METRO's proposed Inner Katy BRT project to ensure a shared vision that doesn't prohibit future opportunities or improvements. TxDOT"s goal is always to avoid, minimize, and only then to mitigate possible impacts to the human and natural environment. TxDOT is committed to on-going stakeholder and public engagement as this project progresses over the years from the planning phase to design.
I am a resident of Cottage Grove and have recently been informed of the I-10 Inner Katy Managed lanes project. After reviewing the project materials I am very concerned about all concepts proposed and the impacts they may have on my home and neighborhood.
I oppose all options TxDOT has presented, and I encourage H-GAC to not accept the addition of the TxDOT I-10 Inner Katy Managed Lanes project to the 2045 Regional Transportation Plan. TxDOT should reconsider the scale of this project and look at alternatives that will have less impact on the neighborhood.
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: The Inner Katy (I10) corridor from I610 to the Central Business District is a high-volume corridor in terms of passenger and freight movement with limited right of way for future improvements. METRO's Inner Katy BRT project will impact the State's right of way and the interstate facility; therefore, TxDOT initiated a corridor study to evaluate the future needs of the State's system in this segment of roadway. TxDOT is coordinating the corridor study with METRO's proposed Inner Katy BRT project to ensure a shared vision that doesn't prohibit future opportunities or improvements. TxDOT"s goal is always to avoid, minimize, and only then to mitigate possible impacts to the human and natural environment. TxDOT is committed to on-going stakeholder and public engagement as this project progresses over the years from the planning phase to design.
I am a resident of Cottage Grove and have recently been informed of the I-10 Inner Katy Managed lanes project. After reviewing the project materials I am very concerned about all concepts proposed and the impacts they may have on my home and neighborhood.
I oppose all options TxDOT has presented, and I encourage H-GAC to not accept the addition of the TxDOT I-10 Inner Katy Managed Lanes project to the 2045 Regional Transportation Plan. TxDOT should reconsider the scale of this project and look at alternatives that will have less impact on the neighborhood.
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: The Inner Katy (I10) corridor from I610 to the Central Business District is a high-volume corridor in terms of passenger and freight movement with limited right of way for future improvements. METRO's Inner Katy BRT project will impact the State's right of way and the interstate facility; therefore, TxDOT initiated a corridor study to evaluate the future needs of the State's system in this segment of roadway. TxDOT is coordinating the corridor study with METRO's proposed Inner Katy BRT project to ensure a shared vision that doesn't prohibit future opportunities or improvements. TxDOT"s goal is always to avoid, minimize, and only then to mitigate possible impacts to the human and natural environment. TxDOT is committed to on-going stakeholder and public engagement as this project progresses over the years from the planning phase to design.
Dear H-GAC – Transportation Planning,
I am a resident of Cottage Grove and have recently been informed of the I-10 Inner Katy Managed lanes project. After reviewing the project materials, I am very concerned about all concepts proposed and the impacts they may have on my home and neighborhood.
Concept A appears to threaten homes along the feeder and our only green space, Cottage Grove Park. Concept B brings the noise and pollution of I-10 upwards on elevated freeway decks and projects it across our neighborhood.
Concept C does both – elevating the freeway lanes and then bringing them immediately adjacent to our homes and park.
I oppose all options. H-GAC should reconsider their support of this project and look at alternatives that will have less impact on the neighborhood.
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: The Inner Katy (I10) corridor from I610 to the Central Business District is a high-volume corridor in terms of passenger and freight movement with limited right of way for future improvements. METRO's Inner Katy BRT project will impact the State's right of way and the interstate facility; therefore, TxDOT initiated a corridor study to evaluate the future needs of the State's system in this segment of roadway. TxDOT is coordinating the corridor study with METRO's proposed Inner Katy BRT project to ensure a shared vision that doesn't prohibit future opportunities or improvements. TxDOT"s goal is always to avoid, minimize, and only then to mitigate possible impacts to the human and natural environment. TxDOT is committed to on-going stakeholder and public engagement as this project progresses over the years from the planning phase to design.
As a resident of Cottage Grove I recently heard about the I-10 Inner Katy Managed lanes project. After reviewing the project materials, I am very concerned about all concepts proposed and the impacts they may have on my home and neighborhood. Currently not in favor of any of these proposed solutions.
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: The Inner Katy (I10) corridor from I610 to the Central Business District is a high-volume corridor in terms of passenger and freight movement with limited right of way for future improvements. METRO's Inner Katy BRT project will impact the State's right of way and the interstate facility; therefore, TxDOT initiated a corridor study to evaluate the future needs of the State's system in this segment of roadway. TxDOT is coordinating the corridor study with METRO's proposed Inner Katy BRT project to ensure a shared vision that doesn't prohibit future opportunities or improvements. TxDOT"s goal is always to avoid, minimize, and only then to mitigate possible impacts to the human and natural environment. TxDOT is committed to on-going stakeholder and public engagement as this project progresses over the years from the planning phase to design.
Dear H-GAC – Transportation Planning,
I am a resident of Cottage Grove and have recently been informed of the I-10 Inner Katy Managed lanes project. After reviewing the project materials, I am very concerned about all concepts proposed and the impacts they may have on my home and neighborhood.
Concept A appears to threaten homes along the feeder and our only green space, Cottage Grove Park. Concept B brings the noise and pollution of I-10 upwards on elevated freeway decks and projects it across our neighborhood.
Concept C does both – elevating the freeway lanes and then bringing them immediately adjacent to our homes and park.
I oppose all options. H-GAC should reconsider their support of this project and look at alternatives that will have less impact on the neighborhood.
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: The Inner Katy (I10) corridor from I610 to the Central Business District is a high-volume corridor in terms of passenger and freight movement with limited right of way for future improvements. METRO's Inner Katy BRT project will impact the State's right of way and the interstate facility; therefore, TxDOT initiated a corridor study to evaluate the future needs of the State's system in this segment of roadway. TxDOT is coordinating the corridor study with METRO's proposed Inner Katy BRT project to ensure a shared vision that doesn't prohibit future opportunities or improvements. TxDOT"s goal is always to avoid, minimize, and only then to mitigate possible impacts to the human and natural environment. TxDOT is committed to on-going stakeholder and public engagement as this project progresses over the years from the planning phase to design.
Attached is a letter with the comments from the City of Houston on the 2045 Regional Transportation Plan amendments. Our comments are limited to the amendments within the City of Houston boundaries. Overall, our major concern is the regional elevated lanes have not be vetted by the public, reviewed or approved by the H-GAC TPC, nor contemplated in the 2045 Regional Transportation Plan. Our ask is for a regional study conducted by H-GAC that evaluates is the Regional Express Access Lanes are consistent with the vision for the region and includes a public vetting process.
View Attached Letter
A response from TxDOT is attached.
View Attached Response
Please find attached a letter of support from the Alliance to add the 36A project to the 2045 RTP.
A hard copy of this letter was mailed to you today.
View Attached Letter
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
I am a resident of Cottage Grove and have recently been informed of the I-10 Inner Katy Managed lanes project. After reviewing the project materials I am very concerned about all concepts proposed and the impacts they may have on my home and neighborhood.
I oppose all options TxDOT has presented, and I encourage H-GAC to not accept the addition of the TxDOT I-10 Inner Katy Managed Lanes project to the 2045 Regional Transportation Plan. TxDOT should reconsider the scale of this project and look at alternatives that will have less impact on the neighborhood.
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: The Inner Katy (I10) corridor from I610 to the Central Business District is a high-volume corridor in terms of passenger and freight movement with limited right of way for future improvements. METRO's Inner Katy BRT project will impact the State's right of way and the interstate facility; therefore, TxDOT initiated a corridor study to evaluate the future needs of the State's system in this segment of roadway. TxDOT is coordinating the corridor study with METRO's proposed Inner Katy BRT project to ensure a shared vision that doesn't prohibit future opportunities or improvements. TxDOT"s goal is always to avoid, minimize, and only then to mitigate possible impacts to the human and natural environment. TxDOT is committed to on-going stakeholder and public engagement as this project progresses over the years from the planning phase to design.
There are too many traffic lights that run 24 hours a day on minor side streets with very little traffic. These unnecessary lights add to air pollution, wasted fuel, and wasted time. I know of several lights in my neighborhood adjacent to large commercial buildings that have been unoccupied for several years, but formerly held hundreds of employees, yet the lights continue to operate with very light traffic. More traffic lights should be set to blink yellow/red, replaced with stop signs, or eliminated.
Thank you for your input. Please see the response from TxDOT below.
TxDOT response: TxDOT's is continously evaluating new tools, technologies, and techniques to improve safety. Thank you for your comment.
The Hurricane Evacuation Routes do not consider road flooding that routinely occurs at low spots and feeder roads. Low areas should be addressed.
Thank you for your input. Please see the response from TxDOT below.
TxDOT response: Per federal and state design criteria, all projects are evaluated and designed to meet prescribed drainage criteria. The National Oceanic Atmospheric Administration (NOAA) published a new atlas for precipitation frequency covering the United States, which is entitled Atlas 14. You can find more information here: https://hdsc.nws.noaa.gov/hdsc.pfds/index.html.
Numerous and heavy storms and the associated flooding have necessitated changes to design standard to incorporate the new Atlas 14 design standards for infrastructure improvements. The new Atlas 14 guidance will assist in our ability to mitigate flood impacts. Further, TxDOT does coordinate with local governments in the region to identify and address problem areas. This coordination with the local governments is helpful in identifying specific locations of concern so that we can eliminate the effect of flood events by raising the road and/or facilitating evacuation.
TxDOT has done a terrible job designing major freeway expansions at I-45 Gulf Freeway southbound Exit 25 through Exit 24. In a distance of ~1/2 mile, I-45 southbound goes from 5 lanes, to 4 lanes, to 3 lanes, with a disappearing weaving lane for entering traffic and exiting traffic for the NASA One bypass. This often creates a 1 to 4 mile span of southbound backed-up traffic from El Dorado Blvd. to Bay Area Blvd. to 528 to NASA One to League City.
Thank you for your input. Please see the response from TxDOT below.
TxDOT response: At this time, the lane reduction on IH-45 is a temporary condition. When the IH-45 widening project to the south of this location between NASA 1 and FM 518 is complete, there will be 10 mainlanes on I-45 (5 in each direction) with an HOV lane in each direction at NASA 1. Once IH-45 is in the final configuration, the referenced lane reduction that is currently present on the IH-45 southbound main lanes approaching NASA 1 (5 lanes to 3 lanes) will be eliminated. The current construction project should alleviate some of the concerns discussed in the comment. In addition, TxDOT has initiated a Planning and Environmental Linkage (PEL) study for I-45 south (Gulf Fwy). This study will evaluate major investments needed for improving congestion and safety, while mitigating environmental factors such as flooding. Please follow the I-45 PEL by going to our website: https://www.txdot.gov/inside-txdot/gulf-freeway-pel-study/about-gulf-freeway-study.html
Dear H-GAC – Transportation Planning,
I am a resident of Cottage Grove, a neighborhood directly adjacent to the north and south of I-10, just inside I-610 Loop W. I have recently been informed of the I-10 Inner Katy Managed lanes project. After reviewing the project materials, I am very concerned about all concepts proposed and the impacts they may have on my home and neighborhood.
Concept A appears to threaten homes along the feeder and our only green space, Cottage Grove Park. Concept B brings the noise and pollution of I-10 upwards on elevated freeway decks and projects it across our neighborhood.
Concept C does both – elevating the freeway lanes and then bringing them immediately adjacent to our homes and park.
I oppose all options. H-GAC should reconsider their support of this project and look at alternatives that will have less impact on the neighborhood.
Sincerely,
Katie Niemann
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: The Inner Katy (I10) corridor from I610 to the Central Business District is a high-volume corridor in terms of passenger and freight movement with limited right of way for future improvements. METRO's Inner Katy BRT project will impact the State's right of way and the interstate facility; therefore, TxDOT initiated a corridor study to evaluate the future needs of the State's system in this segment of roadway. TxDOT is coordinating the corridor study with METRO's proposed Inner Katy BRT project to ensure a shared vision that doesn't prohibit future opportunities or improvements. TxDOT"s goal is always to avoid, minimize, and only then to mitigate possible impacts to the human and natural environment. TxDOT is committed to on-going stakeholder and public engagement as this project progresses over the years from the planning phase to design.
The 2045 RTP is an impressive yet challenging step forward for the H-GAC area. Given the limited information released to the public, it is still unclear what data and assumptions are used to make projections about the future transportation need, for each project. However, the fact that 2045rtp.com only refers to the 1990 to 2015 data to support the necessity of the 2045 RTP is worrisome: the 1990-2015 data don’t account for the recent changes which significantly impact the future transportation need of the H-GAC area, including, the post-pandemic work-from-everywhere new norm, the oil bust post-2014, and the ongoing shifts from ICE vehicles to EVs. You don’t want to build some overly planned, highly invasive mega projects that no one will use. As a result, I highly recommend making the projects, at least the disruptive ones, more transparent and adaptive.
For example, the Inner Katy BRT and Inner Katy managed lanes projects will be disruptive in the narrow Inner Katy corridor. Rather than planning and building the two competing projects almost in parallel, it’s better to build one first (e.g. the BRT), evaluate its impact, estimate the updated future need, then plan and build another.
In this way, we’ll have more capital efficient, less invasive projects that better serve the 2045 goal.
Thank you for your comment.
The 2045 Regional Transportation Plan (RTP) update process began in 2017 and completed in 2019. The data we used were up to date at the time when the process started. We did projections based on the data we had and made recommendations for the next 25 years. The Regional Transportation Plan will update every four years to make sure our recommendations are compatible with the changing needs in the region. The next full update to the RTP will begin later this year we will take your comment into our consideration for the 2050 RTP. The 2050RTP development process will include public involvement process and we encourage your participation.
We use Call for Projects process on a regular basis tentatively once every three years to select the projects for programming in the Transportation Improvement Program (TIP), the 10-Year Plan, and inclusion in the RTP. Last Call for Projects Process was conducted in conjunction with the development of 2045RTP. All projects submitted through the 2018 Call for Projects (2018 CFP) were evaluated based on 50% score (100 points) given to its benefit/cost ratio and 50% score (100 points) given to various planning factors. The benefit-cost analyses were focused on reduction of crashes, delay and emissions. Please refer to 2045 RTP Appendix P for more details about "Call for projects evaluation criteria". Thank you again for your participation and comment. Please see the response from TxDOT below.
TxDOT response: The Inner Katy (I10) corridor from I610 to the Central Business District is a high-volume corridor in terms of passenger and freight movement with limited right of way for future improvements. METRO's Inner Katy BRT project will impact the State's right of way and the interstate facility; therefore, TxDOT initiated a corridor study to evaluate the future needs of the State's system in this segment of roadway. TxDOT is coordinating the corridor study with METRO's proposed Inner Katy BRT project to ensure a shared vision that doesn't prohibit future opportunities or improvements. TxDOT"s goal is always to avoid, minimize, and only then to mitigate possible impacts to the human and natural environment. TxDOT is committed to on-going stakeholder and public engagement as this project progresses over the years from the planning phase to design.
Some folks in the region have been trying to push this 36A Highway (more than ten years ago) as a TOLL road that Waller Co. citizens would pay for thru bonds, etc. - (for the destruction of farm land) under the guise of bringing jobs....what jobs, for whom, and who asked for them? Sold it as urgency so we can get down to Freeport without a traffic jam so we can get to the port. (I been to Freeport once, I didn't know I needed ANOTHER TOLLWAY (you can pick it up in Pearland area and take all the way-many ways thru Houston. More globalist projects paid for at locals expense. This is like to BS toy train to Dallas, another scam private corp. project, with (corrupt imminent domain status)! DId you hear one of those presentations in local community, ('we have to have the toy train (50 plus year old technology) or I-45 is going to be a 35mph travel speed to Dallas in just a few years!' Sure, who doesn't want to drive to the Galleria to get felt-up by TSA perverts during a private business transaction (buying a service from the private corp). To go to Dallas to then what, rent a car to get around?! No thanks to funding globalist projects. PS the toy train doesn't have any project profits scheduled-but federal bailouts will come....
Thank you for your comment. Please see the response from TxDOT below.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
Dear H-GAC- Planning and Projects Committees,
The elected leadership team of the Cottage Grove Civic Association and would like to provide
comments on behalf of the neighborhood and its residents. For those unfamiliar, Cottage Grove is
adjacent to I-10 on the north and south, generally centered at T.C. Jester. Cottage Grove is home to
approximately 5,500 residents as of the 2019 American Community Survey.
After review of the Inner Katy Managed Lanes preliminary concepts and associated materials, we
strongly oppose all options listed. Each concept has substantial potential impact on our community in
the form of road-noise, right of way (ROW) acquisition, or traffic pollution. Cottage Grove, as well as
many other neighborhoods in this corridor, were established before the construction of I-10 and have
become some of Houston’s most densely populated areas. All options, most especially concepts C and A
would have unacceptable impact and will be met with extreme neighborhood opposition.
We recommend H-GAC reconsider their support of the project and review alternatives that will be less
impactful to the adjacent neighborhoods. TxDOT has created similar 2-Lane managed lanes further west
on I-10 and other freeways. We believe TxDOT would accomplish many of its goals with this design and
with minimal neighborhood impact.
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: The Inner Katy (I10) corridor from I610 to the Central Business District is a high-volume corridor in terms of passenger and freight movement with limited right of way for future improvements. METRO's Inner Katy BRT project will impact the State's right of way and the interstate facility; therefore, TxDOT initiated a corridor study to evaluate the future needs of the State's system in this segment of roadway. TxDOT is coordinating the corridor study with METRO's proposed Inner Katy BRT project to ensure a shared vision that doesn't prohibit future opportunities or improvements. TxDOT"s goal is always to avoid, minimize, and only then to mitigate possible impacts to the human and natural environment. TxDOT is committed to on-going stakeholder and public engagement as this project progresses over the years from the planning phase to design.
Hi,
I am a resident of Cottage Grove and was made aware that H-GAC is planning to add the Inner Katy managed lanes project to their regional plan. I am strongly opposed to that project because of the impact it will have on my neighborhood. This is one of Houston's densest corridors and its amazing that TXDOT is planning to do what they always do - keep adding lanes and destroying neighborhoods. TxDOT's previous projects have shown plenty of times that more lanes won't fix traffic. The federal government stepped in with the NHHIP and this project is very similar. I strongly encourage H-GAC to reconsider their support of this project and look at mass transit alternatives that will actually benefit the residents of the region.
Thank you,
Vivian
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: The Inner Katy (I10) corridor from I610 to the Central Business District is a high-volume corridor in terms of passenger and freight movement with limited right of way for future improvements. METRO's Inner Katy BRT project will impact the State's right of way and the interstate facility; therefore, TxDOT initiated a corridor study to evaluate the future needs of the State's system in this segment of roadway. TxDOT is coordinating the corridor study with METRO's proposed Inner Katy BRT project to ensure a shared vision that doesn't prohibit future opportunities or improvements. TxDOT"s goal is always to avoid, minimize, and only then to mitigate possible impacts to the human and natural environment. TxDOT is committed to on-going stakeholder and public engagement as this project progresses over the years from the planning phase to design.
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
To: Houston-Galveston Area Council (H-GAC), Regional Transportation Plan and Air Quality Conformity Public Comment
Re: Support for the Amendments to add Highway 36A to the 2045 Regional Transportation Plan
The American Council of Engineering Companies (ACEC) Houston is comprised of over 245 firms in the region for the purpose of advancing the private practice of consulting engineering and educating public officials on the importance of infrastructure investment. As advocates for the development of transportation infrastructure, ACEC Houston supports the amendments to add Highway 36A to the list of projects in the 2045 Regional Transportation Plan.
The routes included in 36A will provide efficient and expanded transportation from Port Freeport to US 290 and are necessary for enhanced evacuation capacity given that State Highway 36 is a primary evacuation route for southern Brazoria County. In addition, the routes are important for efficient freight movement outside the metropolitan core, a priority for the H-GAC. With the groundbreaking of the Port Freeport Harbor Channel Improvement Project, we need to ensure that mobility keeps up with the Port’s growth.
The 2045 Regional Transportation Plan is very important to the future planning of regional mobility, congestion mitigation, quality of life, safety, and the efficient movement of goods. H-GAC knows well that, if possible, building before development expands options and reduces cost. For this reason, the Southern Route should be incorporated this year at minimum. The pace of development in Fort Bend County poses great risk to the future location of such a route and threatens to increase costs should it not be undertaken now. The 36A Southern Route provides the key connection from Port Freeport and Brazoria County to Interstate 10 and provides enhanced evacuation, safety, freight mobility, and commerce throughout the region.
Thank you for this opportunity to comment. Please contact me if you have questions or need more information.
Sincerely,
David Hagy
Executive Director
American Council of Engineering Companies (ACEC) Houston
(713) 426-0800 (Office) | (703) 835-2735 (Cell)
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
The Katy Prairie Conservancy appreciates the opportunity to provide comments to the proposed amendments to H-GAC’s 2045 Regional Transportation Plan.
The Katy Prairie Conservancy (KPC) has protected over 18,000 acres of contiguous natural lands on the historic Katy Prairie in Harris and Waller Counties, for the benefit of people and wildlife and an additional 6,448 acres in Matagorda, Jackson, and Brazoria Counties. Preserved lands in Harris and Waller Counties (the Katy Prairie Preserve) provide excellent habitat for the many upland and wetland species that live or migrate on the coastal prairie while also providing multiple benefits to the public, including recreation, local agricultural production, water quality benefits, enhancements to mental and physical health, and improvements to the quality of life for all residents. Land management activities by KPC, such as native prairie restoration, wetlands enhancements, invasive species control, prescribed burns, and sustainable grazing practices, further enhance these benefits. Prairie grasses also absorb and hold floodwaters back from downstream and allow them to release more slowly, native grassland soils store carbon which make our air cleaner, and wetlands filter rainwater and resulting pollutants and sediment, thereby helping improve water quality.
Of continued interest to KPC is the possibility of a new 36A thoroughfare project, and in particular the segment north of I-10, project 18720. KPC is not aware that a route has been selected for 36A nor that TxDOT has narrowed the corridor to Waller County. However, the map included as “Attachment - B DRAFT RTP 2045 TXDOT Amendment Projects” includes a dotted red line that appears to cross directly over the Katy Prairie Preserve. Further, during the public meetings held on April 8, HGAC planners referred to the 36A project as affecting Waller County, with a connection ending at 290 within Waller County.
KPC requests that any reference to 36A be clarified to remove any materials or references that imply that the corridor has been narrowed to Waller County, and that the dotted red line be deleted from “Attachment - B DRAFT RTP 2045 TXDOT Amendment Projects.”
We do note that an additional attachment “Attachment - B 36A North and South Study Area,” indicates that the 36A project could be sited anywhere on the east from the Grand Parkway (99) in Harris County to an area west past Highway 36 in Austin County.
KPC requests that this larger study area map is the only map that is appropriate to include in any reference to the 36A project.
As noted in Chapter 3, Natural Environment, “The parks, open spaces, natural areas, farmlands and waterways are indispensable and contribute to the economy and the health and quality of life of residents…. [Unless] proactive action is taken, we stand to lose or significantly impair these resources and the important ecological services that they provide to the region. In addition, the ongoing disappearance of undeveloped land will have serious consequences for air and water quality, agricultural productivity, wildlife habitat, opportunities for recreation and pursuing healthy lifestyles, and keeping the region’s character and cultural heritage. The challenge is how to plan for the projected urban growth and increased mobility while conserving our high priority natural resources and preserving the ecological diversity of our region.”
The 2045 RTP also addresses indirect environmental impacts:
• “Flood risk increases as forests, grasslands, and wetlands in the flat and low-lying metropolitan region are replaced with rooftops and pavement.”
• “H-GAC also recognizes that transportation infrastructure projects can have foreseeable consequences that occur later in time but not necessarily near the project site. Through its policies, impacts must be considered during the transportation planning process. Strategies for mitigating these impacts include using spatial environmental data tools to evaluate the impact of potential projects; promoting low-impact developmental practices in transportation projects and subsequent development; and coordinating with other air and water quality and land conservation efforts in project areas.”
• KPC requests that H-GAC consider the serenity of the preserve for both people and wildlife would be harmed in multiple ways by a major road on or adjacent to the Katy Prairie Preserve:
• Land Fragmentation. Unfragmented and contiguous lands are critical to the wildlife populations that live on the Katy Prairie. Land fragmentation impacts not only farming and ranching activities, but also negatively impacts many plants and animals that live on the prairie and require connected habitat to maintain healthy populations. A thoroughfare across the preserve would disrupt those connections.
• Wildlife Disturbance. The Katy Prairie is at the southern terminus of the Central Flyway providing winter habitat for migratory waterfowl, shorebirds, and Sandhill cranes. The Katy Prairie Preserve has been designated a Global Important Bird Area by National Audubon, one of only 20 such designations in Texas. These grasslands provide respite for upland birds, many of which are in decline due to the loss of grassland habitat elsewhere. In addition, many birds and other prairie animals are sensitive to light, sound, and vibration and would be driven away by the construction and operation of any new roadway that cuts a new path through any part of the preserve system or that is sited in close proximity to the Katy Prairie Preserve.
• Soundscape. Busy roadways create noise that seriously diminish this community asset for both people and wildlife. The Katy Prairie is a serene place where one can hear the calls of native birds and insects. The soundscape is a very important environmental characteristic that KPC is trying to retain. Quiet places are few and far between these days; keeping the Katy Prairie Preserve’s soundscape quiet should have high importance when considering new infrastructure.
• Destruction of Habitat. The land on which a thoroughfare would be constructed would be destroyed and greatly altered by a roadway and associated infrastructure, as well as by subsequent associated development.
• Pavement and adjacent development will exacerbate flooding and minimize the benefits that KPC lands and other natural lands on the Katy Prairie already provide to slow down, absorb, and store water.
• Quality of Life Impact. In addition to the benefits the Katy Prairie Preserve system provides to wildlife, the prairie also offers significant benefits to the public by improving air and water quality, providing nearby agricultural products, and offering much needed recreational opportunities – all of which improve the quality of life for area residents. These benefits would be degraded by a new roadway impacting KPC’s preserve system.
KPC urges transportation planners to respect the myriad benefits that the Katy Prairie Preserve provides to the region including water quality, flood mitigation, local agriculture, wildlife habitat, physical and mental health benefits, and carbon sequestration. As set forth in the 2045 RTP, these values must be fully considered as transportation projects are evaluated, particularly major thoroughfares that not only directly impact the lands over and adjacent to the projects, but also cause many indirect impacts as working and natural lands are fragmented and developed. It is appropriate for a multi-billion-dollar project, such as the proposed 36A project, to be studied in accordance with the required process, including the evaluation of environmental impacts, and that HGAC refrain from any communications that imply a circumvention of this process.
The transportation planning process should frame the discussion of new roads sensibly and sensitively with proactive guidance for the protection of natural resources. By starting early there is the option and flexibility to adjust the route, but the natural resources cannot be moved nor replaced. The study should treat ecological and environmental concerns as of the utmost and fundamental importance and should reconcile transportation needs with natural imperatives, not the other way round. Once natural assets are lost, they are lost forever. We have the opportunity and the responsibility to make sure that these natural assets are preserved and enjoyed by future generations.
Thank you for the opportunity to comment on the proposed amendments.
Mary Anne Piacentini, President and CEO, Katy Prairie Conservancy
Michael Huffmaster, Board Member and Chair, Public Affairs Committee, Katy Prairie Conservancy
Thank you for your participation and comment. We will take the points of your comment into our consideration. As stated in Transportation Policy Council Resolution 2014-01 (attachment) “the Katy Prairie is a significant natural regional resource that should be preserved and enhanced for the benefit of current and future generations and, although all feasible alternatives should be investigated in this study, it is neither the intention nor in the regional interest to build 36A on land that is currently under control or ownership of the Katy Prairie Conservancy.” H-GAC is committed to an inclusive “grass roots” planning process utilizing the guidance of key stakeholders at the corridor and segment level. As per the requested comment the June TAC/TPC amendment material will include the study area to represent Highway 36A projects 18719 and 18720.
Please see the response from TxDOT below.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. Our study methodology always seeks to avoid potential impacts. If impacts cannot be reasonably avoided, we try to minimize the impact; and only then do we mitigate the impacts of a project. This alternatives alignment process is very prescribed and consistent with federal and state practices. The process also includes extensive stakeholder and public engagement.
The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
None of these plans seem to care about the systemic changes Americans need to make for climate change. The Covid-19 Pandemic has shown that many people can work from home and that will make suburbs and commuting both less desirable. Continuing to plan racist and unjust highway expansions is wildly offensive to many Houstonians.
With a 61% increase in population, the H-GAC assumes a 61% increase in single-occupancy vehicle usage. Projects in the RTP should be determining future outcomes, not being influenced by presumed outcomes. Please provide a data based justification used to estimate a 61% increase in vehicle usage?
Please provide and explain the relationship between the two air quality standards in question—the EPA’s NAAQS ozone standard and TCEQ’s MVEB targets
Thank you for your comment on the Regional Transportation Plan and Air Quality comment page. H-GAC values your input. The 61% growth in single -occupancy vehicle usage coming from fact sheet 2 (http://www.2045rtp.com/documents/2045-fact-sheet2.pdf) was developed as a promotional material for first round of public involvement meetings conducted during the development of 2045 RTP process in spring of 2018. 61% of estimated population growth was applied to vehicle ownership (5.5 million) data from 2017. This estimated vehicle ownership growth was not used in the project selection process. The agency provides a public data lab (Link) and documentation (Link) explaining its forecasting processes.
For your comment regarding the relation between the national ambient air quality standard (NAAQS) and the motor vehicle emission budgets (MVEBs): The air quality state implementation plan (SIP) is the state's comprehensive plan to clean the air and meet federal air quality standards. Our region is in nonattainment for ozone and TCEQ is the state agency to prepare the air quality SIP. To prepare the SIP, the state agency must consider all sources of air pollution in the region, like industrial emissions, mobile on-road emissions, non-road emissions (construction equipment}, off-road emissions (locomotives, airports, commercial marine), area emission (residential and small business). The emission inventories for the sources of air pollution are generated and input into the photochemical model to get the concentration of ozone for the attainment year. Air quality control strategies are being also included into the model to attain the standard. Based on this exercise, on-road mobile sources get a quota of up to how much they can emit to reach the standard and that quota is called the Motors Vehicle Emission Budget (MVEB). Conformity is the exercise that shows that all the emissions coming from the transportation plan for a given year do not exceed the MVEB, in other words, the emissions coming from the transportation plan do not delay the attainment of the ozone standard.
Unfortunately, this amendment includes various roadway widenings and lane additions. Lane construction will never solve for roadway congestion in the long-term. The field of transportation planning is slowly addressing this across the United States. It is disappointing to see these costly plans still being recommended here in Harris County when they will certainly not solve the long-term problem. In addition, these construction projects will have long-term negative health impacts to those residents who live nearby. Additional lanes mean additional pollutants and overall worse air quality for Harris County residents. Adding lanes does not support any touted air quality goals--it works against them. I am a resident of Houston I am opposed to these roadway expansions and lane additions included in this amendment.
Thank you for your input. We will take those comment into our consideration for the 2045 RTP Amendments process.
With a 61% increase in population, the H-GAC assumes a 61% increase in single-occupancy vehicle usage. Projects in the RTP should be determining future outcomes, not being influenced by presumed outcomes. Please provide a data based justification used to estimate a 61% increase in vehicle usage?
The Proposed Amendment to the 2045 RTP should not include Segment 3 of the NHHIP because of the FHWA’s and USDOT’s pause of the project.
Has Texas Central approved the Hempstead Road elevated managed lanes project? Why would we build a highway right next to US290? Please provide record of input from Texas Central on project #18706, and justification for 18701, 18702, 18703, 18704, and 18705.
Please provide and explain the relationship between the two air quality standards in question—the EPA’s NAAQS ozone standard and TCEQ’s MVEB targets
Please include discussion of air quality related health risks and benefits
Thank you for your comment to the Regional Transportation Plan and Air Quality comment page. H-GAC values your input. The 61% growth in single -occupancy vehicle usage coming from fact sheet 2 (http://www.2045rtp.com/documents/2045-fact-sheet2.pdf) was developed as a promotional material for first round of public involvement meetings conducted during the development of 2045 RTP process in spring of 2018. 61% of estimated population growth was applied to vehicle ownership (5.5 million) data from 2017. This estimated vehicle ownership growth was not used in the project selection process.
The agency provides a public data lab (link) and documentation (link) explaining its forecasting processes.
For your comment regarding the relation between the national ambient air quality standard (NAAQS) and the motor vehicle emission budgets (MVEBs): The air quality state implementation plan (SIP) is the state's comprehensive plan to clean the air and meet federal air quality standards. Our region is in nonattainment for ozone and TCEQ is the state agency to prepare the air quality SIP. To prepare the SIP, the state agency must consider all sources of air pollution in the region, like industrial emissions, mobile on-road emissions, non-road emissions (construction equipment}, off-road emissions (locomotives, airports, commercial marine), area emission (residential and small business). The emission inventories for the sources of air pollution are generated and input into the photochemical model to get the concentration of ozone for the attainment year. Air quality control strategies are being also included into the model to attain the standard. Based on this exercise, on-road mobile sources get a quota of up to how much they can emit to reach the standard and that quota is called the Motors Vehicle Emission Budget (MVEB). Conformity is the exercise that shows that all the emissions coming from the transportation plan for a given year do not exceed the MVEB, in other words, the emissions coming from the transportation plan do not delay the attainment of the ozone standard. For our next conformity determination, H-GAC will consider the addition of a discussion regarding air pollution and health effects.
See below response from TxDOT for comment on NHHIP and Hempstead Road projects
TxDOT response: Segment 3 of the of the NHHIP is already included in the 2045 RTP. This amendment includes a change to the existing project. The Federal Highway Administration's review of the NHHIP does not preclude the projects inclusion in the 2045 RTP.
Hempstead
The Hempstead project from I-610 to BW 8 currently exists in the 2045 RTP. Hempstead Road between I-610 and Beltway 8 will undergo a feasibility study to determine potential scope changes. The study has not commenced, but it will include significant stakeholder and public involvement.
It is very important that there be adequate, safe connectivity between Northside and Heights. Right now, the safest crossing is at Patton and I-45 because it is a 4-way stop. Many people in Northside don't drive (you see Fiesta trucks driving the neighborhood picking up shopping carts). Making everyone go to North St. to safely cross over isn't sufficient. To begin with, Browning elementary is on Patton.
TxDOT's response does not address the question:"The Hardy Toll Road (HTR) Extension will only function to its full potential as a reliever route with the NHHIP constructed as proposed. The following are two critical improvements that are included with the NHHIP (and are only possible with NHHIP) that will make I-45, I-610, and HTR function as complimentary transportation corridors:
1) I-45/I-610 Interchange reconstruction. This interchange was constructed in the 1950s and has an outdated design with left-hand exits from freeway to freeway and there is no frontage road system through the interchange to prevent neighborhood cut-through traffic. The proximity of the HTR existing termination to this interchange exacerbates the safety and capacity I-45 and I-610 which carries a high volume of freight traffic from Port Houston.
2) The HCTRA HTR extension design (without NHHIP) has two lanes each direction merging to one lane at I-10/I-69 as it has to tie into the existing I-10 to I-69 connector ramps. This will result in a mixing of traffic between users desiring to get to/from the Hardy Toll Road with users desiring to access I-10 and I-69. The NHHIP plan reconfigures the HTR Extension so that it no longer connects to a freeway to freeway connection, but instead the HTR will have a dedicated connection that gives users the option to connect to downtown or stay on the freeway. This option is ONLY possible through NHHIP."
This phase of the Regional Transportation Plan represents a huge potential step forward for our region, but I am disappointed to see several steps backward. Despite significant public outcry to massive car-centric infrastructure investments like the NHHIP, this plan continues to center pollutive, inefficient, and unjust single-occupancy-vehicle transportation. With such initiatives as major expansions of I-10 and 610; expansions of SH99; and creation of an all new highway, SH36A; this Plan will ensure that our region spends billions of dollars on infrastructure that limits our choices and pollutes the very air we breathe.
The negative health outcomes of living next to highways is well documented by now, as you should know from the public outcry and federal investigation surrounding the NHHIP. By continuing to create more and larger highways, you are subjecting Texans—the people you have chosen to represent and serve—to respiratory illness, pre-term births, increased mortality, and more. These are serious issues, and the rest of the country knows it: our region has been out of compliance with EPA air quality standards for quite some time, and I fail to see how this new Plan will do anything but worsen our air quality.
I believe that you, the agency responsible, owe your constituents clearer and stronger justification for these massive and dangerous projects. Please, provide us with the following:
1) With a 61% increase in population, the H-GAC assumes a 61% increase in single-occupancy vehicle usage. Projects in the RTP should be determining future outcomes, not being influenced by presumed outcomes. Please provide a data based justification used to estimate a 61% increase in vehicle usage.
2) The Proposed Amendment to the 2045 RTP should not include Segment 3 of the NHHIP because of the FHWA’s and USDOT’s pause of the project.
3) Has Texas Central approved the Hempstead Road elevated managed lanes project? Why would we build a highway right next to US290? Please provide record of input from Texas Central on project #18706, and justification for 18701, 18702, 18703, 18704, and 18705.
4) Please provide and explain the relationship between the two air quality standards in question—the EPA’s NAAQS ozone standard and TCEQ’s MVEB targets
5) Please include discussion of air quality related health risks and benefits in this RTP.
Thank you for your comment on the Regional Transportation Plan and Air Quality comment page. H-GAC values your input. The 61% growth in single -occupancy vehicle usage coming from fact sheet 2 (http://www.2045rtp.com/documents/2045-fact-sheet2.pdf) was developed as a promotional material for first round of public involvement meetings conducted during the development of 2045 RTP process in spring of 2018. 61% of estimated population growth was applied to vehicle ownership (5.5 million) data from 2017. This estimated vehicle ownership growth was not used in the project selection process. The agency provides a public data lab (Link) and documentation (Link) explaining its forecasting processes.
For your comment regarding the relation between the national ambient air quality standard (NAAQS) and the motor vehicle emission budgets (MVEBs):The air quality state implementation plan (SIP) is the state's comprehensive plan to clean the air and meet federal air quality standards. Our region is in nonattainment for ozone and TCEQ is the state agency to prepare the air quality SIP. To prepare the SIP, the state agency must consider all sources of air pollution in the region, like industrial emissions, mobile on-road emissions, non-road emissions (construction equipment}, off-road emissions (locomotives, airports, commercial marine), area emission (residential and small business). The emission inventories for the sources of air pollution are generated and input into the photochemical model to get the concentration of ozone for the attainment year. Air quality control strategies are being also included into the model to attain the standard. Based on this exercise, on-road mobile sources get a quota of up to how much they can emit to reach the standard and that quota is called the Motors Vehicle Emission Budget (MVEB). Conformity is the exercise that shows that all the emissions coming from the transportation plan for a given year do not exceed the MVEB, in other words, the emissions coming from the transportation plan do not delay the attainment of the ozone standard. For our next conformity determination, H-GAC will consider the addition of a discussion regarding air pollution and health effects.
See response to you comments on NHHIP and Hempstead Road from TxDOT below
IH 45, Segment 3 (North Houston Highway Improvement Project)
Segment 3 of the of the NHHIP is already included in the 2045 RTP. This amendment includes a change to the existing project. The Federal Highway Administration's review of the NHHIP does not preclude the projects inclusion in the 2045 RTP.
Hempstead
The Hempstead project from I-610 to BW 8 currently exists in the 2045 RTP. Hempstead Road between I-610 and Beltway 8 will undergo a feasibility study to determine potential scope changes. The study has not commenced, but it will include significant stakeholder and public involvement.
I do not understand how the HGAC can confidently claim that a 61% increase in population automatically translates to a 61% increase in single occupancy vehicle usage. Can y'all produce any data to support that?
Why does the HGAC assume that air quality will improve even if VMTs go up? Can y'all explain it?
Additionally, why does this suddenly change in 2045? These charts make no sense.
I do not think any of these assumptions make sense, so the entire RTP is predicated on flawed assumptions. I do not support most of the 2045 RTP because most of the projects involve adding main lanes without robust consideration of walking, biking, or transit infrastructure. We have to be thinking and acting and spending differently, or this region will be nightmare to navigate by any mode of transportation. We, as serious non-attainers, should be looking for ways to be proactive about improving air quality at all costs. I am an ER nurse and public health nurse in my late twenties, and I can say with confidence that my biggest health risks right now are poor air quality and car dependence. Further comments below:
1. RTP fact sheets published with the 2045 RTP and its amendment state that the HGAC region will experience a 61% population growth and corresponding 61% increase in vehicle ownership over the next 25 years. The transportation infrastructure built between now and 2045 is one of the most influential drivers of future vehicle ownership. The RTP should be addressing future population growth using methods that efficiently and sustainably move the population while also ensuring that households without a vehicle are provided the same transportation equity as vehicle owners. Projects in the RTP should be determining future outcomes, not being influenced by presumed outcomes. Please provide the data-based justification used to estimate a 61% increase in vehicle usage.
2. The Proposed Amendment to the 2045 RTP should not include Segment 3 of the NHHIP because of the FHWA and USDOT’s pause of the project.
3. SH99 (grand parkway) expansion from 4 lanes to 6 lanes is a perfect example of induced demand and unsustainable transportation paradigm. The growth around this road is facilitating further destruction of the Katy Prairie, an ecosystem critical to manage flooding of regional watershed. The portion of the Grand Parkway proposed for expansion was completed less than 10 years ago. The RTP needs to be investing in transportation infrastructure that will be effective for longer than 10 years.
4. The new SH-36A is a disruption of precious continuous prairie land.
5. Has Texas Central approved the Hempstead Road elevated managed lanes project? Why would we build a highway right next to US290? Please provide record of input from Texas Central on project #18706 and justification for 18701, 18703, 18704, and 18705.
Is alignment of the I-10 W inner Katy corridor required for completion of the METRONext plan?
The proposed amendment does not respect the city of Houston and Harris County’s stated goals to reduce VMT in the region over time.
8. Projects in the RTP should be prioritizing safety; expanding lanes and increasing VMTs do not align with Vision Zero initiatives.
Of gravest concern, is that the “Transportation Conformity” Chapter, titled “Air Quality” in the 2045 RTP table of contents, misleadingly represents the region’s air quality status.
While we appreciate the need for the chapter to discuss and present the conformity process and results, the lack of information and data presented on the ozone standard and the region’s attainment designation is striking. In essence, there are two air quality standards of interest for the Houston-Galveston-Brazoria (HGB) region—one that the region meets (the Texas Commission on Environmental Quality’s (TCEQ) Motor Vehicle Emission Budgets (MVEB) for nitrogen oxides (NOx) and volatile organic compounds (VOCs)) and one that it does not (the Environmental Protection Agency’s (EPA) National Ambient Air Quality Standards (NAAQS) Ozone standard). The chapter overwhelmingly focuses on the TCEQ MVEB standard; 4 of the chapter’s 7 pages are of charts and tables showing the region meeting the emission budgets. Nowhere in the chapter, however, are similar tables, charts or data illustrating the region’s nonattainment to EPA’s ozone standard. We are concerned that the information presented, and omitted, gives the false impression that the region is successfully meeting air quality standards, when in reality, it is not.
This is yet more concerning given that the region’s ozone readings are actual—obtained via dozens of air quality monitoring sites across the region—whereas TCEQ’s MVEB targets are theoretical and model-derived.
To improve this, we request/ recommend:
• Provide a clear representation of the region’s actual air quality status;
• Please provide and explain the relationship between the two air quality standards in question—the EPA’s NAAQs ozone standard and TCEQ’s MVEB targets;
• Include data, charts, tables regarding the EPA ozone standard.
9. The stark disconnect between conformity results (conformity achieved) and actual ozone readings (serious nonattainment) highlights the flaws in the Texas air quality regulatory process. Conformity data presented on pages 5-7 of the Transportation Conformity chapter shows the HGB region easily meeting MVEBs under moderate and serious RFP SIPs for years 2020 through 2045. Meanwhile actual ozone readings from TCEQ air quality monitoring stations (for 2020) continue to designate the region as serious nonattainment. This disconnect demonstrates that the combination of using TCEQ’s MVEBs coupled with the EPA’s MOVES2014 model is not a proper tool to help Texas MPOs meet the federal ozone standard. TCEQ’s MVEBs, shown on pages 5-7, are particularly divorced from reality and unhelpful targets.
To address this, we request/recommend:
• Work with TCEQ and other state MPOs to revise the MVEB process;
• Give less credence to the conformity results especially within planning purposes and when sharing information with the public. The conformity process is complex, confusing, is disconnected from actual ozone levels, and should not be the basis for the region’s air quality decisions. Instead, air quality planning and programs should be developed with the end goal of meeting the Federal ozone standard.
10. Rewrite the Transportation Conformity/ Air Quality chapter as a more user-friendly document with the public in mind.
Conformity and the air quality regulatory process is complex and confusing. The way that the Transportation Conformity/ Air Quality chapter is written and presented makes it more so. Throughout the chapter, a number of important acronyms are never spelled out. These include TCEQ, NOx, VOCs. Please remember that the RTP is a public facing document intended to present the region’s long range transportation vision. This section is not digestible, lacks context (why do we care about air quality?), excludes references (footnotes 2 and 3), and provides very few leads for an individual to educate themselves on air quality issues.
To address this, we request/ recommend:
• Provide context; why is air quality important to the region;
• Use less technical language and spell out acronyms;
• Provide information on the Transportation Control Measures and Emission Control Programs deployed across the region. Given the region’s “serious attainment” designation, we would imagine the public to be interested in the region’s efforts to reduce emissions.
11. Include discussion of air quality related health risks and benefits
Via the Clean Air Act, the NAAQS for six criteria pollutants were created as safeguards for public health. To be exact, they were created “to protect human health and welfare” from harmful pollutants; ozone having been identified by the EPA as one of the six criteria pollutants. The intent of an MPO’s air quality efforts therefore must be with this health goal in mind. However, chapter 6 includes no discussion of human health or why the region should be concerned about VOCs, NOx, or ozone.
Across Texas, asthma (the clearest and most serious health risk tied to high levels of ozone) is the number one reason for school absenteeism. Child asthma rates are also found to be higher at schools with greater proximity to roads. A 2017 American Lung Association study found asthma levels to be higher in Houston than in most other parts of the country and are most concentrated in low-income and minority communities. Asthma rates, and health injustices, are yet another datapoint that must be considered while planning the region’s transportation future.
To address this, we request/ recommend:
• Establish programs and goals that address the region’s air quality related health issues with a focus on the populations and communities that suffer the brunt of environmental/ transportation-related health harms;
• Prioritize transportation modes, such as biking, walking, electric vehicles, and public transportation over road expansion and single occupancy vehicle travel that will worsen air quality.
12. As a whole, RTP 2045 (and its amendments) are in conflict with the region’s air quality and health goals.
As long as H-GAC transportation planning prioritizes road expansion and single-occupancy vehicle travel over alternative transportation modes, as is done throughout RTP 2045, air quality, health, and road congestion will be horrendous in the region. For example, under the current plan, there will be a 61% population growth over the next 25 years, with a 61% increase in vehicles, and an increase of more than 100,000,000 VMT. When logic is applied, it is evident that a transportation forced to absorb 61% more vehicles would be crippled far beyond the existing congestion rates. RTP 2045 should plan for future population growth using methods that efficiently move the population, which is not with single occupant vehicles. The transportation infrastructure built between now and 2045 is one of the most influential drivers of vehicle ownership.
Again, please remember that the purpose of long-range transportation plans, such as RTP 2045, is to provide the public with a vision for the region. The vision that RTP 2045 presents is increased population, VMTs, congestion without identifying any programs or strategy for improving air quality and health outcomes.
To address this, we request/ recommend:
• Prioritize transportation modes, such as biking, walking, electric vehicles, and public transportation over road expansion and single occupancy vehicle travel that will worsen air quality.
13. Consider Greenhouse Gasses
The federal air standards do not yet regulate greenhouse gasses (GHG). The question of how and when GHG should be regulated, and added to the air quality standards, has been actively considered by the Clinton, Bush, Obama, and Biden Administrations. With greater concern over the climate crisis, there is reason to believe that GHG will be assessed in the coming years. We saw no references to GHG in Air Quality/ Conformity chapter.
To address this, we request/ recommend:
• Include discussion of GHG sources within the transportation sector;
• Set goals and strategies for reducing GHG emissions.
Thank you.
Thank you for your comment on the Regional Transportation Plan and Air Quality comment page. H-GAC values your input. The 61% growth in single -occupancy vehicle usage coming from fact sheet 2 (http://www.2045rtp.com/documents/2045-fact-sheet2.pdf) was developed as a promotional material for first round of public involvement meetings conducted during the development of 2045 RTP process in spring of 2018. 61% of estimated population growth was applied to vehicle ownership (5.5 million) data from 2017. This estimated vehicle ownership growth was not used in the project selection process. The agency provides a public data lab (Link) and documentation (Link) explaining its forecasting processes.
For your comment regarding Chapter 6 of the RTP document, H-GAC will consider the addition of more air quality information on this chapter in the next conformity determination.
Also, for our next conformity determination, H-GAC will consider the addition of a discussion regarding air quality standards, air quality control strategies for mobile sources, and air pollution and health effects.
For your comment regarding the relation between the national ambient air quality standard (NAAQS) and the motor vehicle emission budgets (MVEBs), here is our explanation: The air quality state implementation plan (SIP) is the state's comprehensive plan to clean the air and meet federal air quality standards. Our region is in nonattainment for ozone and TCEQ is the state agency to prepare the air quality SIP. To prepare the SIP, the state agency must consider all sources of air pollution in the region, like industrial emissions, mobile on-road emissions, non-road emissions (construction equipment}, off-road emissions (locomotives, airports, commercial marine), area emission (residential and small business). The emission inventories for the sources of air pollution are generated and input into the photochemical model to get the concentration of ozone for the attainment year. Air quality control strategies are being also included into the model to attain the standard. Based on this exercise, on-road mobile sources get a quota of up to how much they can emit to reach the standard and that quota is called the Motors Vehicle Emission Budget (MVEB). Conformity is the exercise that shows that all the emissions coming from the transportation plan for a given year do not exceed the MVEB, in other words, the emissions coming from the transportation plan do not delay the attainment of the ozone standard.
For your comment regarding the fact that in the future VMT goes up as air pollution goes down. these emissions reductions are due primarily to fleet turn over and the implementation of new federal standards. The Tier 2 emission standards implemented in 2004 for light duty gasoline vehicles and light duty gasoline trucks show emission reductions of up to 95% in NOx versus Tier 1 vehicles. In addition, the Clean Diesel federal rule, which was implemented in 2006 for heavy duty diesel vehicles, shows an emission reduction of 96% in NOx versus previous standards. The Tier 3 vehicle standards implemented between 2017 and 2025 reduces both tailpipe and evaporative emissions from passenger cars, light-duty trucks, medium-duty passenger vehicles and some heavy-duty vehicles. Once fully implemented, smog-forming volatile organic compounds and nitrogen oxides will be reduced by 80% from current levels, particulate matter will be reduced by 70%, and fuel vapor emissions will be driven to near zero levels. For more information on the emission reductions and the implementation timeline for these rules, please refer to the following EPA websites:
https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-light-duty-vehicles-and-trucks-and
https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-heavy-duty-highway-engines-and-vehicles
https://theicct.org/sites/default/files/publications/ICCTupdate_Tier3_NPRM.pdf
Due to all the above emission standards for vehicles, the emissions in the transportation plan are being reduced in the future years due to fleet over turn although the VMT keeps increasing due to population increase.
The analysis of projects regarding their GHGs emissions is not required for a conformity determination. However, the federal government may require this analysis in the future for project selection and H-GAC will be happy to comply.
For your comment regarding the use of acronyms, H-GAC has a list of acronyms in the conformity website.
See response to you comments on NHHIP Segment 3, SH99, Highway 36A, Hempstead Road and IH 10 W/Inner Katy from TxDOT below
IH 45, Segment 3 (North Houston Highway Improvement Project)
Segment 3 of the of the NHHIP is already included in the 2045 RTP. This amendment includes a change to the existing project. The Federal Highway Administration's review of the NHHIP does not preclude the project's inclusion in the 2045 RTP.
SH 99
The current and projected travel demand on SH 99 warrants improvements to ensure continued mobility and safety in the corridor.
36A
36A North: (MPOID 18720) and 36A South: (0912-72-544, MPOID 18719)
At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. Our study methodology always seeks to avoid potential impacts. If impacts cannot be reasonably avoided, we try to minimize the impact; and only then do we mitigate the impacts of a project. This alternatives alignment process is very prescribed and consistent with federal and state practices. The process also includes extensive stakeholder and public engagement.
Hempstead
The Hempstead project from I-610 to BW 8 currently exists in the 2045 RTP. Hempstead Road between I-610 and Beltway 8 will undergo a feasibility study to determine potential scope changes. The study has not commenced, but it will include significant stakeholder and public involvement. Texas Central does not have authority to perform or approve a TxDOT project. TxDOT has had multple meetings with the Texas Central team. The Texas Central team will continue to be consulted as a stakeholder during the Hempstead feasibility study.
Inner Katy:
The Inner Katy (I10) corridor from I610 to the Central Business District is a high-volume corridor in terms of passenger and freight movement with limited right of way for future improvements. METRO's Inner Katy BRT project will impact the State's right of way and the interstate facility; therefore, TxDOT initiated a corridor study to evaluate the future needs of the State's system in this segment of roadway. TxDOT is coordinating the corridor study with METRO's proposed Inner Katy BRT project to ensure a shared vision that doesn't prohibit future opportunities or improvements. TxDOT"s goal is always to avoid, minimize, and only then to mitigate possible impacts to the human and natural environment. TxDOT is committed to on-going stakeholder and public engagement as this project progresses over the years from the planning phase to design. TxDOT identified improvement concepts are not expected to affect METRO's implementation of their Inner Katy BRT project. There may, however, be some partnership opportunities that must be considered through both agencies' efforts.
The 2045 RTP is more of the same from the HGAC. Car dependency is choking and killing our region. We have to get serious about air quality, and we have to get serious about getting away from our car-centric paradigm. Many of these projects add main lanes and do not have biking or transit infrastructure. How are y'all going to expand the Grand Parkway when it is brand new? These projects are a waste of precious funds, and they will be a dysfunctional as every other highway expansion has been in the US for the last several decades. I urge you to consider more creative and effective solutions to our region's mobility needs. I also agree with all of the following comments and request the same answers from the HGAC:
1. RTP fact sheets published with the 2045 RTP and its amendment state that the HGAC region will experience a 61% population growth and corresponding 61% increase in vehicle ownership over the next 25 years. The transportation infrastructure built between now and 2045 is one of the most influential drivers of future vehicle ownership. The RTP should be addressing future population growth using methods that efficiently and sustainably move the population while also ensuring that households without a vehicle are provided the same transportation equity as vehicle owners. Projects in the RTP should be determining future outcomes, not being influenced by presumed outcomes. Please provide the data-based justification used to estimate a 61% increase in vehicle usage.
2. The Proposed Amendment to the 2045 RTP should not include Segment 3 of the NHHIP because of the FHWA and USDOT’s pause of the project.
3. SH99 (grand parkway) expansion from 4 lanes to 6 lanes is a perfect example of induced demand and unsustainable transportation paradigm. The growth around this road is facilitating further destruction of the Katy Prairie, an ecosystem critical to manage flooding of regional watershed. The portion of the Grand Parkway proposed for expansion was completed less than 10 years ago. The RTP needs to be investing in transportation infrastructure that will be effective for longer than 10 years.
4. The new SH-36A is a disruption of precious continuous prairie land.
5. Has Texas Central approved the Hempstead Road elevated managed lanes project? Why would we build a highway right next to US290? Please provide record of input from Texas Central on project #18706 and justification for 18701, 18703, 18704, and 18705.
Is alignment of the I-10 W inner Katy corridor required for completion of the METRONext plan?
The proposed amendment does not respect the city of Houston and Harris County’s stated goals to reduce VMT in the region over time.
8. Projects in the RTP should be prioritizing safety; expanding lanes and increasing VMTs do not align with Vision Zero initiatives.
Of gravest concern, is that the “Transportation Conformity” Chapter, titled “Air Quality” in the 2045 RTP table of contents, misleadingly represents the region’s air quality status.
While we appreciate the need for the chapter to discuss and present the conformity process and results, the lack of information and data presented on the ozone standard and the region’s attainment designation is striking. In essence, there are two air quality standards of interest for the Houston-Galveston-Brazoria (HGB) region—one that the region meets (the Texas Commission on Environmental Quality’s (TCEQ) Motor Vehicle Emission Budgets (MVEB) for nitrogen oxides (NOx) and volatile organic compounds (VOCs)) and one that it does not (the Environmental Protection Agency’s (EPA) National Ambient Air Quality Standards (NAAQS) Ozone standard). The chapter overwhelmingly focuses on the TCEQ MVEB standard; 4 of the chapter’s 7 pages are of charts and tables showing the region meeting the emission budgets. Nowhere in the chapter, however, are similar tables, charts or data illustrating the region’s nonattainment to EPA’s ozone standard. We are concerned that the information presented, and omitted, gives the false impression that the region is successfully meeting air quality standards, when in reality, it is not.
This is yet more concerning given that the region’s ozone readings are actual—obtained via dozens of air quality monitoring sites across the region—whereas TCEQ’s MVEB targets are theoretical and model-derived.
To improve this, we request/ recommend:
• Provide a clear representation of the region’s actual air quality status;
• Please provide and explain the relationship between the two air quality standards in question—the EPA’s NAAQs ozone standard and TCEQ’s MVEB targets;
• Include data, charts, tables regarding the EPA ozone standard.
9. The stark disconnect between conformity results (conformity achieved) and actual ozone readings (serious nonattainment) highlights the flaws in the Texas air quality regulatory process. Conformity data presented on pages 5-7 of the Transportation Conformity chapter shows the HGB region easily meeting MVEBs under moderate and serious RFP SIPs for years 2020 through 2045. Meanwhile actual ozone readings from TCEQ air quality monitoring stations (for 2020) continue to designate the region as serious nonattainment. This disconnect demonstrates that the combination of using TCEQ’s MVEBs coupled with the EPA’s MOVES2014 model is not a proper tool to help Texas MPOs meet the federal ozone standard. TCEQ’s MVEBs, shown on pages 5-7, are particularly divorced from reality and unhelpful targets.
To address this, we request/recommend:
• Work with TCEQ and other state MPOs to revise the MVEB process;
• Give less credence to the conformity results especially within planning purposes and when sharing information with the public. The conformity process is complex, confusing, is disconnected from actual ozone levels, and should not be the basis for the region’s air quality decisions. Instead, air quality planning and programs should be developed with the end goal of meeting the Federal ozone standard.
10. Rewrite the Transportation Conformity/ Air Quality chapter as a more user-friendly document with the public in mind.
Conformity and the air quality regulatory process is complex and confusing. The way that the Transportation Conformity/ Air Quality chapter is written and presented makes it more so. Throughout the chapter, a number of important acronyms are never spelled out. These include TCEQ, NOx, VOCs. Please remember that the RTP is a public facing document intended to present the region’s long range transportation vision. This section is not digestible, lacks context (why do we care about air quality?), excludes references (footnotes 2 and 3), and provides very few leads for an individual to educate themselves on air quality issues.
To address this, we request/ recommend:
• Provide context; why is air quality important to the region;
• Use less technical language and spell out acronyms;
• Provide information on the Transportation Control Measures and Emission Control Programs deployed across the region. Given the region’s “serious attainment” designation, we would imagine the public to be interested in the region’s efforts to reduce emissions.
11. Include discussion of air quality related health risks and benefits
Via the Clean Air Act, the NAAQS for six criteria pollutants were created as safeguards for public health. To be exact, they were created “to protect human health and welfare” from harmful pollutants; ozone having been identified by the EPA as one of the six criteria pollutants. The intent of an MPO’s air quality efforts therefore must be with this health goal in mind. However, chapter 6 includes no discussion of human health or why the region should be concerned about VOCs, NOx, or ozone.
Across Texas, asthma (the clearest and most serious health risk tied to high levels of ozone) is the number one reason for school absenteeism. Child asthma rates are also found to be higher at schools with greater proximity to roads. A 2017 American Lung Association study found asthma levels to be higher in Houston than in most other parts of the country and are most concentrated in low-income and minority communities. Asthma rates, and health injustices, are yet another datapoint that must be considered while planning the region’s transportation future.
To address this, we request/ recommend:
• Establish programs and goals that address the region’s air quality related health issues with a focus on the populations and communities that suffer the brunt of environmental/ transportation-related health harms;
• Prioritize transportation modes, such as biking, walking, electric vehicles, and public transportation over road expansion and single occupancy vehicle travel that will worsen air quality.
12. As a whole, RTP 2045 (and its amendments) are in conflict with the region’s air quality and health goals.
As long as H-GAC transportation planning prioritizes road expansion and single-occupancy vehicle travel over alternative transportation modes, as is done throughout RTP 2045, air quality, health, and road congestion will be horrendous in the region. For example, under the current plan, there will be a 61% population growth over the next 25 years, with a 61% increase in vehicles, and an increase of more than 100,000,000 VMT. When logic is applied, it is evident that a transportation forced to absorb 61% more vehicles would be crippled far beyond the existing congestion rates. RTP 2045 should plan for future population growth using methods that efficiently move the population, which is not with single occupant vehicles. The transportation infrastructure built between now and 2045 is one of the most influential drivers of vehicle ownership.
Again, please remember that the purpose of long-range transportation plans, such as RTP 2045, is to provide the public with a vision for the region. The vision that RTP 2045 presents is increased population, VMTs, congestion without identifying any programs or strategy for improving air quality and health outcomes.
To address this, we request/ recommend:
• Prioritize transportation modes, such as biking, walking, electric vehicles, and public transportation over road expansion and single occupancy vehicle travel that will worsen air quality.
13. Consider Greenhouse Gasses
The federal air standards do not yet regulate greenhouse gasses (GHG). The question of how and when GHG should be regulated, and added to the air quality standards, has been actively considered by the Clinton, Bush, Obama, and Biden Administrations. With greater concern over the climate crisis, there is reason to believe that GHG will be assessed in the coming years. We saw no references to GHG in Air Quality/ Conformity chapter.
To address this, we request/ recommend:
• Include discussion of GHG sources within the transportation sector;
• Set goals and strategies for reducing GHG emissions.
Thank you for your comment on the Regional Transportation Plan and Air Quality comment page. H-GAC values your input. The 61% growth in single -occupancy vehicle usage coming from fact sheet 2 (http://www.2045rtp.com/documents/2045-fact-sheet2.pdf) was developed as a promotional material for first round of public involvement meetings conducted during the development of 2045 RTP process in spring of 2018. 61% of estimated population growth was applied to vehicle ownership (5.5 million) data from 2017. This estimated vehicle ownership growth was not used in the project selection process. The agency provides a public data lab (Link) and documentation (Link) explaining its forecasting processes.
For your comment regarding Chapter 6 of the RTP document, H-GAC will consider the addition of more air quality information on this chapter in the next conformity determination.
Also, for our next conformity determination, H-GAC will consider the addition of a discussion regarding air quality standards, air quality control strategies for mobile sources, and air pollution and health effects.
For your comment regarding the relation between the national ambient air quality standard (NAAQS) and the motor vehicle emission budgets (MVEBs), here is our explanation: The air quality state implementation plan (SIP) is the state's comprehensive plan to clean the air and meet federal air quality standards. Our region is in nonattainment for ozone and TCEQ is the state agency to prepare the air quality SIP. To prepare the SIP, the state agency must consider all sources of air pollution in the region, like industrial emissions, mobile on-road emissions, non-road emissions (construction equipment}, off-road emissions (locomotives, airports, commercial marine), area emission (residential and small business). The emission inventories for the sources of air pollution are generated and input into the photochemical model to get the concentration of ozone for the attainment year. Air quality control strategies are being also included into the model to attain the standard. Based on this exercise, on-road mobile sources get a quota of up to how much they can emit to reach the standard and that quota is called the Motors Vehicle Emission Budget (MVEB). Conformity is the exercise that shows that all the emissions coming from the transportation plan for a given year do not exceed the MVEB, in other words, the emissions coming from the transportation plan do not delay the attainment of the ozone standard.
Regarding your comment about the future years, where the VMT goes up and the emissions go down, these emissions reductions are due primarily to fleet turn over and the implementation of new federal standards. The Tier 2 emission standards implemented in 2004 for light duty gasoline vehicles and light duty gasoline trucks show emission reductions of up to 95% in NOx versus Tier 1 vehicles. In addition, the Clean Diesel federal rule, which was implemented in 2006 for heavy duty diesel vehicles, shows an emission reduction of 96% in NOx versus previous standards. The Tier 3 vehicle standards implemented between 2017 and 2025 reduces both tailpipe and evaporative emissions from passenger cars, light-duty trucks, medium-duty passenger vehicles and some heavy-duty vehicles. Once fully implemented, smog-forming volatile organic compounds and nitrogen oxides will be reduced by 80% from current levels, particulate matter will be reduced by 70%, and fuel vapor emissions will be driven to near zero levels. For more information on the emission reductions and the implementation timeline for these rules, please refer to the following EPA websites:
https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-light-duty-vehicles-and-trucks-and
https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-heavy-duty-highway-engines-and-vehicles
https://theicct.org/sites/default/files/publications/ICCTupdate_Tier3_NPRM.pdf
Due to all the above emission standards for vehicles, the emissions in the transportation plan are being reduced in the future years due to fleet over turn although the VMT keeps increasing due to population increase.:
The analysis of projects regarding their GHGs emissions is not required for a conformity determination. However, the federal government may require this analysis in the future for project selection and H-GAC will be happy to comply.
For your comment regarding the use of acronyms, H-GAC has a list of acronyms in the conformity website.
See response to you comments on NHHIP Segment 3, SH99, Highway 36A, Hempstead Road and IH 10 W/Inner Katy from TxDOT below
IH 45, Segment 3 (North Houston Highway Improvement Project)
Segment 3 of the of the NHHIP is already included in the 2045 RTP. This amendment includes a change to the existing project. The Federal Highway Administration's review of the NHHIP does not preclude the project's inclusion in the 2045 RTP.
SH 99
The current and projected travel demand on SH 99 warrants improvements to ensure continued mobility and safety in the corridor.
36A
36A North: (MPOID 18720) and 36A South: (0912-72-544, MPOID 18719)
At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. Our study methodology always seeks to avoid potential impacts. If impacts cannot be reasonably avoided, we try to minimize the impact; and only then do we mitigate the impacts of a project. This alternatives alignment process is very prescribed and consistent with federal and state practices. The process also includes extensive stakeholder and public engagement.
Hempstead
The Hempstead project from I-610 to BW 8 currently exists in the 2045 RTP. Hempstead Road between I-610 and Beltway 8 will undergo a feasibility study to determine potential scope changes. The study has not commenced, but it will include significant stakeholder and public involvement. Texas Central does not have authority to perform or approve a TxDOT project. TxDOT has had multple meetings with the Texas Central team. The Texas Central team will continue to be consulted as a stakeholder during the Hempstead feasibility study.
Inner Katy:
The Inner Katy (I10) corridor from I610 to the Central Business District is a high-volume corridor in terms of passenger and freight movement with limited right of way for future improvements. METRO's Inner Katy BRT project will impact the State's right of way and the interstate facility; therefore, TxDOT initiated a corridor study to evaluate the future needs of the State's system in this segment of roadway. TxDOT is coordinating the corridor study with METRO's proposed Inner Katy BRT project to ensure a shared vision that doesn't prohibit future opportunities or improvements. TxDOT"s goal is always to avoid, minimize, and only then to mitigate possible impacts to the human and natural environment. TxDOT is committed to on-going stakeholder and public engagement as this project progresses over the years from the planning phase to design. TxDOT identified improvement concepts are not expected to affect METRO's implementation of their Inner Katy BRT project. There may, however, be some partnership opportunities that must be considered through both agencies' efforts.
As a long-time Houston resident, I am concerned that many of these proposed changes include added lanes to the detriment of walking, biking, and transit infrastructure. The above mentioned projects all prioritize car-dependency. I have been here long enough to remember when we expanded I-10 with the promise that it would relieve congestion. The relief was temporary and now I-10 continues to be congested. Urban planners around the world use Houston's I-10 expansion as a cautionary tale of what not to do.
While I appreciate the need to discuss and present the conformity process and results, the lack of information and data presented on the ozone standard and the region’s attainment designation is striking. In essence, there are two air quality standards of interest for the Houston-Galveston-Brazoria (HGB) region—one that the region meets (the Texas Commission on Environmental Quality’s (TCEQ) Motor Vehicle Emission Budgets (MVEB) for nitrogen oxides (NOx) and volatile organic compounds (VOCs)) and one that it does not (the Environmental Protection Agency’s (EPA) National Ambient Air Quality Standards (NAAQS) Ozone standard). The chapter overwhelmingly focuses on the TCEQ MVEB standard; 4 of the chapter’s 7 pages are of charts and tables showing the region meeting the emission budgets. Nowhere in the chapter, however, are similar tables, charts or data illustrating the region’s nonattainment to EPA’s ozone standard. I am concerned that the information presented, and omitted, gives the false impression that the region is successfully meeting air quality standards, when in reality, it is not. This is yet more concerning given that the region’s ozone readings are actual—obtained via dozens of air quality monitoring sites across the region—whereas TCEQ’s MVEB targets are theoretical and model-derived.
To improve this, I request:
• Provide a clear representation of the region’s actual air quality status;
• Please provide and explain the relationship between the two air quality standards in question—the EPA’s NAAQs ozone standard and TCEQ’s MVEB targets;
• Include data, charts, tables regarding the EPA ozone standard.
As long as H-GAC transportation planning prioritizes road expansion and single occupancy vehicle travel over alternative transportation modes, as is done throughout RTP 2045, air quality, health, and road congestion will be horrendous in the region. For example, under the current plan, there will be a 61% population growth over the next 25 years, with a 61% increase in vehicles, and an increase of more than 100,000,000 VMT. When logic is applied, it is evident that a transportation forced to absorb 61% more vehicles would be crippled far beyond the existing congestion rates. RTP 2045 should plan for future population growth using methods that efficiently move the
population, which is not with single occupant vehicles. The transportation infrastructure built between now and 2045 is one of the most influential drivers of vehicle ownership. Again, please remember that the purpose of long-range transportation plans, such as RTP 2045, is to provide the public with a vision for the region. The vision that RTP
2045 presents is increased population, VMTs, congestion without identifying any programs or strategy for improving air quality and health outcomes.
To address this, I request:
• Prioritize transportation modes, such as biking, walking, electric vehicles, and public transportation over road expansion and single occupancy vehicle travel that will worsen air quality.
Furthermore, the federal air standards do not yet regulate greenhouse gasses (GHG). The question of how and when GHG should be regulated, and added to the air quality standards, has been actively considered by the Clinton, Bush, Obama, and Biden Administrations. With greater concern over the climate crisis, there is reason to believe that GHG will be assessed in the coming years. We saw no references to GHG in Air Quality/ Conformity chapter.
To address this, I request:
• Include discussion of GHG sources within the transportation sector;
• Set goals and strategies for reducing GHG emissions.
Thank you for your consideration.
Thank you for your comment on the Regional Transportation Plan and Air Quality comment page. H-GAC values your input. The 61% growth in single -occupancy vehicle usage coming from fact sheet 2 (http://www.2045rtp.com/documents/2045-fact-sheet2.pdf) was developed as a promotional material for first round of public involvement meetings conducted during the development of 2045 RTP process in spring of 2018. 61% of estimated population growth was applied to vehicle ownership (5.5 million) data from 2017. This estimated vehicle ownership growth was not used in the project selection process. The agency provides a public data lab (Link) and documentation (Link) explaining its forecasting processes.
The 2045 RTP is made up of more focused individual plans including the Regional Active Transportation Plan, Regional Safety plan, Regional Coordinated Transportation Plan, Congestion Mitigation Air Quality Plan, to list a few. All these plans can be found in the appendix of the document.
For the next conformity determination, H-GAC will consider the addition of a discussion regarding air quality standards, air quality control strategies for mobile sources, and air pollution and health effects.
Regarding your comment on GHGs, the analysis of projects regarding their GHGs emissions is not required for a conformity determination. However, the federal government may require this analysis in the future and H-GAC will be happy to comply.
1, A planned increase is based on the current world in which we live and hopes for 61% increased vehicle use. Ideally, the plans would include planning and creating future outcomes that acknowledge the realities and goals of the region, including less car dependence and more access to transportation, biking, and walking.
2. The changes should keep in account the department of transportation's pause of the i45 expansion, and create new plans.
3. Why have you not taken into account the worsening air standards in the Houston region that endanger all residents, but especially Black and Hispanic residents, and those who live in low-income communities? These racist standards cause greater harm to communities and hurt people throughout the region due to a lack of regard for health and safety.
4. The continued push for expanded car use and access makes cities more dangerous, hotter, and more vulnerable to the realities of climate change which will affect many cities, and especially Houston as hurricanes and incredibly hot summers become more and more frequent. Please think of the world you want to leave for your children. A dirty one that is overheated and inhospitable to human life? Or one that is green, walkable, welcoming, and able to keep them healthy? You have the opportunity to decide.
Houston can be a city that continues to look to the future, and symbolize technology, science and energy, or it can be one destroyed by cars and climate change.
Thank you for your comment on the Regional Transportation Plan and Air Quality comment page. H-GAC values your input. The 61% growth in single -occupancy vehicle usage coming from fact sheet 2 (http://www.2045rtp.com/documents/2045-fact-sheet2.pdf) was developed as a promotional material for first round of public involvement meetings conducted during the development of 2045 RTP process in spring of 2018. 61% of estimated population growth was applied to vehicle ownership (5.5 million) data from 2017. This estimated vehicle ownership growth was not used in the project selection process. The agency provides a public data lab (Link) and documentation (Link) explaining its forecasting processes.
The 2045 RTP is made up of more focused individual plans including the Regional Active Transportation Plan, Regional Safety plan, Regional Coordinated Transportation Plan, Congestion Mitigation Air Quality Plan, to list a few. All these plans can be found in the appendix of the document.
Thank you for your interest in the 2045 RTP. H-GAC appreciates you taking the time to express your concerns. These comments will be considered for the 2050 RTP.
Regarding the 2045 RTP: This project is not in the best interest of Houston, Harris County, or the Gulf Coast Region. Building more highways (and widening existing ones) at the expense of mass transportation will only make congestion and pollution worse in the long run.
• With a 61% increase in population, the H-GAC assumes a 61% increase in single-occupancy vehicle usage. Projects in the RTP should be determining future outcomes, not being influenced by presumed outcomes. Please provide a data based justification used to estimate a 61% increase in vehicle usage?
• The Proposed Amendment to the 2045 RTP should not include Segment 3 of the NHHIP because of the FHWA’s and USDOT’s pause of the project.
• Has Texas Central approved the Hempstead Road elevated managed lanes project? Why would we build a highway right next to US290? Please provide record of input from Texas Central on project #18706, and justification for 18701, 18702, 18703, 18704, and 18705.
• Please provide and explain the relationship between the two air quality standards in question—the EPA’s NAAQS ozone standard and TCEQ’s MVEB targets
• Please include discussion of air quality related health risks and benefits
Thank you for your comment on the Regional Transportation Plan and Air Quality comment page. H-GAC values your input. The 61% growth in single -occupancy vehicle usage coming from fact sheet 2 (http://www.2045rtp.com/documents/2045-fact-sheet2.pdf) was developed as a promotional material for first round of public involvement meetings conducted during the development of 2045 RTP process in spring of 2018. 61% of estimated population growth was applied to vehicle ownership (5.5 million) data from 2017. This estimated vehicle ownership growth was not used in the project selection process. The agency provides a public data lab (Link) and documentation (Link) explaining its forecasting processes.
The NHHIP is included in the Regional Transportation Plan, TxDOT only seeks to update the existing project. Texas Central is not responsible for the approval of capital projects, nor is the organization’s input required. The Hempstead Road construction will provide traffic an alternate route to US 290.
Regarding your comment on the relation between the national ambient air quality standard (NAAQS)and the motor vehicle emission budgets (MVEBs): The air quality state implementation plan (SIP) is the state's comprehensive plan to clean the air and meet federal air quality standards. Our region is in nonattainment for ozone and TCEQ is the state agency to prepare the air quality SIP. To prepare the SIP, the state agency must consider all sources of air pollution in the region, like industrial emissions, mobile on-road emissions, non-road emissions (construction equipment}, off-road emissions (locomotives, airports, commercial marine), area emission (residential and small business). The emission inventories for the sources of air pollution are generated and input into the photochemical model to get the concentration of ozone for the attainment year. Air quality control strategies are being also included into the model to attain the standard. Based on this exercise, on-road mobile sources get a quota of up to how much they can emit to reach the standard and that quota is called the Motors Vehicle Emission Budget (MVEB). Conformity is the exercise that shows that all the emissions coming from the transportation plan for a given year do not exceed the MVEB, in other words, the emissions coming from the transportation plan do not delay the attainment of the ozone standard.
See response from TxDOT below:
TxDOT Response: IH 45, Segment 3 (North Houston Highway Improvement Project)
Segment 3 of the of the NHHIP is already included in the 2045 RTP. This amendment includes a change to the existing project. The Federal Highway Administration's review of the NHHIP does not preclude the project's inclusion in the 2045 RTP.
Hempstead
The Hempstead project from I-610 to BW 8 currently exists in the 2045 RTP. Hempstead Road between I-610 and Beltway 8 will undergo a feasibility study to determine potential scope changes. The study has not commenced, but it will include significant stakeholder and public involvement. Texas Central does not have authority to perform or approve a TxDOT project. TxDOT has had multiple meetings with the Texas Central team. The Texas Central team will continue to be consulted as a stakeholder during the Hempstead feasibility study.
Technology is changing rapidly. The issues of emissions is being addressed by this technology. What needs to be done is to make sure that EV's and automous vehicles are planned for in design. As motor carrier traffic increases, so does the technology in them much faster than the travelling public since it is also about efficency and reducing costs. Planning for this motor carrier traffic is key to the reduction in congestion and reducing crashes as well. We must think about this is planning and not stick to the old way of thinking such as some of the groups that oppose new infrastructure. I 45 is dangerous for all including the neighbors that travel on it, too! It must be fixed in order to keep our economy moving in a positive direction. The price being paid not to do anything is the lives lost every day on I45.
Thank you for your comment. Autonomous and Connected vehicles benefits and drawbacks and their current and future applications is discussed in the current 2045 regional Transportation Plan (RTP) in the Emerging transportation technology section of chapter 3. Building upon the existing discussion in the 2045RTP, technology in transportation will be further developed in the 2050RTP. Your comment will be taken into consideration during the 2050RTP development process. The 2045 RTP includes more focused plans such as Congestion Mitigation Air Quality (CMAQ) Plan, Regional Safety Plan and Congestion Management Process to address the congestion, air quality and safety concerns in our region. For more details please see appendices to the 2045RTP at http://www.2045rtp.com/documents.aspx. The 2045RTP projects list include multiple projects on IH 45.
Please provide and explain the relationship between the two air quality standards in question—the EPA’s NAAQS ozone standard and TCEQ’s MVEB targets
Please include discussion of air quality related health risks and benefits
Most of the projects include added lanes to the detriment of walking, biking, and transit infrastructure. The above mentioned projects all prioritize car-dependency
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. For your question regarding the relation between the national ambient air quality standard (NAAQS) and the motor vehicle emission budgets (MVEB): The air quality state implementation plan (SIP) is the state's comprehensive plan to clean the air and meet federal air quality standards. Our region is in nonattainment for ozone and TCEQ is the state agency to prepare the air quality SIP. To prepare the SIP, the state agency must consider all sources of air pollution in the region, like industrial emissions, mobile on-road emissions, non-road emissions (construction equipment}, off-road emissions (locomotives, airports, commercial marine), area emission (residential and small business). The emission inventories for the sources of air pollution are generated and input into the photochemical model to get the concentration of ozone for the attainment year. Air quality control strategies are being also included into the model to attain the standard. Based on this exercise, on-road mobile sources get a quota of up to how much they can emit to reach the standard and that quota is called the Motors Vehicle Emission Budget (MVEB). Conformity is the exercise that shows that all the emissions coming from the transportation plan for a given year do not exceed the MVEB, in other words, the emissions coming from the transportation plan do not delay the attainment of the ozone standard.
For our next conformity determination, H-GAC will consider the addition of a discussion regarding air quality standards, air quality control strategies for mobile sources, and air pollution and health effects.
I am in support of this very important Project. It has the great capacity to be a game changer for the State Of Texas!
Thank you for your input. We will take your comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: Thank you for your input.
RTP fact sheets published with the 2045 RTP and its amendment state that the HGAC region will experience a 61% population growth and corresponding 61% increase in vehicle ownership over the next 25 years. The transportation infrastructure built between now and 2045 is one of the most influential drivers of future vehicle ownership. The RTP should be addressing future population growth using methods that efficiently and sustainably move the population while also ensuring that households without a vehicle are provided the same transportation equity as vehicle owners.
Projects in the RTP should be determining future outcomes, not being influenced by presumed outcomes.
Please provide the source and assumptions made to support the 61% increase in population growth.
Please provide the source and assumptions made to support the 61% increase in vehicle ownership.
Please provide alternative projections of future vehicle ownership that include increases in alternative modes of transportation.
The amendments proposed in the RTP 2045 will increase Vehicle Miles Traveled.
This increase is not in alignment with Houston or Harris County’s stated goals to reduce VMT in the region over time. The RTP 2045 is also not in alignment with Houston or Harris County’s Vision Zero initiatives.
Please provide alternative designs for these projects that are in alignment with Houston and Harris County’s stated goals to reduce VMT over time.
Please provide alternative designs for these projects that are in alignment with Houston and Harris County’s Vision Zero initiatives.
The RTP 2045 focus on building roadways as the primary solution for our areas future transportation needs is unsustainable.
SH99 (grand parkway) expansion from 4 lanes to 6 lanes is a perfect example of induced demand and unsustainable transportation paradigm. The growth around this road is facilitating further destruction of the Katy Prairie, an ecosystem critical to manage flooding of regional watershed. The portion of the Grand Parkway proposed for expansion was completed less than 10 years ago. The RTP needs to be investing in transportation infrastructure that will be effective for longer than 10 years.
Please provide an alternative project for SH 99 that includes in addition to the widening of roadways alternative means of transportation infrastructure such as commuter rail and/or BRT that doesn’t increase suburban sprawl and further destruction of the Katy Prairie and other natural resources.
Are the Hempstead Road elevated lanes necessary? Has Texas Central approved the Hempstead Road elevated managed lanes project? Why would we build a highway right next to US290? Please provide record of input from Texas Central on project #18706, and justification for 18701, 18702, 18703, 18704, and 18705.
The METRO Next Inner Katy BRT approved by the voters is a small step in the right direction. However, the TxDOT project to add lanes is not.
Please provide additional justification for the increased lanes beyond the projection of 61% population growth and corresponding vehicle ownership.
All the projects in the RTP 2045 including the proposed amendments that encourage suburban sprawl and ignore the reality of climate change. The proposed 36 A Project is a prime example. It will further the destruction of the Katy Prairie by prior highway projects, especially the Grand Parkway. It will also encourage development in these areas encouraging and increasing sprawl.
Please provide a justification for not prioritizing transportation modes, such as biking, walking, electric vehicles, and public transportation over road expansion and single occupancy vehicle travel that will worsen air quality.
Please provide discussion of GreenHouse Gas sources within the transportation sector.
Please provide goals and strategies for reducing GHG emissions.
Again, please remember that the purpose of long-range transportation plans, such as RTP 2045, is to provide the public with a vision for the region. The vision that RTP 2045 presents is increased population, VMTs, congestion without identifying any programs or strategy for improving air quality and health outcomes. I expect more than this from my MPO.
The 2045 RTP includes more focused plans such as Congestion Mitigation Air Quality (CMAQ) Plan, Regional Safety Plan and Congestion Management Process to address the congestion, air quality and safety concerns in our region. For more details please see appendices to the 2045RTP at http://www.2045rtp.com/documents.aspx.
For the next conformity determination, H-GAC will consider the addition of a discussion regarding air quality standards, air quality control strategies for mobile sources, and air pollution and health effects.
Regarding your comment on GHGs, the analysis of projects regarding their GHGs emissions is not required for a conformity determination. However, the federal government may require this analysis in the future and H-GAC will be happy to comply.
Please see response from TxDOT on your comments regarding SH 99, Hempstead, and Inner Katy projects below.
TxDOT Response:
SH 99
The current and projected travel demand on SH 99 warrants improvements to ensure continued mobility and safety in the corridor.
Hempstead
The Hempstead project from I-610 to BW 8 currently exists in the 2045 RTP. Hempstead Road between I-610 and Beltway 8 will undergo a feasibility study to determine potential scope changes. The study has not commenced, but it will include significant stakeholder and public involvement. Texas Central does not have authority to perform or approve a TxDOT project. TxDOT has had multple meetings with the Texas Central team. The Texas Central team will continue to be consulted as a stakeholder during the Hempstead feasibility study.
Inner Katy:
The Inner Katy (I10) corridor from I610 to the Central Business District is a high-volume corridor in terms of passenger and freight movement with limited right of way for future improvements. METRO's Inner Katy BRT project will impact the State's right of way and the interstate facility; therefore, TxDOT initiated a corridor study to evaluate the future needs of the State's system in this segment of roadway. TxDOT is coordinating the corridor study with METRO's proposed Inner Katy BRT project to ensure a shared vision that doesn't prohibit future opportunities or improvements. TxDOT"s goal is always to avoid, minimize, and only then to mitigate possible impacts to the human and natural environment. TxDOT is committed to on-going stakeholder and public engagement as this project progresses over the years from the planning phase to design. TxDOT identified improvement concepts are not expected to affect METRO's implementation of their Inner Katy BRT project. There may, however, be some partnership opportunities that must be considered through both agencies' efforts.
RTP fact sheets published with the 2045 RTP and its amendment state that the HGAC region
will experience a 61% population growth and corresponding 61% increase in vehicle
ownership over the next 25 years. The transportation infrastructure built between now and
2045 is one of the most influential drivers of future vehicle ownership. The RTP should be
addressing future population growth using methods that efficiently and sustainably move the
population while also ensuring that households without a vehicle are provided the same
transportation equity as vehicle owners. Projects in the RTP should be determining future
outcomes, not being influenced by presumed outcomes. Please provide the data-based
justification used to estimate a 61% increase in vehicle usage.
2. The Proposed Amendment to the 2045 RTP should not include Segment 3 of the NHHIP
because of the FHWA and USDOT’s pause of the project.
3. SH99 (grand parkway) expansion from 4 lanes to 6 lanes is a perfect example of induced
demand and unsustainable transportation paradigm. The growth around this road is
facilitating further destruction of the Katy Prairie, an ecosystem critical to manage flooding of
regional watershed. The portion of the Grand Parkway proposed for expansion was
completed less than 10 years ago. The RTP needs to be investing in transportation
infrastructure that will be effective for longer than 10 years.
4. The new SH-36A is a disruption of precious continuous prairie land.
5. Has Texas Central approved the Hempstead Road elevated managed lanes project? Why
would we build a highway right next to US290? Please provide record of input from Texas
Central on project #18706 and justification for 18701, 18703, 18704, and 18705.
Is alignment of the I-10 W inner Katy corridor required for completion of the
METRONext plan?
The proposed amendment does not respect the city of Houston and Harris County’s
stated goals to reduce VMT in the region over time.
8. Projects in the RTP should be prioritizing safety; expanding lanes and increasing VMTs do not
align with Vision Zero initiatives.
Of gravest concern, is that the “Transportation Conformity” Chapter, titled “Air
Quality” in the 2045 RTP table of contents, misleadingly represents the region’s
air quality status.
While we appreciate the need for the chapter to discuss and present the conformity
process and results, the lack of information and data presented on the ozone
standard and the region’s attainment designation is striking. In essence, there are
Stop TxDOT I-45 Public Comments for Amendments to the 2045 RTP
two air quality standards of interest for the Houston-Galveston-Brazoria (HGB)
region—one that the region meets (the Texas Commission on Environmental
Quality’s (TCEQ) Motor Vehicle Emission Budgets (MVEB) for nitrogen oxides (NOx)
and volatile organic compounds (VOCs)) and one that it does not (the Environmental
Protection Agency’s (EPA) National Ambient Air Quality Standards (NAAQS) Ozone
standard). The chapter overwhelmingly focuses on the TCEQ MVEB standard; 4 of
the chapter’s 7 pages are of charts and tables showing the region meeting the
emission budgets. Nowhere in the chapter, however, are similar tables, charts or
data illustrating the region’s nonattainment to EPA’s ozone standard. We are
concerned that the information presented, and omitted, gives the false impression
that the region is successfully meeting air quality standards, when in reality, it is not.
This is yet more concerning given that the region’s ozone readings are actual—
obtained via dozens of air quality monitoring sites across the region—whereas
TCEQ’s MVEB targets are theoretical and model-derived.
To improve this, we request/ recommend:
• Provide a clear representation of the region’s actual air quality status;
• Please provide and explain the relationship between the two air quality standards in
question—the EPA’s NAAQs ozone standard and TCEQ’s MVEB targets;
• Include data, charts, tables regarding the EPA ozone standard.
9. The stark disconnect between conformity results (conformity achieved) and actual
ozone readings (serious nonattainment) highlights the flaws in the Texas air quality
regulatory process. Conformity data presented on pages 5-7 of the Transportation Conformity
chapter shows the HGB region easily meeting MVEBs under moderate and serious RFP SIPs for
years 2020 through 2045. Meanwhile actual ozone readings from TCEQ air quality monitoring
stations (for 2020) continue to designate the region as serious nonattainment. This disconnect
demonstrates that the combination of using TCEQ’s MVEBs coupled with the EPA’s MOVES2014
model is not a proper tool to help Texas MPOs meet the federal ozone standard. TCEQ’s MVEBs,
shown on pages 5-7, are particularly divorced from reality and unhelpful targets.
To address this, we request/recommend:
• Work with TCEQ and other state MPOs to revise the MVEB process;
• Give less credence to the conformity results especially within planning purposes and
when sharing information with the public. The conformity process is complex,
confusing, is disconnected from actual ozone levels, and should not be the basis for
the region’s air quality decisions. Instead, air quality planning and programs should
be developed with the end goal of meeting the Federal ozone standard.
10. Rewrite the Transportation Conformity/ Air Quality chapter as a more user-friendly
document with the public in mind.
Conformity and the air quality regulatory process is complex and confusing. The way
that the Transportation Conformity/ Air Quality chapter is written and presented makes
it more so. Throughout the chapter, a number of important acronyms are never spelled
Stop TxDOT I-45 Public Comments for Amendments to the 2045 RTP
out. These include TCEQ, NOx, VOCs. Please remember that the RTP is a public facing
document intended to present the region’s long range transportation vision. This
section is not digestible, lacks context (why do we care about air quality?), excludes
references (footnotes 2 and 3), and provides very few leads for an individual to educate
themselves on air quality issues.
To address this, we request/ recommend:
• Provide context; why is air quality important to the region;
• Use less technical language and spell out acronyms;
• Provide information on the Transportation Control Measures and Emission Control
Programs deployed across the region. Given the region’s “serious attainment”
designation, we would imagine the public to be interested in the region’s efforts to
reduce emissions.
11. Include discussion of air quality related health risks and benefits
Via the Clean Air Act, the NAAQS for six criteria pollutants were created as safeguards
for public health. To be exact, they were created “to protect human health and welfare”
from harmful pollutants; ozone having been identified by the EPA as one of the six
criteria pollutants. The intent of an MPO’s air quality efforts therefore must be with this
health goal in mind. However, chapter 6 includes no discussion of human health or why
the region should be concerned about VOCs, NOx, or ozone.
Across Texas, asthma (the clearest and most serious health risk tied to high levels of
ozone) is the number one reason for school absenteeism. Child asthma rates are also
found to be higher at schools with greater proximity to roads. A 2017 American Lung
Association study found asthma levels to be higher in Houston than in most other parts
of the country and are most concentrated in low-income and minority communities.
Asthma rates, and health injustices, are yet another datapoint that must be considered
while planning the region’s transportation future.
To address this, we request/ recommend:
• Establish programs and goals that address the region’s air quality related health
issues with a focus on the populations and communities that suffer the brunt of
environmental/ transportation-related health harms;
• Prioritize transportation modes, such as biking, walking, electric vehicles, and public
transportation over road expansion and single occupancy vehicle travel that will
worsen air quality.
12. As a whole, RTP 2045 (and its amendments) are in conflict with the region’s air quality
and health goals.
As long as H-GAC transportation planning prioritizes road expansion and singleoccupancy vehicle travel over alternative transportation modes, as is done throughout
RTP 2045, air quality, health, and road congestion will be horrendous in the region. For
example, under the current plan, there will be a 61% population growth over the next
Stop TxDOT I-45 Public Comments for Amendments to the 2045 RTP
25 years, with a 61% increase in vehicles, and an increase of more than 100,000,000
VMT. When logic is applied, it is evident that a transportation forced to absorb 61%
more vehicles would be crippled far beyond the existing congestion rates. RTP 2045
should plan for future population growth using methods that efficiently move the
population, which is not with single occupant vehicles. The transportation infrastructure
built between now and 2045 is one of the most influential drivers of vehicle ownership.
Again, please remember that the purpose of long-range transportation plans, such
as RTP 2045, is to provide the public with a vision for the region. The vision that RTP
2045 presents is increased population, VMTs, congestion without identifying any
programs or strategy for improving air quality and health outcomes.
To address this, we request/ recommend:
• Prioritize transportation modes, such as biking, walking, electric vehicles, and public
transportation over road expansion and single occupancy vehicle travel that will
worsen air quality.
13. Consider Greenhouse Gasses
The federal air standards do not yet regulate greenhouse gasses (GHG). The question of
how and when GHG should be regulated, and added to the air quality standards, has
been actively considered by the Clinton, Bush, Obama, and Biden Administrations. With
greater concern over the climate crisis, there is reason to believe that GHG will be
assessed in the coming years. We saw no references to GHG in Air Quality/ Conformity
chapter.
To address this, we request/ recommend:
• Include discussion of GHG sources within the transportation sector;
• Set goals and strategies for reducing GHG emissions.
Thank you for your comment on the Regional Transportation Plan and Air Quality comment page. H-GAC values your input. The 61% growth in single -occupancy vehicle usage coming from fact sheet 2 (http://www.2045rtp.com/documents/2045-fact-sheet2.pdf) was developed as a promotional material for first round of public involvement meetings conducted during the development of 2045 RTP process in spring of 2018. 61% of estimated population growth was applied to vehicle ownership (5.5 million) data from 2017. This estimated vehicle ownership growth was not used in the project selection process. The agency provides a public data lab (Link) and documentation (Link) explaining its forecasting processes.
For your comment regarding Chapter 6 of the RTP document, H-GAC will consider the addition of more air quality information on this chapter in the next conformity determination.
Also, for our next conformity determination, H-GAC will consider the addition of a discussion regarding air quality standards, air quality control strategies for mobile sources, and air pollution and health effects.
For your comment regarding the relation between the national ambient air quality standard (NAAQS) and the motor vehicle emission budgets (MVEBs), here is our explanation: The air quality state implementation plan (SIP) is the state's comprehensive plan to clean the air and meet federal air quality standards. Our region is in nonattainment for ozone and TCEQ is the state agency to prepare the air quality SIP. To prepare the SIP, the state agency must consider all sources of air pollution in the region, like industrial emissions, mobile on-road emissions, non-road emissions (construction equipment}, off-road emissions (locomotives, airports, commercial marine), area emission (residential and small business). The emission inventories for the sources of air pollution are generated and input into the photochemical model to get the concentration of ozone for the attainment year. Air quality control strategies are being also included into the model to attain the standard. Based on this exercise, on-road mobile sources get a quota of up to how much they can emit to reach the standard and that quota is called the Motors Vehicle Emission Budget (MVEB). Conformity is the exercise that shows that all the emissions coming from the transportation plan for a given year do not exceed the MVEB, in other words, the emissions coming from the transportation plan do not delay the attainment of the ozone standard.
For your comment regarding why the VMT goes up while the emissions go down in future years, these emissions reductions are due primarily to fleet turn over and the implementation of new federal standards. The Tier 2 emission standards implemented in 2004 for light duty gasoline vehicles and light duty gasoline trucks show emission reductions of up to 95% in NOx versus Tier 1 vehicles. In addition, the Clean Diesel federal rule, which was implemented in 2006 for heavy duty diesel vehicles, shows an emission reduction of 96% in NOx versus previous standards. The Tier 3 vehicle standards implemented between 2017 and 2025 reduces both tailpipe and evaporative emissions from passenger cars, light-duty trucks, medium-duty passenger vehicles and some heavy-duty vehicles. Once fully implemented, smog-forming volatile organic compounds and nitrogen oxides will be reduced by 80% from current levels, particulate matter will be reduced by 70%, and fuel vapor emissions will be driven to near zero levels. For more information on the emission reductions and the implementation timeline for these rules, please refer to the following EPA websites:
https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-light-duty-vehicles-and-trucks-and
https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-heavy-duty-highway-engines-and-vehicles
https://theicct.org/sites/default/files/publications/ICCTupdate_Tier3_NPRM.pdf
Due to all the above emission standards for vehicles, the emissions in the transportation plan are being reduced in the future years due to fleet over turn although the VMT keeps increasing due to population increase.:
The analysis of projects regarding their GHGs emissions is not required for a conformity determination. However, the federal government may require this analysis in the future for project selection and H-GAC will be happy to comply.
For your comment regarding the use of acronyms, H-GAC has a list of acronyms in the conformity website.
See response to you comments on NHHIP Segment 3, SH99, Highway 36A, Hempstead Road and IH 10 W/Inner Katy from TxDOT below
IH 45, Segment 3 (North Houston Highway Improvement Project)
Segment 3 of the of the NHHIP is already included in the 2045 RTP. This amendment includes a change to the existing project. The Federal Highway Administration's review of the NHHIP does not preclude the project's inclusion in the 2045 RTP.
SH 99
The current and projected travel demand on SH 99 warrants improvements to ensure continued mobility and safety in the corridor.
36A
36A North: (MPOID 18720) and 36A South: (0912-72-544, MPOID 18719)
At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. Our study methodology always seeks to avoid potential impacts. If impacts cannot be reasonably avoided, we try to minimize the impact; and only then do we mitigate the impacts of a project. This alternatives alignment process is very prescribed and consistent with federal and state practices. The process also includes extensive stakeholder and public engagement.
Hempstead
The Hempstead project from I-610 to BW 8 currently exists in the 2045 RTP. Hempstead Road between I-610 and Beltway 8 will undergo a feasibility study to determine potential scope changes. The study has not commenced, but it will include significant stakeholder and public involvement. Texas Central does not have authority to perform or approve a TxDOT project. TxDOT has had multple meetings with the Texas Central team. The Texas Central team will continue to be consulted as a stakeholder during the Hempstead feasibility study.
Inner Katy:
The Inner Katy (I10) corridor from I610 to the Central Business District is a high-volume corridor in terms of passenger and freight movement with limited right of way for future improvements. METRO's Inner Katy BRT project will impact the State's right of way and the interstate facility; therefore, TxDOT initiated a corridor study to evaluate the future needs of the State's system in this segment of roadway. TxDOT is coordinating the corridor study with METRO's proposed Inner Katy BRT project to ensure a shared vision that doesn't prohibit future opportunities or improvements. TxDOT"s goal is always to avoid, minimize, and only then to mitigate possible impacts to the human and natural environment. TxDOT is committed to on-going stakeholder and public engagement as this project progresses over the years from the planning phase to design. TxDOT identified improvement concepts are not expected to affect METRO's implementation of their Inner Katy BRT project. There may, however, be some partnership opportunities that must be considered through both agencies' efforts.
Has Texas Central approved the Hempstead Road elevated managed lanes project? Why
would we build a highway right next to US290? Please provide record of input from Texas
Central on project #18706 and justification for 18701, 18703, 18704, and 18705.
Thank you for your input. We will take those comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: The Hempstead project from I-610 to BW 8 currently exists in the 2045 RTP. Hempstead Road between I-610 and Beltway 8 will undergo a feasibility study to determine potential scope changes. The study has not commenced, but it will include significant stakeholder and public involvement. Texas Central does not have authority to perform or approve a TxDOT project. TxDOT has had multiple meetings with the Texas Central team. The Texas Central team will continue to be consulted as a stakeholder during the Hempstead feasibility study.
I believe TXDOT has proven time and time again that it is an out of touch entity that does not know what is best for houstonians and the way in which we need to travel within our city. We need local oversight over any and all projects transportation projects for our city not only because we deserve the most efficient method of transportation but we also need a system that is conscious of flooding, air pollution and conserves our communities and green spaces. TXDOT has proven it cannot handle that duty please relinquish their oversight to the citizens. We know what's best for our home.
Thank you for your input. We will take those comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: Thanks for your input. TxDOT's responsibilities cover the entire State system with more than 80,000 centerline miles of roadway including interstate, US, and State highways, FM roads, frontage roads, and park roads. Each year, the State system carries people and freight more than 203 billion miles. While only 26 percent of the roadways in Texas are State owned, the State system carries 72 percent of all vehicles miles traveled. the Houston District is a microcosm of the State statistics including just under 3,500 centerline miles and more than 100 million miles traveled in fiscal year 2020. This transportation system is vital to the population and economic growth of the region and has national significance in moving people and goods.
Hello, my name is Chloe and I’m a resident here in Houston (77092). I’m giving a public comment in order to make my opposition to the proposed 2045 plan heard. For far too long, Houston has emphasized freeway expansion in the name of “reducing traffic”. However, the latent effects of this continuous behavior have been a serious detriment to our community. Over the years, freeways in Houston have bred community division, enforced legal segregation AND de-facto segregation, polluted our habitat, and destroyed the homes and businesses of thousands. All the while doing nothing to reduce traffic. I am here to demand NO MORE. If we want to have a better future in Houston, a future that prioritizes the health, safety, and well-being of its residents, then we MUST transition away from these types of projects. It’s long overdue. Houston desperately needs more pedestrian methods of transportation, and I sure hope that in 2045, our future holds something more than another expansion/ creation of these massive freeways. The citizens you represent are demanding change, and it’s in the best interest of the entire Houston Metro area to come up with new ideas to fit our changing world.
Thank you for your interest in the 2045 RTP. H-GAC appreciates you taking the time to express your concerns. These comments will be considered for the 2050 RTP.
As a citizen of Houston, TX I am commenting to express my concern with some of the content of the 2045 RTP and its amendments, specifically around the issue of air quality. You claim that all of the proposed projects will be compliant with EPA standards, but we know that we have some of the worst air quality in the nation. I do not believe that the RTP accurately addresses air quality concerns. I request that HGAC provide a clear assessment of the area's air quality, explain the relationship between the two different air quality standards in question (the EPAs NAAQs ozone standard and TCEQ’s MVEB target), and finally I ask that you include discussion of air quality related health risks and benefits. How will the projects proposed affect our air quality and what is HGAC's plan to make sure that the air quality meets EPA standards now and in the future?
Thank you for submitting comments regarding air quality conformity.
For the next conformity determination, H-GAC will consider the addition of a discussion regarding air quality standards, air quality control strategies for mobile sources, and air pollution and health effects.
Regarding your comment about how the national ambient air quality standar (NAAQS) relates to the motor vehicle emission budgets (MVEBs),here is H-GAC's answer: the air quality state implementation plan (SIP) is the state's comprehensive plan to clean the air and meet federal air quality standards. Our region is in nonattainment for ozone and TCEQ is the state agency to prepare the air quality SIP. To prepare the SIP, the state agency must consider all sources of air pollution in the region, like industrial emissions, mobile on-road emissions, non-road emissions (construction equipment}, off-road emissions (locomotives, airports, commercial marine), area emission (residential and small business). The emission inventories for the sources of air pollution are generated and input into the photochemical model to get the concentration of ozone for the attainment year. Air quality control strategies are being also included into the model to attain the standard. Based on this exercise, on-road mobile sources get a quota of up to how much they can emit to reach the standard and that quota is called the Motors Vehicle Emission Budget (MVEB). Conformity is the exercise that shows that all the emissions coming from the transportation plan for a given year do not exceed the MVEB, in other words, the emissions coming from the transportation plan do not delay the attainment of the ozone standard.
This is not a project with the best and future interests of Texas city citizens in mind. It is wholly to suit the desires if developers and people who will not be affected by the gross mismanagement of funding, land, and organization. Moreover, orienting an incredibly expensive project around a dying thing -- cars and fossil fuels -- is a bad plan regardless. STOP THIS. LET CITIZENS DECIDE.
Thank you for your interest in the 2045 RTP. H-GAC appreciates you taking the time to express your concerns. These comments will be considered for the 2050 RTP.
I have a few questions and comments about the RTP amendment.
The population growth projects show 61% population growth to 2045. I don't understand the assumption behind the corresponding 61% increase in vehicle ownership. How is single passenger vehicle ownership corresponding exactly to population increase a given? If Houston area development emphasizes walk-ability and access to transit over the next 25 years, wouldn't demand for single passenger vehicles decrease, or at least not grow at the same rate as population? Conversely if we emphasize single passenger vehicle projects, aren't we essentially ensuring that the associated prediction would happen by inducing demand? Can any of our roadway infrastructure accommodate a 61% increase in single passenger vehicles? That sounds like a number that would completely cripple our transportation infrastructure. When NYC sees population growth, I guarantee there isn't a corresponding 1 to 1 increase in vehicle ownership.
I would also like clarification on the emissions standards and modeling. What are the differences between standards set by the EPA and Texas? Why are we listed as conforming when the EPA is changing our classification to being a serious non-attainer? Why is there a large predicted decrease in regional emissions despite a large increase in vehicle ownership and vehicle miles traveled? Improvements in combustion and stop start technology could conceivably yield maybe a 10-15% reduction in emissions over the next 25 years, but I don't understand the models HGAC is using for emissions. Is electric vehicle adoption included in the projections? I'm also confused as to how we track total emissions as a region vs just from transportation. Can you clarify some of these differences? I also saw no reference to greenhouse gases, are these incorporated somewhere? There also seems to be no discussion of the regions health costs and effects due to pollution. This part of the document is confusing and difficult to understand from a general public perspective.
As for the projects themselves, I'm disappointed to see that most of them seem to be focused on single passenger vehicles to the detriment of transit, bicycling, and walking. I want to see this body take a more holistic view of development and transportation. SH99 was completed less than 10 years ago and it already needs a major lane expansion? How do Hempstead road elevated lanes relate to a high speed rail project?
For us to be a region that is more livable, economically, and environmentally sustainable, we have to reduce our vehicle miles traveled. We can accomplish this by encouraging walk-able development, and prioritizing other transportation modes in our planning process beyond simply single passenger vehicles. I would like our RTP process to reflect this.
The 2045 RTP is made up of numerous plans including the Regional Active Transportation Plan, Regional Safety plan, Regional Coordinated Transportation Plan, Congestion Mitigation Air Quality Plan, to list a few. All these plans can be found in the appendix of the document http://www.2045rtp.com/documents.aspx.
Regarding your question on why the vehicle emissions decreases as the VMT increases: These emissions reductions are due primarily to fleet turn over and the implementation of new federal standards. The Tier 2 emission standards implemented in 2004 for light duly gasoline vehicles and light duty gasoline trucks show emission reductions of up to 95% in NOx versus Tier 1 vehicles. In addition, the Clean Diesel federal rule, which was implemented in 2006 for heavy duty diesel vehicles, shows an emission reduction of 96% in NOx versus previous standards. The Tier 3 vehicle standards implemented between 2017 and 2025 reduces both tailpipe and evaporative emissions from passenger cars, light-duty trucks, medium-duty passenger vehicles and some heavy-duty vehicles. Once fully implemented, smog-forming volatile organic compounds and nitrogen oxides will be reduced by 80% from current levels, particulate matter will be reduced by 70%, and fuel vapor emissions will be driven to near zero levels
For more information on the emission reductions and the implementation timeline for these rules, please refer to the following EPA websites:
https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-light-duty-vehicles-and-trucks-and
https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-heavy-duty-highway-engines-and-vehicles
https://theicct.org/sites/default/files/publications/ICCTupdate_Tier3_NPRM.pdf
Due to all the above emission standards for vehicles, the emissions in the transportation plan are being reduced in the future years due to fleet over turn although the VMT keeps increasing due to population increase.
Regarding your comment on the relation between the national ambient air quality standard (NAAQS) and the motor vehicle emission budgets (MVEBs), here is H-GAC 's answer: The air quality state implementation plan (SIP) is the state's comprehensive plan to clean the air and meet federal air quality standards. Our region is in nonattainment for ozone and TCEQ is the state agency to prepare the air quality SIP. To prepare the SIP, the state agency must consider all sources of air pollution in the region, like industrial emissions, mobile on-road emissions, non-road emissions (construction equipment}, off-road emissions (locomotives, airports, commercial marine), area emission (residential and small business). The emission inventories for the sources of air pollution are generated and input into the photochemical model to get the concentration of ozone for the attainment year. Air quality control strategies are being also included into the model to attain the standard. Based on this exercise, on-road mobile sources get a quota of up to how much they can emit to reach the standard and that quota is called the Motors Vehicle Emission Budget (MVEB). Conformity is the exercise that shows that all the emissions coming from the transportation plan for a given year do not exceed the MVEB, in other words, the emissions coming from the transportation plan do not delay the attainment of the ozone standard.
Regarding your question about GHGs: the analysis of projects regarding their GHGs emissions is not required for a conformity determination. However, the federal government may require this analysis in the future for project selection.
For our next conformity determination, H-GAC will consider the addition of a discussion regarding air quality standards, air quality control strategies for mobile sources, and air pollution and health effects.
The proposed amendment to the 2045 RTP represents the continuation of failed transportation policy. This plan has the opportunity to determine future mobility outcomes, and yet RTP factsheets indicate an assumed 61% increase in vehicles with a 61% increase in population. The RTP should be including projects that prevent such an unstainable increase in vehicles by moving future residents more efficiently via busses and trains. Please provide data driven justification for the estimated 61% increase in vehicles.
Segment 3 of the NHHIP should not be included in the proposed amendment due to the FHWA and USDOT instructing TXDOT to pause work on the project. Why is segment 3 included in the amendment?
SH99 from I-10 to Holzwarth road was completed less than ten years ago and there is already a proposed expansion project. The Grand Parkway exacerbates destruction of critical natural flood control watersheds in the Katy Prairie. Expanding this toll road less than ten years after construction is proof of our failed transportation strategies. Furthermore, this project does not improve walk-ability in and around the intersections of surface streets and SH-99. The RTP needs to be directing funds to projects that will be effective for longer than ten years.
I will echo the Katy Prairie Conservancy's comments on SH36A. This project is ambiguous and problematic. We must protect our prairieland ecosystems and watersheds. Please provide justification for this roadway.
Has Texas Central approved the Hempstead Road elevated managed lanes project? Why
would we build a highway right next to US290? Please provide record of input from Texas
Central on project #18706 and a diagram indicating how proposed project #18706 is required to accommodate the Texas Central project. Additionally, please provide traffic model justification for projects 18701, 18703, 18704, and 18705.
Based on the Chapter 6: Air Quality Conformity document, the projects in the 2045 RTP and the proposed amendment will increase total vehicle miles traveled by roughly 50% over the next 25 years. This prediction diverges from the City of Houston and Harris County's stated intent to reduce total VMTs in our region. The majority of the residents in the HGAC area live in Harris county. Why does the RTP not adopt the intentions of the governing body that oversees the majority of residents in the area? Please provide correspondence with COH and Harris county planners that show they align with the RTP's proposed VMT increase over time.
On the topic of increasing VMTs, statistically speaking more VMTs and more vehicle lane miles will result in more crashes in our region. The city of Houston has signed on to the Vision Zero intitiative, as has the Texas Transportation Commission. Please explain how increasing VMTs and lane miles in our region will reduce crashes and traffic fatalities. Reminder: The TTC has pledged to reduce traffic fatalities to 50% of current levels by 2030.
The interaction of the TCEQ's MVEB and the EPA's NAAQS "Serious non-attainer" standard is confusing. Please provide a clearer explanation of the Houston-Galveston-Brazoria region's annual emissions non-attainment under the NAAQS standard and how the TCEQ's Motor Vehicle Emissions Budget falls within the EPA limits.
Please explain how with a sizable increase in VMTs our region will see a substantial decrease in NOx and VOC over the next 20 years and why after 20 years emissions will rise again. (Referring to Chapter 6, air quality conformity)
In summary, please provide the public with the following information:
1. data driven justification for the estimated 61% increase in vehicles
2. Justification for inclusion of NHHIP Segment 3 in the proposed amendment
3. Explanation why SH36A is a needed roadway, and the final footprint of the road
4. Documented input from Texas Central on their involvement and approval of project #18706, as well as a diagram of the Texas Central railway project ROW and the proposed Hempstead Road managed lanes project (18706) illustrating the need for 18706.
5. Justification for projects 18701, 18703, 18704, and 18705.
6. Documented correspondence with COH and Harris county planners that show they support the RTP's proposed VMT increase over time.
7. Data behind how an increase in total VMTs can reduce traffic fatalities, something TxDOT (under the direction of the TTC) has pledged to do.
8. A clearer explanation of the relationship between EPA regional non-attainer emission standards and the compliance of transportation emissions projections within the EPA ceiling.
9. Explanation of how emissions can be reduced with an increase of VMTs over time.
Thank you for your comment on the Regional Transportation Plan and Air Quality comment page. H-GAC values your input. The 61% growth in single -occupancy vehicle usage coming from fact sheet 2 (http://www.2045rtp.com/documents/2045-fact-sheet2.pdf) was developed as a promotional material for first round of public involvement meetings conducted during the development of 2045 RTP process in spring of 2018. 61% of estimated population growth was applied to vehicle ownership (5.5 million) data from 2017. This estimated vehicle ownership growth was not used in the project selection process. The agency provides a public data lab (Link) and documentation (Link) explaining its forecasting processes.
The NHHIP is included in the Regional Transportation Plan, TxDOT only seeks to update the existing project. Texas Central is not responsible for the approval of capital projects, nor is the organization’s input required. The Hempstead Road construction will provide traffic an alternate route to US 290.
As stated in Transportation Policy Council Resolution 2014-01 (attachment) “the Katy Prairie is a significant natural regional resource that should be preserved and enhanced for the benefit of current and future generations and, although all feasible alternatives should be investigated in this study, it is neither the intention nor in the regional interest to build 36A on land that is currently under control or ownership of the Katy Prairie Conservancy.” H-GAC is committed to an inclusive “grass roots” planning process utilizing the guidance of key stakeholders at the corridor and segment level.
City of Houston and Harris County Planners are part of the subcommittees and Transportation Advisory committee that provides guidance and advice to H-GAC staff on a regular basis. You can see City of Houston’s comments on proposed amendments to the 2045 RTP (letter) posted on our website at https://www.h-gac.com/getmedia/c2ad2cd0-2a93-439e-9ed9-c29d3c5ba72a/COH-Comments-RTP-Amendments-4-16-2021.pdf.
Regarding your comment on the relation between the national ambient air quality standard (NAAQS) and the motor vehicle emission budgets (MVEBs), here is H-GAC's answer: The air quality state implementation plan (SIP) is the state's comprehensive plan to clean the air and meet federal air quality standards. Our region is in nonattainment for ozone and TCEQ is the state agency to prepare the air quality SIP. To prepare the SIP, the state agency must consider all sources of air pollution in the region, like industrial emissions, mobile on-road emissions, non-road emissions (construction equipment}, off-road emissions (locomotives, airports, commercial marine), area emission (residential and small business). The emission inventories for the sources of air pollution are generated and input into the photochemical model to get the concentration of ozone for the attainment year. Air quality control strategies are being also included into the model to attain the standard. Based on this exercise, on-road mobile sources get a quota of up to how much they can emit to reach the standard and that quota is called the Motors Vehicle Emission Budget (MVEB). Conformity is the exercise that shows that all the emissions coming from the transportation plan for a given year do not exceed the MVEB, in other words, the emissions coming from the transportation plan do not delay the attainment of the ozone standard. For our next conformity determination, H-GAC will consider the addition of a discussion regarding air pollution and health effects.
Regarding your question on why the vehicle emissions decreases as the VMT increases: These emissions reductions are due primarily to fleet turn over and the implementation of new federal standards. The Tier 2 emission standards implemented in 2004 for light duly gasoline vehicles and light duty gasoline trucks show emission reductions of up to 95% in NOx versus Tier 1 vehicles. In addition, the Clean Diesel federal rule, which was implemented in 2006 for heavy duty diesel vehicles, shows an emission reduction of 96% in NOx versus previous standards. The Tier 3 vehicle standards implemented between 2017 and 2025 reduces both tailpipe and evaporative emissions from passenger cars, light-duty trucks, medium-duty passenger vehicles and some heavy-duty vehicles. Once fully implemented, smog-forming volatile organic compounds and nitrogen oxides will be reduced by 80% from current levels, particulate matter will be reduced by 70%, and fuel vapor emissions will be driven to near zero levels
For more information on the emission reductions and the implementation timeline for these rules, please refer to the following EPA websites:
https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-light-duty-vehicles-and-trucks-and
https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-heavy-duty-highway-engines-and-vehicles
https://theicct.org/sites/default/files/publications/ICCTupdate_Tier3_NPRM.pdf
Due to all the above emission standards for vehicles, the emissions in the transportation plan are being reduced in the future years due to fleet over turn although the VMT keeps increasing due to population increase.
Please see response to your comment on NHHIP, SH 99, Highway 36A, and Hempstead Road projects from TxDOT below.
IH 45, Segment 3 (North Houston Highway Improvement Project)
Segment 3 of the of the NHHIP is already included in the 2045 RTP. This amendment includes a change to the existing project. The Federal Highway Administration's review of the NHHIP does not preclude the project's inclusion in the 2045 RTP.
SH 99
The current and projected travel demand on SH 99 warrants improvements to ensure continued mobility and safety in the corridor.
36A
36A North: (MPOID 18720) and 36A South: (0912-72-544, MPOID 18719)
At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. Our study methodology always seeks to avoid potential impacts. If impacts cannot be reasonably avoided, we try to minimize the impact; and only then do we mitigate the impacts of a project. This alternatives alignment process is very prescribed and consistent with federal and state practices. The process also includes extensive stakeholder and public engagement.
Hempstead
The Hempstead project from I-610 to BW 8 currently exists in the 2045 RTP. Hempstead Road between I-610 and Beltway 8 will undergo a feasibility study to determine potential scope changes. The study has not commenced, but it will include significant stakeholder and public involvement. Texas Central does not have authority to perform or approve a TxDOT project. TxDOT has had multiple meetings with the Texas Central team. The Texas Central team will continue to be consulted as a stakeholder during the Hempstead feasibility study.
We Houstonians request and demand more Metro Rail lines, and more rapid bus services. Our current public transportation lines do not cover enough ground and it makes no sense that the rapid Silver Line was placed in the wealthy predominantly white area (galleria). What we Houstonians are need is all current Metro Rail lines (red, green, and purple) to connect to our airports. Additionally we would like to propose a new Metro Rail or Rapid Bus Service line to connect Maine Medical Plaza@South Main Street to Trotter (JT) Park@Little York Road. This potential route could use Alt 90, 69th Street, and Wayside drive as its route. This new line would be a dream come true for all Houstonians, as it covers lots of ground and connects many neighborhoods. I hope you will consider this proposal that would move 1000s of Houstonians around the city and cut transportation costs for our citizens.
Needs Response from METRO
With a 61% increase in population, the H-GAC assumes a 61% increase in single-occupancy vehicle usage. Projects in the RTP should be determining future outcomes, not being influenced by presumed outcomes. Please provide a data based justification used to estimate a 61% increase in vehicle usage?
The Proposed Amendment to the 2045 RTP should not include Segment 3 of the NHHIP because of the FHWA’s and USDOT’s pause of the project.
Has Texas Central approved the Hempstead Road elevated managed lanes project? Why would we build a highway right next to US290? Please provide record of input from Texas Central on project #18706, and justification for 18701, 18702, 18703, 18704, and 18705.
Please provide and explain the relationship between the two air quality standards in question—the EPA’s NAAQS ozone standard and TCEQ’s MVEB targets
Please include discussion of air quality related health risks and benefits
Thank you for your comment on the Regional Transportation Plan and Air Quality comment page. H-GAC values your input. The 61% growth in single -occupancy vehicle usage coming from fact sheet 2 (http://www.2045rtp.com/documents/2045-fact-sheet2.pdf) was developed as a promotional material for first round of public involvement meetings conducted during the development of 2045 RTP process in spring of 2018. 61% of estimated population growth was applied to vehicle ownership (5.5 million) data from 2017. This estimated vehicle ownership growth was not used in the project selection process. The agency provides a public data lab (Link) and documentation (Link) explaining its forecasting processes.
The NHHIP is included in the Regional Transportation Plan, TxDOT only seeks to update the existing project. Texas Central is not responsible for the approval of capital projects, nor is the organization’s input required. The Hempstead Road construction will provide traffic an alternate route to US 290.
Regarding your comment on the relation between the national ambient air quality standard (NAAQS) and the motor vehicle emission budgets (MVEBs), here is H-GAC's answer: The air quality state implementation plan (SIP) is the state's comprehensive plan to clean the air and meet federal air quality standards. Our region is in nonattainment for ozone and TCEQ is the state agency to prepare the air quality SIP. To prepare the SIP, the state agency must consider all sources of air pollution in the region, like industrial emissions, mobile on-road emissions, non-road emissions (construction equipment}, off-road emissions (locomotives, airports, commercial marine), area emission (residential and small business). The emission inventories for the sources of air pollution are generated and input into the photochemical model to get the concentration of ozone for the attainment year. Air quality control strategies are being also included into the model to attain the standard. Based on this exercise, on-road mobile sources get a quota of up to how much they can emit to reach the standard and that quota is called the Motors Vehicle Emission Budget (MVEB). Conformity is the exercise that shows that all the emissions coming from the transportation plan for a given year do not exceed the MVEB, in other words, the emissions coming from the transportation plan do not delay the attainment of the ozone standard. For our next conformity determination, H-GAC will consider the addition of a discussion regarding air pollution and health effects.
Please see response to your comment on NHHIP and Hempstead Road projects from TxDOT below.
TxDOT Response: "IH 45, Segment 3 (North Houston Highway Improvement Project)
Segment 3 of the of the NHHIP is already included in the 2045 RTP. This amendment includes a change to the existing project. The Federal Highway Administration's review of the NHHIP does not preclude the projects inclusion in the 2045 RTP. "
Hempstead
The Hempstead project from I-610 to BW 8 currently exists in the 2045 RTP. Hempstead Road between I-610 and Beltway 8 will undergo a feasibility study to determine potential scope changes. The study has not commenced, but it will include significant stakeholder and public involvement.
Dear Houston-Galveston Area Council,
Thank you for the opportunity to comment. I was disappointed to read the updated “Air Quality” (as it is titled in the RTP 2045 table of comments)/ “Transportation Conformity” chapter as it misrepresents the region’s air quality status and provides no strategy for how the region must address the serious nonattainment ozone designation.
I request for the following issues to be addressed:
1. Currently, discussion of conformity and the region’s ability to “meet” TCEQ’s MVEBs accounts for the majority of the Air Quality chapter. For example, 3 pages (of a 7 page long) document are dedicated to charts and tables on how the region meets MVEBs while no similar data, charts, or tables regarding the NAAQS ozone standard are included. This imbalance of information gives the reader the false impression that the region meets federal air quality requirements, when in fact, it does not. This should be corrected by providing more information on the NAAQS ozone standard. At a minimum, the region’s ozone design-value chart should be included.
2. The HGB region is designated by the EPA to be in “serious nonattainment” for the criteria pollutant, ozone. This designation demands a strategy for how the region will improve its air quality. Yet, I see no information or plans to this effect within any part of the RTP, including the Air Quality Chapter. Please provide a strategy, including programs, policies, and goals, for how the region intends to meet attainment for the federal 2008 and 2015 ozone standards.
3. The NAAQS were created to protect public health, yet Chapter 6 includes no discussion of air quality related health risks and concerns for the region. Please address health, in particular asthma and respiratory ailments, within the Chapter. The discussion/ analysis should include information on the relationships between asthma rates and proximity to transportation infrastructure and how asthma is being addressed as an environmental justice issue.
Thank you for submitting comments regarding air quality conformity.
For your comment regarding Chapter 6 of the RTP document, H-GAC will consider the addition of more air quality information on this chapter in the next conformity determination.
Also, for our next conformity determination, H-GAC will consider the addition of a discussion regarding air quality standards, air quality control strategies for mobile sources, and air pollution and health effects.
Environmental justice issues regarding air pollution are not required to be included in the conformity report. However, the 2045 RTP has an environmental justice program where you are invited to participate WEBSITE
Thank you for the opportunity to provide public comment on H-GAC’s 2045 Regional Transportation Plan (RTP). The RTP is an important regional planning tool, focusing on regional mobility, congestion mitigation, quality of life, safety and efficient movement of goods. We greatly appreciate the work undertaken to produce such a plan.
We enthusiastically support the following proposed amendments to the 2045 RTP:
• 18719, 18720 – 36A
• 18723 – 18726 – SH 99 Widening
• 18727 – Widening of Frontage Roads
• 16328 – Existing NHHIP Segment 3
• 18701 – 18706 – Hempstead Road Improvements
36A – Although outside of the NHA service area, this project will improve mobility in the region. This route provides an efficient and expanded transportation and freight route from Port Freeport to US 290. In addition to improving daily mobility, the project also improves safety since State Highway 36 is a primary evacuation route from southern Brazoria County.
SH 99 Widening – SH 99 is a highly-utilized highway in north Houston and is in need of widening in the segments outlined from four to six lanes. This widening will help mitigate congestion as well as support operational efficiency.
Widening of Frontage Roads East of Hardy Toll Rd to East of Aldine Westfield – this frontage road is frequently congested, and direct connectors between Beltway 8 and the Hardy Toll Road are much needed.
Existing NHHIP Segment 3 – Although outside of the NHA service area, the completion of Segment 3 of the North Houston Highway Improvement Project makes possible further improvements northward in this much-congested corridor. Commuters in north Harris County and Montgomery County need improved access to the major business centers in Houston, including dual-directional HOV lanes which improves mass transit options. Additionally, I-45 is the primary evacuation route, which is a critical safety issue.
Hempstead Road Improvements – Includes reconstruction, construction of managed lanes and the addition of a transit lane in each direction.
As an advocate for issues in northern Harris and Montgomery Counties, the North Houston Association is actively involved in regional mobility issues, and we appreciate the opportunity to provide input on the H-GAC 2045 RTP.
Thank you for your input. We will take those comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: Thank you for your input.
City of Pearland comments regarding the proposal from TxDOT to add the SH35 Corridor from I-610 to SH-99 to the H-GAC Regional Transportation Plan (RTP)
April 27, 2021
On April 26, 2021, TxDOT representatives provided a briefing on the SH35 Corridor (I-610 to Future SH99) to the Pearland City Council. The Council provided input and discussion on the proposed freeway. The general sense of the discuss was there was not a need for the project locally or regionally and that the detrimental impacts to the community outweigh any mobility benefits.
Based on Council and staff input, the City of Pearland is submitting the following comments regarding the proposed RTP Amendment that will add the SH35 Corridor project to the RTP:
1. An elevated freeway is not an option for Pearland along the existing BNSF rail corridor due to its impacts on:
a. Existing Development – The SH35 and Mykawa Road corridors are high value employment and investment areas with room for additional growth. The freeway will cause permanent economic disruption by eliminating much of this value and negatively impacting future growth.
b. Aesthetics – Pearland has long-range plans for the SH35 corridor and revitalization of the Old Town area already underway that are not compatible with and will be diminished in value with an adjacent freeway.
c. Long term detrimental impacts – Long term impacts to other communities that were divided by similar freeways after the areas were developed irreparably ruptured those communities (see communities divided by the Hardy Tollroad, SH59, I-10, etc.). We do not want that for Pearland. The benefits are for communities to the south while the detrimental impacts to Pearland are significant and unlikely to be overcome
d. Noise Pollution – The City of Pearland worked with BNSF Railroad for a decade and spent over $40M building three overpasses and three at-grade intersection with supplemental safety measures to implement a “Quiet Zone” throughout Pearland where the trains do not use their horns within our community. A freeway, elevated or not, will bring constant noise levels approaching the volume of train horns.
2. Pearland questions the need for a freeway at all (elevated or other) and the assumptions the growth projections are based upon are outdated and have flaws, such as:
a. SH35 Corridor where it has already been expanded to six lanes in Pearland (BW8 to FM518) does not have am or pm peak capacity of Level of Service issues.
b. The need for the freeway is based on the antiquated hub and spoke Central Business District (CBD) model. This model served the transportation needs of outlying areas reaching the CBD to the detriment of the communities it divided. The Houston metro area today has many business districts and destinations and is not in need of an additional freeway into downtown, especially where the necessary right-of-way was not preserved. Additionally, many corporations located in Houston are moving permanently to a work from home model in response to the COVID-19 pandemic and the evolving real estate market downtown.
c. The growth percentages (2018-2045) to the south of Pearland are flawed and skewed due to the low existing population numbers in the Hastings Oilfield area. Pearland staff requested TxDOT provide actual number of population growth and to present that data to City Council however only the percentages were used.
d. The growth projections do not consider the changing commuting patterns and the future of work for 2045. Where does H-GAC get their data on where people work? They should be engaging with developers to have a better understanding of where people will be working in the future and therefore be able to better determine where they will live and the resulting commuting patterns.
e. The much better option for connecting the SH35 Bypass in Alvin to the freeway system is completing SH99 to I-45. The benefits are a shorter route (less costs) and the right-of-way has been preserved or traverses open land with little to no development minimizing the disruptions to businesses and residents.
3. Existing Road Capacity Needs – Pearland has multiple existing State roadways that as of today, not 25 years into the future, have a lack of capacity, very high congestion, and safety issues. These roadways were identified in the Northern Brazoria County/Pearland Subregional Planning Initiative (SPI) conducted by H-GAC themselves to be the highest priority roadways in our area. The SPI include Pearland, Manvel, Iowa Colony, and Alvin. TxDOT should prioritize the use of their limited resources to address the corridors that have existing needs as identified in the SPI over a future freeway that has no clear sub-regional or regional need, only considers the needs of one community, has no available corridor to be built, and was not a priority in the SPI.
a. FM518 Widening (SH288 to FM865 (Cullen Pkwy) – No. 1 priority from the SPI. TxDOT has started design and land acquisition. Construction is scheduled to start in 2025. Need to ensure this project is fully funded and stays on schedule. It has already slipped from 2024.
b. SH35 Widening (FM518 to Alvin) – No. 2 priority from the SPI. This undivided high-speed corridor has the most significant safety issues in Brazoria County. No planning, design, or environmental clearance efforts have been started by TxDOT.
c. FM518 Widening (FM865 to SH35) – No. 5 priority from the SPI. TxDOT has started the environmental work and design but construction funds have not been allocated.
d. FM518 Widening (McLean to Walnut) – This short segment of FM518 is part of the No. 5 priority from the SPI but has been left out of the TxDOT project and environmental document due to the existing narrow right-of-way. The segment includes the intersection with SH35 and needs to be further evaluated to see if a one-way pair option is viable by using Walnut Street or other options should be considered. Instead of incorporating this analysis into the overall FM518 project, TxDOT has left this evaluation to the City. The City has requested funds from H-GAC for the analysis.
e. FM518 Widening (SH35 to Friendswood) – Although not identified and studied at the time the SPI was conducted, this segment of FM518 continues to experience high commercial/retail growth leading to traffic volumes surpassing volumes on the No. 5 SPI priority segment of FM518 between FM865 and SH35. No planning, design, or environmental clearance efforts have been started by TxDOT.
f. FM1128 Widening (FM518 to SH6) – No. 4 & 6 priorities from the SPI. This corridor will eventually connect SH6 to BW8, when the City completes the segment north of FM518. No planning, design, or environmental clearance efforts have been started by TxDOT for the FM518 to SH6 segment.
4. There will be little to no Evacuation Route benefits to Pearland, communities to the south, or the region because the SH35 corridor will just put evacuation traffic onto existing routes that are already inadequate for evacuation (BW8, I-610, I-45)
5. Crash Trends – The freeway will not solve the crash trends on the existing SH35 or Mykawa Road. To address, TxDOT should widen and implement safety measures in the areas with the highest crash rates. Where SH35 has been widened and safety measures have been implemented in Pearland, the crash rates are relatively low.
Thank you for your comment on the Regional Transportation Plan and Air Quality comment page. H-GAC values your input.
TxDOT Response: SH 35
The need for SH 35 improvements from Dixie Drive and continuing south to future SH99 is just beginning. The Texas Department of Transportation has scrapped the previous plans for S 35 and is staring over in the feasibility process. Our process for corridor studies involves both a quantitative and qualitative process that features extensive stakeholder and public engagement and input before finalizing a proposed improvement concept. We believe including the project in the 2045 RTP puts the public on notice that we intend to study the corridor because this corridor is vital to the transportation system. Improvements are anticipated to move people and good more reliably.
With a 61% increase in population, the H-GAC assumes a 61% increase in single-occupancy vehicle usage. Projects in the RTP should be determining future outcomes, not being influenced by presumed outcomes. Please provide a data based justification used to estimate a 61% increase in vehicle usage?
The Proposed Amendment to the 2045 RTP should not include Segment 3 of the NHHIP because of the FHWA’s and USDOT’s pause of the project.
Has Texas Central approved the Hempstead Road elevated managed lanes project? Why would we build a highway right next to US290? Please provide record of input from Texas Central on project #18706, and justification for 18701, 18702, 18703, 18704, and 18705.
Please provide and explain the relationship between the two air quality standards in question—the EPA’s NAAQS ozone standard and TCEQ’s MVEB targets
Please include discussion of air quality related health risks and benefits
Thank you for your comment on the Regional Transportation Plan and Air Quality comment page. H-GAC values your input. The 61% growth in single -occupancy vehicle usage coming from fact sheet 2 (http://www.2045rtp.com/documents/2045-fact-sheet2.pdf) was developed as a promotional material for first round of public involvement meetings conducted during the development of 2045 RTP process in spring of 2018. 61% of estimated population growth was applied to vehicle ownership (5.5 million) data from 2017. This estimated vehicle ownership growth was not used in the project selection process. The agency provides a public data lab (Link) and documentation (Link) explaining its forecasting processes.
The NHHIP is included in the Regional Transportation Plan, TxDOT only seeks to update the existing project. Texas Central is not responsible for the approval of capital projects, nor is the organization’s input required. The Hempstead Road construction will provide traffic an alternate route to US 290.
Regarding your comment on the relation between the national ambient air quality standard (NAAQS) and the motor vehicle emission budgets (MVEBs), here is H-GAC's answer: The air quality state implementation plan (SIP) is the state's comprehensive plan to clean the air and meet federal air quality standards. Our region is in nonattainment for ozone and TCEQ is the state agency to prepare the air quality SIP. To prepare the SIP, the state agency must consider all sources of air pollution in the region, like industrial emissions, mobile on-road emissions, non-road emissions (construction equipment}, off-road emissions (locomotives, airports, commercial marine), area emission (residential and small business). The emission inventories for the sources of air pollution are generated and input into the photochemical model to get the concentration of ozone for the attainment year. Air quality control strategies are being also included into the model to attain the standard. Based on this exercise, on-road mobile sources get a quota of up to how much they can emit to reach the standard and that quota is called the Motors Vehicle Emission Budget (MVEB). Conformity is the exercise that shows that all the emissions coming from the transportation plan for a given year do not exceed the MVEB, in other words, the emissions coming from the transportation plan do not delay the attainment of the ozone standard. For our next conformity determination, H-GAC will consider the addition of a discussion regarding air pollution and health effects.
Please see response to your comment on NHHIP and Hempstead Road projects from TxDOT below.
TxDOT Response: "IH 45, Segment 3 (North Houston Highway Improvement Project)
Segment 3 of the of the NHHIP is already included in the 2045 RTP. This amendment includes a change to the existing project. The Federal Highway Administration's review of the NHHIP does not preclude the projects inclusion in the 2045 RTP. "
Hempstead
The Hempstead project from I-610 to BW 8 currently exists in the 2045 RTP. Hempstead Road between I-610 and Beltway 8 will undergo a feasibility study to determine potential scope changes. The study has not commenced, but it will include significant stakeholder and public involvement.
My question on every single one of these projects is: where is the water going to go?
Twenty years ago, Sugar Land still had rice paddies, prairies, and marshes, and Meyerland didn’t flood. Now, where there were once open fields that would take the water in heavy rain, there is concrete that pushes the water into people’s homes. So, while TXDOT paid one price to build all those roads, we all pay a much higher price when HUD has to come in a pay to rebuild homes and businesses, as they have so many times in the past decade. There are too many million dollar homes in Houston that started out as $300,000 homes, but have been rebuilt three times this century, due to flooding. The people who live in homes that didn’t used to flood but now do flood obviously have paid and suffered the most, but we all pay when HUD subsidizes rebuilding, and we all pay for it in higher flood insurance premiums. So, I’d like to know if you could include the trauma tax in the original cost estimates for these projects.
I agree with everything that Katy Prairie Conservancy has stated. Further, I am interested how paving over prairie here will affect flooding in other parts of the region. What has been done to study how these new roads will affect flooding in heavy rain? Has anything been done to minimize or negate the negative effects?
What is being done to compensate home owners who are not in the direct path of the new roads, but whose homes will nonetheless be destroyed by flooding as a direct result of replacing flood control areas with highways?
Thank you for your participation and comment. We will take the points of your comment into consideration. As stated in Transportation Policy Council Resolution 2014-01 (attachment) “the Katy Prairie is a significant natural regional resource that should be preserved and enhanced for the benefit of current and future generations and, although all feasible alternatives should be investigated in this study, it is neither the intention nor in the regional interest to build 36A on land that is currently under control or ownership of the Katy Prairie Conservancy.” H-GAC is committed to an inclusive “grass roots” planning process utilizing the guidance of key stakeholders at the corridor and segment level.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. Our study methodology always seeks to avoid potential impacts. If impacts cannot be reasonably avoided, we try to minimize the impact; and only then do we mitigate the impacts of a project. This alternatives alignment process is very prescribed and consistent with federal and state practices. The process also includes extensive stakeholder and public engagement.
The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
With a 61% increase in population, the H-GAC assumes a 61% increase in single-occupancy vehicle usage. Projects in the RTP should be determining future outcomes, not being influenced by presumed outcomes. Please provide a data-based justification used to estimate a 61% increase in vehicle usage?
The Proposed Amendment to the 2045 RTP should not include Segment 3 of the NHHIP because of the FHWA’s and USDOT’s pause of the project.
Has Texas Central approved the Hempstead Road elevated managed lanes project? Why would we build a highway right next to US290? Please provide record of input from Texas Central on project #18706, and justification for 18701, 18702, 18703, 18704, and 18705.
Please provide and explain the relationship between the two air quality standards in question—the EPA’s NAAQS ozone standard and TCEQ’s MVEB targets
Please include discussion of air quality related health risks and benefits
Thank you for your comment on the Regional Transportation Plan and Air Quality comment page. H-GAC values your input. The 61% growth in single -occupancy vehicle usage coming from fact sheet 2 (http://www.2045rtp.com/documents/2045-fact-sheet2.pdf) was developed as a promotional material for first round of public involvement meetings conducted during the development of 2045 RTP process in spring of 2018. 61% of estimated population growth was applied to vehicle ownership (5.5 million) data from 2017. This estimated vehicle ownership growth was not used in the project selection process. The agency provides a public data lab (Link) and documentation (Link) explaining its forecasting processes.
The NHHIP is included in the Regional Transportation Plan, TxDOT only seeks to update the existing project. Texas Central is not responsible for the approval of capital projects, nor is the organization’s input required. The Hempstead Road construction will provide traffic an alternate route to US 290.
Regarding your comment on the relation between the national ambient air quality standard (NAAQS) and the motor vehicle emission budgets (MVEBs), here is H-GAC's answer: The air quality state implementation plan (SIP) is the state's comprehensive plan to clean the air and meet federal air quality standards. Our region is in nonattainment for ozone and TCEQ is the state agency to prepare the air quality SIP. To prepare the SIP, the state agency must consider all sources of air pollution in the region, like industrial emissions, mobile on-road emissions, non-road emissions (construction equipment}, off-road emissions (locomotives, airports, commercial marine), area emission (residential and small business). The emission inventories for the sources of air pollution are generated and input into the photochemical model to get the concentration of ozone for the attainment year. Air quality control strategies are being also included into the model to attain the standard. Based on this exercise, on-road mobile sources get a quota of up to how much they can emit to reach the standard and that quota is called the Motors Vehicle Emission Budget (MVEB). Conformity is the exercise that shows that all the emissions coming from the transportation plan for a given year do not exceed the MVEB, in other words, the emissions coming from the transportation plan do not delay the attainment of the ozone standard. For our next conformity determination, H-GAC will consider the addition of a discussion regarding air pollution and health effects.
Please see response to your comment on NHHIP and Hempstead Road projects from TxDOT below.
TxDOT Response: "IH 45, Segment 3 (North Houston Highway Improvement Project)
Segment 3 of the of the NHHIP is already included in the 2045 RTP. This amendment includes a change to the existing project. The Federal Highway Administration's review of the NHHIP does not preclude the projects inclusion in the 2045 RTP. "
Hempstead
The Hempstead project from I-610 to BW 8 currently exists in the 2045 RTP. Hempstead Road between I-610 and Beltway 8 will undergo a feasibility study to determine potential scope changes. The study has not commenced, but it will include significant stakeholder and public involvement.
* With a 61% increase in population, the H-GAC assumes a 61% increase in single-occupancy vehicle usage. Projects in the RTP should be determining future outcomes, not being influenced by presumed outcomes. Please provide a data based justification used to estimate a 61% increase in vehicle usage?
* The Proposed Amendment to the 2045 RTP should not include Segment 3 of the NHHIP because of the FHWA’s and USDOT’s pause of the project.
* Has Texas Central approved the Hempstead Road elevated managed lanes project? Why would we build a highway right next to US290? Please provide record of input from Texas Central on project #18706, and justification for 18701, 18702, 18703, 18704, and 18705.
* Please provide and explain the relationship between the two air quality standards in question—the EPA’s NAAQS ozone standard and TCEQ’s MVEB targets
* Please include discussion of air quality related health risks and benefits
Thank you for your comment on the Regional Transportation Plan and Air Quality comment page. H-GAC values your input. The 61% growth in single -occupancy vehicle usage coming from fact sheet 2 (http://www.2045rtp.com/documents/2045-fact-sheet2.pdf) was developed as a promotional material for first round of public involvement meetings conducted during the development of 2045 RTP process in spring of 2018. 61% of estimated population growth was applied to vehicle ownership (5.5 million) data from 2017. This estimated vehicle ownership growth was not used in the project selection process. The agency provides a public data lab (Link) and documentation (Link) explaining its forecasting processes.
The NHHIP is included in the Regional Transportation Plan, TxDOT only seeks to update the existing project. Texas Central is not responsible for the approval of capital projects, nor is the organization’s input required. The Hempstead Road construction will provide traffic an alternate route to US 290.
Regarding your comment on the relation between the national ambient air quality standard (NAAQS) and the motor vehicle emission budgets (MVEBs), here is H-GAC's anser: The air quality state implementation plan (SIP) is the state's comprehensive plan to clean the air and meet federal air quality standards. Our region is in nonattainment for ozone and TCEQ is the state agency to prepare the air quality SIP. To prepare the SIP, the state agency must consider all sources of air pollution in the region, like industrial emissions, mobile on-road emissions, non-road emissions (construction equipment}, off-road emissions (locomotives, airports, commercial marine), area emission (residential and small business). The emission inventories for the sources of air pollution are generated and input into the photochemical model to get the concentration of ozone for the attainment year. Air quality control strategies are being also included into the model to attain the standard. Based on this exercise, on-road mobile sources get a quota of up to how much they can emit to reach the standard and that quota is called the Motors Vehicle Emission Budget (MVEB). Conformity is the exercise that shows that all the emissions coming from the transportation plan for a given year do not exceed the MVEB, in other words, the emissions coming from the transportation plan do not delay the attainment of the ozone standard. For our next conformity determination, H-GAC will consider the addition of a discussion regarding air pollution and health effects.
Please see response to your comment on NHHIP and Hempstead Road projects from TxDOT below.
TxDOT Response: "IH 45, Segment 3 (North Houston Highway Improvement Project)
Segment 3 of the of the NHHIP is already included in the 2045 RTP. This amendment includes a change to the existing project. The Federal Highway Administration's review of the NHHIP does not preclude the projects inclusion in the 2045 RTP. "
Hempstead
The Hempstead project from I-610 to BW 8 currently exists in the 2045 RTP. Hempstead Road between I-610 and Beltway 8 will undergo a feasibility study to determine potential scope changes. The study has not commenced, but it will include significant stakeholder and public involvement.
This is genocide. Sustainable development is what the minority communities in Houston’s downtown wards need. Stop pushing minorities to the suburbs. I am tired of your shit. It stinks.
Thank you for your interest in the 2045 RTP. H-GAC appreciates you taking the time to express your opinions.
The proposed amendment to the 2045 RTP should not include Segment 3 of the NHHIP because of the FHWA and USDOT's pause of the project. It is a disruption of precious continuous prairie land.
Thank you for comment on the Regional Transportation Plan and Air Conformity. The NHHIP is included in the Regional Transportation Plan, TxDOT only seeks to update the existing project. H-GAC strives to balance in all modes of transportation while promoting health, safety, mobility, and economic growth. Please see response regarding NHHIP Segment- from TxDOT below.
TxDOT Response: IH 45, Segment 3 (North Houston Highway Improvement Project)
Segment 3 of the of the NHHIP is already included in the 2045 RTP. This amendment includes a change to the existing project. The Federal Highway Administration's review of the NHHIP does not preclude the projects inclusion in the 2045 RTP.
I echo others who raise questions about how the modeling can show a decrease in emissions when building more highway capacity projects an increase in vehicular miles.
I think it's interesting that Hempstead Road elevation is needed to accommodate the Texas Central High Speed Rail. I know there has been a lot of discussion about the rail project, but I've never understood why there wouldn't be the option of expanding existing rail ROW and having the Houston terminus at a Union Station, restored to its original use as a rail station. The Astros go back to the Astrodome (which has higher seating capacity than Minute Maid) and Union Station becomes similar to Union Station in St. Louis. As for elevating Hempstead Highway, elevated freeways in other parts of town have been locations where unhoused people seek shelter and then nearby businesses and residents get upset. Is another elevated roadway parallel to the existing and recently expanded 290 really what this area needs or wants?
The creation of SH36A seems to be yet another belt around Houston that encourages car-dependency and sprawl, leading to worsening air and increased flooding. The Brazos River has experienced frequent flooding already so adding a road such as SH36A would bring added development and added flooding, putting that development at risk.
As for widening SH99, being a tollway, this would not help people who have limited incomes. Actually, such people don't have cars and are looking for other modes of transportation. What alternatives are there in this corridor other than widening the tollway?
I know many of my questions appear rhetorical, but they are sincere.
Thank you for your comment on the Regional Transportation Plan and Air Quality comment page. H-GAC values your input.
For your comment regarding the regarding emissions reductions, here is our response: Conformity is the exercise that shows that all the emissions coming from the transportation plan for a given year do not exceed the MVEB, in other words, the emissions coming from the transportation plan do not delay the attainment of the ozone standard.
Regarding your comment about why VMT increases while emissions decrease in future years, these emissions reductions are due primarily to fleet turn over and the implementation of new federal standards. The Tier 2 emission standards implemented in 2004 for light duty gasoline vehicles and light duty gasoline trucks show emission reductions of up to 95% in NOx versus Tier 1 vehicles. In addition, the Clean Diesel federal rule, which was implemented in 2006 for heavy duty diesel vehicles, shows an emission reduction of 96% in NOx versus previous standards. The Tier 3 vehicle standards implemented between 2017 and 2025 reduces both tailpipe and evaporative emissions from passenger cars, light-duty trucks, medium-duty passenger vehicles and some heavy-duty vehicles. Once fully implemented, smog-forming volatile organic compounds and nitrogen oxides will be reduced by 80% from current levels, particulate matter will be reduced by 70%, and fuel vapor emissions will be driven to near zero levels. For more information on the emission reductions and the implementation timeline for these rules, please refer to the following EPA websites:
https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-light-duty-vehicles-and-trucks-and
https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-heavy-duty-highway-engines-and-vehicles
https://theicct.org/sites/default/files/publications/ICCTupdate_Tier3_NPRM.pdf
Due to all the above emission standards for vehicles, the emissions in the transportation plan are being reduced in the future years due to fleet over turn although the VMT keeps increasing due to population increase.
Please see responses to your comments on Hempstead, Highway 36 A and SH99 projects below.
TxDOT Response:
Hempstead
The Hempstead project from I-610 to BW 8 currently exists in the 2045 RTP. Hempstead Road between I-610 and Beltway 8 will undergo a feasibility study to determine potential scope changes. The study has not commenced, but it will include significant stakeholder and public involvement. Texas Central does not have authority to perform or approve a TxDOT project. TxDOT has had multple meetings with the Texas Central team. The Texas Central team will continue to be consulted as a stakeholder during the Hempstead feasibility study.
36A
36A North: (MPOID 18720) and 36A South: (0912-72-544, MPOID 18719)
At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. Our study methodology always seeks to avoid potential impacts. If impacts cannot be reasonably avoided, we try to minimize the impact; and only then do we mitigate the impacts of a project. This alternatives alignment process is very prescribed and consistent with federal and state practices. The process also includes extensive stakeholder and public engagement.
SH 99
The current and projected travel demand on SH 99 warrants improvements to ensure continued mobility and safety in the corridor.
Re: 2045 RTP
Where is the support that we have had from the judge's office in the past. The map showing the study area for HWY 36A is too narrow and forces focus onto KPC lands. Even worse - a tentative and completely wrong illustration shows a possible route for 36A directly across lands that contain roosting areas for thousands of cranes, ducks and geese not to mention countless other forms of wildlife that are rapidly disappearing elsewhere in the HGAC area. Judge Emmet, Mayor Turner, Harris Co. councilmen, and many public officials in Waller County have all expressed support for the Katy Prairie Conservancy areas to be a hugely valuable future environmental asset to the region. Remember when the same economic development entities called 36A originally the 'Prairie Parkway'? Destruction of the most valuable portion of the last remnants of the Katy Prairie are what is being targeted by this proposal as it currently appears. This terrible abuse of public responsibility for quality of life must be addressed by the current HGAC transportation committee. This cannot stand. Only the shortage of comment period time left precludes me from being able to rally a small army of outraged citizens.
Thank you for your participation and comment. We will take the points of your comment into consideration. As stated in Transportation Policy Council Resolution 2014-01 (attachment) “the Katy Prairie is a significant natural regional resource that should be preserved and enhanced for the benefit of current and future generations and, although all feasible alternatives should be investigated in this study, it is neither the intention nor in the regional interest to build 36A on land that is currently under control or ownership of the Katy Prairie Conservancy.” H-GAC is committed to an inclusive “grass roots” planning process utilizing the guidance of key stakeholders at the corridor and segment level.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. Our study methodology always seeks to avoid potential impacts. If impacts cannot be reasonably avoided, we try to minimize the impact; and only then do we mitigate the impacts of a project. This alternatives alignment process is very prescribed and consistent with federal and state practices. The process also includes extensive stakeholder and public engagement.
The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
What is being done to address the serious non-attainment classification from the EPA? It seems the RTP is cherry picking data, specifically from the TCEQ's air quality models to justify its freeway expansions when in fact, we are not meeting the ozone level standards at federal levels.
And why aren't EVs and public transport options being considered when predicting vehicle usage? By 2045, it's predicted that there will be a 61% increase in population growth AND vehicle ownership? The two aren't related, and frankly illustrates a lack of imagination in H-GAC. Other equally serious concerns are the SH99 expansion creating induced demand effectively rendering it pointless, SH-36A will destroy more of our increasingly scarce prairie land which serves as a natural flood prevention watershed, and an elevated hempstead road becoming redundant when highway 290 sits practically right next and parallel to it.
As a whole, RTP 2045 (and its amendments) are in conflict with the region’s air
quality and health goals, and I demand a more transparent and easy to read document for your Air Quality Conformity document. Why is it so confusing? One shouldn't have to google any acronyms if they're included in the document.
Thank you for submitting comments regarding air quality conformity. For our next conformity determination, H-GAC will consider the addition of a discussion regarding air quality standards, air quality control strategies for mobile sources, and air pollution and health effects.
For your comment regarding the use of acronyms, H-GAC has a list of acronyms in the conformity website.
1) Bikeways that are not protected from vehicle traffic should not count towards the proposed goal. It is criminally negligent to allow for continued construction (or designation) of unprotected bikeways meanwhile touting public safety as a goal. These types of facilities include shared use paths, signed shared roadways, signed shoulders and ‘unidentified’, which account for 93% of all proposed bikeway miles. Bike lanes should be separated from vehicle roadways for the same reason sidewalks are separated – cars pose life threatening risk to both bicyclists and pedestrians. Please provide an adjusted proposed bikeway miles figure based solely on bike paths that are safe for people to travel on (Executive Report page 6).
2) The two performance measures outlined in Figure 2.1 for Goal 5 (Conserve & Protect Natural & Cultural Resources) are not adequate in addressing the risks to environmental health highlighted throughout the plan (particularly Resiliency and Natural Environment sections). Reducing emissions is important but is not relevant to protecting critical ecosystems such as prairie, wetlands, forests and farmland. Reducing impacts requiring mitigation needs to be elaborated on if to be used as a performance measure. Table 3-4 does not offer any performance measures that help meet Goal 5. This is important because of proposed projects like the expansion of SH36 and SH99, which threatens sensitive prairie land. Please provide measurable, concrete parameters for conserving natural land and addressing potential threats to ecosystem loss.
3) The role of roadway expansion as an enabler of regional sprawl and increased flooding is not discussed. H-GAC is a regional body and should be the one to consider the region’s most severe issue of flooding and coastal inundation as it relates to transportation planning. Is there an analysis of how proposed facility expansion will impact or contribute to regional growth projections and increase in impervious cover?
4) NHHIP projects should be removed from 2045 RTP due to the ongoing investigation and project hold placed by FHWA.
5) Please provide total values for Corridor category columns in Table 5-4.
6) Climate change is hardly mentioned throughout the report. Furthermore, increase in greenhouse gas (GHG) emissions due to projected increase in vehicle miles traveled is not discussed. Please include a discussion of construction and vehicular related GHG emissions.
7) The currently proposed NHHIP will merge I-69 and I-45 in downtown Houston. Has any analysis been done on this type of merging for regional hurricane evacuation since I-45 is to serve as a main evacuation corridor?
Needs TxDOT's response H-GAC Response: Thank you for your interest in the 2045 RTP. H-GAC appreciates you taking the time to express your concerns. These comments will be considered for the 2050 RTP. The NHHIP is included in the Regional Transportation Plan, TxDOT only seeks to update the existing project. More informaiton on North Houston Highway Improvement Project can be found at https://www.txdot.gov/inside-txdot/get-involved/about/hearings-meetings/houston/020921.html.
Most of the projects include added lanes to the detriment of walking, biking, and transit infrastructure. The mentioned projects all prioritize car-dependence. I also have concerns about the air quality implications.
Thank you for your input. The 2045 RTP is made up of numerous plans including the Regional Active Transportation Plan, Regional Safety plan, Regional Coordinated Transportation Plan, Congestion Mitigation Air Quality Plan, to list a few. All these plans can be found in the appendix of the document. The direct link to the active transportation plan is (http://2045rtp.com/documents/plan/Appendix-H-Regional-Active-Transportation-Plan.pdf). H-GAC appreciates you taking the time to express your concerns. These comments will be considered for the 2050 RTP.
It is absurd to be considering ANOTHER major highway renovation when we still do not know the impact on traffic from the “almost finished” 288 project. Also just outside of Houston on i10 going towards Austin there are major renovations happening. NO ONE will want to visit here if ALL OF OUR MAJOR HIGHWAYS ARE UNDERGOING MAJOR RECONSTRUCTION INCLUDING THE HIGHWAY THAT LEADS TO THE CITY. I’m astounded by the incompetence. I’ve lived here for 10 years. Now I can’t wait to leave.
Thank you for your input. We will take those comment into our consideration for the 2045 RTP Amendments process.
[LINK Houston submitted comments in PDF format to H-GAC and provides them here also plain text format.]
April 28, 2021
Transportation Policy Council (TPC)
Craig Raborn, Transportation Director
Houston-Galveston Area Council (H-GAC)
RE: Comments on proposed 2045 Regional Transportation Plan amendments
Dear Mr. Raborn and TPC Members:
We submit these comments in response to the two virtual public meetings held by H-GAC on Thursday, April 8, 2021, to discuss proposed amendments to the 2045 Regional Transportation Plan (RTP). People should be able to reach such opportunities in the Houston region safely and with dignity by walking, rolling, biking, and riding transit. These deeply affordable options must be as viable as those afforded by people able to, or choosing to, own and operate personal vehicles. To that end, LINK Houston advocates for a robust and equitable transportation network so that all people can reach opportunity. We strive to be anti-racist and center equity and climate justice in all we do.
Several of the proposed RTP amendments are major highway infrastructure concepts for corridors in Houston through existing residential and commercial development. We have serious concerns about the proposed scope and schedules of these proposed additions to the region's 2045 Regional Transportation Plan. The amendments are not for projects in the distant future. Rather, the amendments requested by the Texas Department of Transportation (TxDOT) propose construction beginning by 2030, within the 10-year Transportation Improvement Program (TIP) program of projects. This gives rise to our primary concern and why we ask TPC to not accept the amendments to the RTP.
TxDOT is premature and acting on outdated concepts. TPC should reject the TxDOT amendments and instead provide leadership by directing the agency to thoroughly implement the federally required process to engage communities and interagency partners to:
(1) Identify if a project is actually warranted and to identify need and purpose (i.e., following the Planning and Environmental Linkages (PEL) process);
AND THEN IF WARRANTED…
(2) Explore a full suite of project alternatives through interagency cooperative planning and in concert with directly adjacent communities (i.e., develop alternatives that satisfy the “critical links between transportation needs and other societal goals”).
The Federal Highway Administration (FHWA) Transportation Planning Process Briefing Book states the following in the introduction,
“The performance of the transportation system also affects public policy concerns, such as safety, air quality, environmental resource consumption, social equity, resilience, land use, urban growth, economic development, and security. Transportation planning recognizes the critical links between transportation needs and other societal goals." [emphasis added]
As proposed, whether new projects or revived after decades-old analyses, the major infrastructure investments will bypass the Planning and Environmental Linkages process which is intended by Congress and FHWA to accelerate project delivery with early cooperative and comprehensive planning. According to the FHWA webpage,
"Planning and Environment Linkages (PEL) represents a collaborative and integrated approach to transportation decision-making that 1) considers environmental, community, and economic goals early in the transportation planning process, and 2) uses the information, analysis, and products developed during planning to inform the environmental review process."
LINK Houston believes thorough community engagement to develop qualitative data and thorough quantitative analysis of transportation demand, travel patterns, and environmental impacts are both warranted given travel preference trends and technologies, recent telework experience, and technological advances changing how and when people and goods move. Data from these analyses will impact the need and purpose for each project. The PEL process, quantitative data analysis, and qualitative data from engagement must be cooperatively undertaken prior to the NEPA process defining project purpose and need as well as alternatives to be evaluated.
The proposed amendments are for transportation projects inseparably connected with other goals and plans. The City of Houston Climate Action Plan, Resilient Houston, Vision Zero Strategy, the METRONext Moving Forward Plan, and other local plans are all more recent than the outdated thinking behind TxDOT’s requested amendments. Houston and the region deserve better. We can do better. Our residents and businesses need us to be better. One way to stretch and be better is for TPC to require project sponsors to incorporate locally supported goals and plans into the purpose and need for corresponding projects. For example, projects within the City of Houston must incorporate goals from the Climate Action Plan, such as to "Reduce Vehicle Miles Travelled per capita 20% by 2050."
LINK Houston suggests TPC instruct H-GAC staff to conduct a study, including extensive public outreach and comment, of the Regional Express Access Lanes (REAL) concept proposed by TxDOT before adding these amendments to the 2045 RTP. The combined Inner Katy Managed Lanes, I-610 W Managed Lanes, and Hempstead Highway Managed Lanes proposed as amendments to the 2045 RTP with 2026-2030 construction dates seem to indicate an intent to construct core elements of a regional express access lane concept. Initiation of federal environmental review for the Inner Katy Managed Lanes, I-610 Managed Lanes, and Hempstead Managed Lanes seems premature given that a network of interconnected elevated express lanes remains a planning-level concept. The vision of a regional elevated express lane network has not been vetted with the public, reviewed, or approved by the H-GAC Transportation Policy Council, nor contemplated in the 2045 Regional Transportation Plan adopted by the agency responsible for regional transportation planning less than two years ago in May 2019.
The benefits and burdens of transportation policies and systems should be equitably allocated across communities so we collectively address past harm and neglect to ensure that all people can reach opportunities in the future. The 2045 RTP states that,
"H-GAC's mission is to plan for the orderly growth and development of the region, working in concert with multiple planning partners. This mission involves building region-wide consensus on improving transportation, promoting smart growth, protecting the environment, enhancing the economy, and fostering equity."
The public expects H-GAC to fulfill its mission. Likewise, the public expects TPC to provide leadership built upon the foundation of sound thinking and fair representation – with deep mutual respect for members representing the locations where projects occur.
Thank you for the opportunity to provide comments on the proposed amendments to the 2045 RTP.
Sincerely,
Oni K. Blair
Executive Director
LINK Houston
P.S. Below are project-specific comments on proposed RTP amendments. We make these additional comments in full support of the City of Houston’s, residents’, and business owners’ posted comments.
Hempstead Highway/Road
Proposed Amendment: Reconstruct Hempstead Road and add one transit lane in each direction at grade and construct 4 elevated managed lanes.
• Traffic analysis requires update to reflect changing technologies, including telework.
• Managed lanes operations are undefined.
• Elevated lanes have not been coordinated.
• Significant work funded by H-GAC has focused on development of commuter rail in the Hempstead corridor. This does not appear to have been considered or recommended. The H-GAC High-Capacity Transit Framework approved by TPC states, "Every investment in transportation that is made by the Transportation Policy Council should be viewed as an opportunity to advance HCT concepts, either in support of transit priority on freeways and thoroughfares, or new transit services along freeways and tollways."
I-10 W from I-610 W to I-45 N
Proposed Amendment: Reconstruct 10 mainlanes and two 2-lane frontage roads and construct 4 new non-toll managed lanes.
• Traffic analysis requires update to reflect changing technologies, including telework.
• Managed lanes operations are undefined.
• Result of METRO's Inner Katy Bus Rapid Transit (BRT) service to accommodate additional travel demand should be recognized before consideration of additional capacity.
I-610 W from I-10 W to I-69 S
Proposed Amendment. Construct 4 express lanes.
• Traffic analysis requires update to reflect changing technologies, including telework.
• Managed lanes operations are undefined.
• Previously canceled due to significant public opposition.
I-10 W Studemont to Houston Ave
Proposed Amendment: Reconstruct to raise the existing 10 mainlanes out of the White Oak Bayou floodway, for reconstructing 2 lane CBD connectors to 4 managed lanes.
• Maintain METRO Inner Katy Bus Rapid Transit (BRT) dedicated access to downtown.
• Removal of structures from the floodway consistent with Resilient Houston goals.
LINK Houston provided detailed comments to TxDOT and METRO in February 2021: Public Comments on Inner Katy Corridor. We are concerned about TxDOT’s I-10 Inner Katy Managed Lanes Project, but generally support the agency’s I-10 Inner Katy Drainage Improvements Project to better manage flooding. TxDOT is exploring if the state should add four managed lanes to I-10 and/or improve flood mitigation. In LINK Houston’s view, a successful I-10 Inner Katy Managed Lanes Project serves high-occupancy vehicles (or enforces high/variable tolls on all vehicles with only one occupant) and does not in any way impede the quality of the Inner Katy METRORapid Bus Rapid Transit (BRT) line and stations. The new BRT line is the additional transportation capacity in the corridor supported by the region’s plans. TxDOT had the opportunity to create managed lanes when originally expanding the highway in the 2000’s and chose not to do so.
SH 35 from Dixie Drive to Brazoria County Line
Proposed Amendment: Construct new 6 lane freeway with new 2-lane frontage roads.
• Traffic analysis requires update to reflect changing technologies, including telework.
• Managed lanes operations are undefined.
• Significant work funded by the metropolitan planning organization has focused on development of commuter rail in the SH 35 corridor. This does not appear to have been considered or recommended. The H-GAC High-Capacity Transit Framework approved by TPC states, "Every investment in transportation that is made by the Transportation Policy Council should be viewed as an opportunity to advance HCT concepts, either in support of transit priority on freeways and thoroughfares, or new transit services along freeways and tollways."
• Limit footprint to within Mykawa Road right-of-way to minimize impacts on residents.
A response from TxDOT is attached.
View Attached Response
The Katy Prairie is an essential, and irreplaceable, key to the region's health and vitality today and going forward, supporting more than 300 species of birds, and providing critical flood mitigation and ecosystem services to the entire region. It is well understood to be a critical piece of natural infrastructure that supports the region's resilience to extreme weather, and provides outdoor recreation and uninterrupted open space for so many in the region who might not otherwise have access. Decades of human capital and real treasure have gone into preserving what little remains of a once much-larger coastal prairie system--to the benefit of the entire region. For the benefit of the people and wildlife of the region, it is essential to keep intact what little is left of this irreplaceable place.
Thank you for your participation and comment. We will take the points of your comment into consideration. As stated in Transportation Policy Council Resolution 2014-01 (attachment) “the Katy Prairie is a significant natural regional resource that should be preserved and enhanced for the benefit of current and future generations and, although all feasible alternatives should be investigated in this study, it is neither the intention nor in the regional interest to build 36A on land that is currently under control or ownership of the Katy Prairie Conservancy.” H-GAC is committed to an inclusive “grass roots” planning process utilizing the guidance of key stakeholders at the corridor and segment level.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. Our study methodology always seeks to avoid potential impacts. If impacts cannot be reasonably avoided, we try to minimize the impact; and only then do we mitigate the impacts of a project. This alternatives alignment process is very prescribed and consistent with federal and state practices. The process also includes extensive stakeholder and public engagement.
The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
Thank you for the opportunity to submit comments. As a Houston resident, I am concerned with future planning that is focused mainly on car travel to move people around the city. There are many detrimental factors to consider regarding air quality with these proposed projects.
Projects in the RTP should be prioritizing safety; expanding lanes and increasing VMTs do not align with Vision Zero initiatives. Of gravest concern, is that the “Transportation Conformity” Chapter, titled “Air Quality” in the 2045 RTP table of contents, misleadingly represents the region’s air quality status.
While we appreciate the need for the chapter to discuss and present the conformity process and results, the lack of information and data presented on the ozone standard and the region’s attainment designation is striking. In essence, there are two air quality standards of interest for the Houston-Galveston-Brazoria (HGB) region—one that the region meets (the Texas Commission on Environmental Quality’s (TCEQ) Motor Vehicle Emission Budgets (MVEB) for nitrogen oxides (NOx) and volatile organic compounds (VOCs)) and one that it does not (the Environmental Protection Agency’s (EPA) National Ambient Air Quality Standards (NAAQS) Ozone standard). The chapter overwhelmingly focuses on the TCEQ MVEB standard; 4 of the chapter’s 7 pages are of charts and tables showing the region meeting the emission budgets. Nowhere in the chapter, however, are similar tables, charts or data illustrating the region’s nonattainment to EPA’s ozone standard. We are concerned that the information presented, and omitted, gives the false impression that the region is successfully meeting air quality standards, when in reality, it is not.
This is yet more concerning given that the region’s ozone readings are actual— obtained via dozens of air quality monitoring sites across the region—whereas TCEQ’s MVEB targets are theoretical and model-derived.
To improve this, we request/ recommend:
• Provide a clear representation of the region’s actual air quality status;
• Please provide and explain the relationship between the two air quality standards in
question—the EPA’s NAAQs ozone standard and TCEQ’s MVEB targets;
• Include data, charts, tables regarding the EPA ozone standard.
Rewrite the Transportation Conformity/ Air Quality chapter as a more user-friendly document with the public in mind.
Conformity and the air quality regulatory process is complex and confusing. The way that the Transportation Conformity/ Air Quality chapter is written and presented makes it more so. Throughout the chapter, a number of important acronyms are never spelled out. These include TCEQ, NOx, VOCs. Please remember that the RTP is a public facing document intended to present the region’s long range transportation vision. This section is not digestible, lacks context (why do we care about air quality?), excludes references (footnotes 2 and 3), and provides very few leads for an individual to educate themselves on air quality issues.
To address this, we request/ recommend:
• Provide context; why is air quality important to the region;
• Use less technical language and spell out acronyms;
• Provide information on the Transportation Control Measures and Emission Control
Programs deployed across the region. Given the region’s “serious attainment” designation, we would imagine the public to be interested in the region’s efforts to reduce emissions.
Include discussion of air quality related health risks and benefits
Via the Clean Air Act, the NAAQS for six criteria pollutants were created as safeguards for public health. To be exact, they were created “to protect human health and welfare” from harmful pollutants; ozone having been identified by the EPA as one of the six criteria pollutants. The intent of an MPO’s air quality efforts therefore must be with this health goal in mind. However, chapter 6 includes no discussion of human health or why the region should be concerned about VOCs, NOx, or ozone.
Across Texas, asthma (the clearest and most serious health risk tied to high levels of ozone) is the number one reason for school absenteeism. Child asthma rates are also found to be higher at schools with greater proximity to roads. A 2017 American Lung Association study found asthma levels to be higher in Houston than in most other parts of the country and are most concentrated in low-income and minority communities. Asthma rates, and health injustices, are yet another datapoint that must be considered while planning the region’s transportation future.
To address this, we request/ recommend:
• Establish programs and goals that address the region’s air quality related health issues with a focus on the populations and communities that suffer the brunt of environmental/ transportation-related health harms;
• Prioritize transportation modes, such as biking, walking, electric vehicles, and public transportation over road expansion and single occupancy vehicle travel that will worsen air quality.
As a whole, RTP 2045 (and its amendments) are in conflict with the region’s air quality and health goals.
As long as H-GAC transportation planning prioritizes road expansion and single- occupancy vehicle travel over alternative transportation modes, as is done throughout RTP 2045, air quality, health, and road congestion will be horrendous in the region. For example, under the current plan, there will be a 61% population growth over the next 25 years, with a 61% increase in vehicles, and an increase of more than 100,000,000 VMT. When logic is applied, it is evident that a transportation forced to absorb 61% more vehicles would be crippled far beyond the existing congestion rates. RTP 2045 should plan for future population growth using methods that efficiently move the population, which is not with single occupant vehicles. The transportation infrastructure built between now and 2045 is one of the most influential drivers of vehicle ownership.
Again, please remember that the purpose of long-range transportation plans, such as RTP 2045, is to provide the public with a vision for the region. The vision that RTP 2045 presents is increased population, VMTs, congestion without identifying any programs or strategy for improving air quality and health outcomes.
To address this, we request/ recommend:
• Prioritize transportation modes, such as biking, walking, electric vehicles, and public transportation over road expansion and single occupancy vehicle travel that will worsen air quality.
It is our right to live in a city that values our health and safety. By continuing to consider and implement projects that increase VMTs, and therefore harmful pollutants Houston residents will be at risk. We should be looking toward the future for moving people around our city that is not solely car based.
Thank you for your time.
Erin Eriksen
Thank you for providing comments on the air quality conformity document. For your comment regarding Chapter 6 of the RTP document, H-GAC will consider the addition of more air quality information on this chapter in the next conformity determination.
For your comment regarding the use of acronyms, H-GAC has a list of acronyms in the conformity website. For your comment regarding the relation between the national ambient air quality standard(NAAQS) and the motor vehicle emission budgets (MVEBs), here is our explanation: The air quality state implementation plan (SIP) is the state's comprehensive plan to clean the air and meet federal air quality standards. Our region is in nonattainment for ozone and TCEQ is the state agency to prepare the air quality SIP. To prepare the SIP, the state agency must consider all sources of air pollution in the region, like industrial emissions, mobile on-road emissions, non-road emissions (construction equipment}, off-road emissions (locomotives, airports, commercial marine), area emission (residential and small business). The emission inventories for the sources of air pollution are generated and input into the photochemical model to get the concentration of ozone for the attainment year. Air quality control strategies are being also included into the model to attain the standard. Based on this exercise, on-road mobile sources get a quota of up to how much they can emit to reach the standard and that quota is called the Motors Vehicle Emission Budget (MVEB). Conformity is the exercise that shows that all the emissions coming from the transportation plan for a given year do not exceed the MVEB, in other words, the emissions coming from the transportation plan do not delay the attainment of the ozone standard.
For our next conformity determination, H-GAC will consider the addition of a discussion regarding air quality standards, air quality control strategies for mobile sources, and air pollution and health effects.
The inclusion of Highway 36A across protected lands managed by the Katy Prairie Conservancy, destroying valuable habitat utilized by thousands of cranes, geese, ducks, and other wildlife is an outrage. This valuable prairie habitat was set aside to provide a lasting refuge in the Waller County area.
The short opportunity you have provided for the comment period appears to be an attempt to slide this by the public vetting process for your own betterment. Please provide an extended comment period so that more voices may be heard on this topic. Better still, please reconsider the location of this highway to minimize the environmental impact to this sensitive and valuable area
Thank you for your participation and comment. We will take the points of your comment into consideration. As stated in Transportation Policy Council Resolution 2014-01 (attachment) “the Katy Prairie is a significant natural regional resource that should be preserved and enhanced for the benefit of current and future generations and, although all feasible alternatives should be investigated in this study, it is neither the intention nor in the regional interest to build 36A on land that is currently under control or ownership of the Katy Prairie Conservancy.” H-GAC is committed to an inclusive “grass roots” planning process utilizing the guidance of key stakeholders at the corridor and segment level.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. Our study methodology always seeks to avoid potential impacts. If impacts cannot be reasonably avoided, we try to minimize the impact; and only then do we mitigate the impacts of a project. This alternatives alignment process is very prescribed and consistent with federal and state practices. The process also includes extensive stakeholder and public engagement.
The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
I don't understand how you can forecast a sharp increase in VMT while also forecasting a sharp decrease in VOC and NOx emissions. Please provide all inputs to your air quality model that relate to vehicle efficiency.
Thank you for submitting your comments on the air quality conformity document.
These emissions reductions are due primarily to fleet turn over and the implementation of new federal standards. The Tier 2 emission standards implemented in 2004 for light duly gasoline vehicles and light duty gasoline trucks show emission reductions of up to 95% in NOx versus Tier 1 vehicles. In addition, the Clean Diesel federal rule, which was implemented in 2006 for heavy duty diesel vehicles, shows an emission reduction of 96% in NOx versus previous standards. The Tier 3 vehicle standards implemented between 2017 and 2025 reduces both tailpipe and evaporative emissions from passenger cars, light-duty trucks, medium-duty passenger vehicles and some heavy-duty vehicles. Once fully implemented, smog-forming volatile organic compounds and nitrogen oxides will be reduced by 80% from current levels, particulate matter will be reduced by 70%, and fuel vapor emissions will be driven to near zero levels
For more information on the emission reductions and the implementation timeline for these rules, please refer to the following EPA websites:
https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-light-duty-vehicles-and-trucks-and
https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-heavy-duty-highway-engines-and-vehicles
https://theicct.org/sites/default/files/publications/ICCTupdate_Tier3_NPRM.pdf
Due to all the above emission standards for vehicles, the emissions in the transportation plan are being reduced in the future years due to fleet over turn although the VMT keeps increasing due to population increase.
Good afternoon,
Please help the Houston-Galveston area be healthier. That means less car dependency, more options for walking, bicycling, and public transportation.
More lanes = more pain for our communities.
We're talking about a plan through 2040. Let's use our imagination and see if we can come up with something to be proud of! Any drunk could come up with the idea to add more lanes to the highway. Let's work smarter! Present a positive, uplifting, healthy, efficient, and new vision for the region.
People are dying of cancer and respiratory issues. More lanes will only make it worse.
Oh, and the Proposed Amendment to the 2045 RTP should not include Segment 3 of the NHHIP
because of the FHWA and USDOT’s pause of the project.
Thank you for your time.
Sincerely,
Abhinav
Thank you for comment on the Regional Transportation Plan and Air Conformity. H-GAC is dedicated to improving the lives and mobility of Greater Houston region. Recently, H-GAC published the Active Transportation Plan and the Regionally Coordinated Transportation Plan which outline the agency’s strategies to the expansion of transit, bike, pedestrian transportation for the eight-county region. The NHHIP is included in the Regional Transportation Plan, TxDOT only seeks to update the existing project. H-GAC strives to balance in all modes of transportation while promoting health, safety, mobility, and economic growth.
TxDOT Response: "IH 45, Segment 3 (North Houston Highway Improvement Project)
Segment 3 of the of the NHHIP is already included in the 2045 RTP. This amendment includes a change to the existing project. The Federal Highway Administration's review of the NHHIP does not preclude the projects inclusion in the 2045 RTP. "
I'm a citizen concerned about how important this plan is and how little the average citizen knows about it or HGAC's existence. What efforts were made to inform the public using the media or community institutions?
I'd also like to know how much coordination there has been with other departments like Housing and Community Affairs. What are the holistic metrics of the impacts of Driving and Transit?
Thank you for your interest in the 2045 RTP Amendments. H-GAC hosted more than 20 public meetings and open house events for the 2045 RTP and the 2018 “Call for Projects.” H-GAC used social media, email lists, direct mailings, newspapers (legal notices and news articles), PSA announcements, TxDOT sign messaging, etc. to notify the public of the public meetings/workshops. Years of coordination take place with the City of Houston, and other major cities in the 8-county region; METRO and other transit authorities; counties of Harris, Waller, Fort Bend, Galveston, Chambers, Liberty and Montgomery; the Ports, etc. in developing the RTP.
Re: 2045 RTP
The map showing the study area for HWY 36A is too narrow and forces focus onto KPC lands. Even worse - a tentative and completely wrong illustration shows a possible route for 36A directly across lands that contain roosting areas for thousands of cranes, ducks and geese not to mention countless other forms of wildlife that are rapidly disappearing elsewhere in the HGAC area. The Katy Prairie Conservancy areas are valuable future environmental asset to the region.
These lands are critical as some of the very last remaining costal prairies in Texas. A habitat that is almost gone in its native state and supports countless animal forms, abates storm water and flooding, and so much more. It is imperative to not infringe on these native lands.
Thank you,
Martin Hagne
Executive Director
Gulf Coast Bird Observatory
Thank you for your participation and comment. We will take the points of your comment into consideration. As stated in Transportation Policy Council Resolution 2014-01 (attachment) “the Katy Prairie is a significant natural regional resource that should be preserved and enhanced for the benefit of current and future generations and, although all feasible alternatives should be investigated in this study, it is neither the intention nor in the regional interest to build 36A on land that is currently under control or ownership of the Katy Prairie Conservancy.” H-GAC is committed to an inclusive “grass roots” planning process utilizing the guidance of key stakeholders at the corridor and segment level. The June TAC/TPC amendment material will include the study area to represent Highway 36A projects 18719 and 18720.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. Our study methodology always seeks to avoid potential impacts. If impacts cannot be reasonably avoided, we try to minimize the impact; and only then do we mitigate the impacts of a project. This alternatives alignment process is very prescribed and consistent with federal and state practices. The process also includes extensive stakeholder and public engagement.
The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
My wife and I have financially supported the KPC for at least the past twenty (20) years. We have enjoyed many nature excursions there and many birding experiences there. PLEASE advocate for preservation of this prairie by prohibiting construction of Hwy 36A or any such public artery through it.
Respectfully yours,
James & Mary Winn
Thank you for your participation and comment. We will take the points of your comment into consideration. As stated in Transportation Policy Council Resolution 2014-01 (attachment) “the Katy Prairie is a significant natural regional resource that should be preserved and enhanced for the benefit of current and future generations and, although all feasible alternatives should be investigated in this study, it is neither the intention nor in the regional interest to build 36A on land that is currently under control or ownership of the Katy Prairie Conservancy.” H-GAC is committed to an inclusive “grass roots” planning process utilizing the guidance of key stakeholders at the corridor and segment level.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. Our study methodology always seeks to avoid potential impacts. If impacts cannot be reasonably avoided, we try to minimize the impact; and only then do we mitigate the impacts of a project. This alternatives alignment process is very prescribed and consistent with federal and state practices. The process also includes extensive stakeholder and public engagement.
The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
Yo pienso que la población de Houston merece un mejor sistema de transporte, de tal manera que no tenga que lidiar con tanto tráfico ni que haya más contaminación.
Lo mejor para Houston sería el tren eléctrico, que sería más veloz y no afectaría la calidad del aire. Sería una gran solución para todos los que vivimos aquí.
Gracias por su amable atención.
Thank you for your interest in the 2045 RTP. H-GAC appreciates you taking the time to express your concerns. These comments will be considered for the 2050 RTP. The 2045 RTP includes more focused plans such as Regional Active Transportation Plan, Congestion Mitigation Air Quality (CMAQ) Plan, Regional Safety Plan and Congestion Management Process to address the congestion, air quality and safety concerns in our region. For more details please see appendices to the 2045RTP at http://www.2045rtp.com/documents.aspx. (Spanish translation: Gracias por su interés en el RTP 2045. H-GAC agradece que se haya tomado el tiempo para expresar sus inquietudes. Estos comentarios serán considerados para el RTP 2050. El RTP 2045 incluye planes más específicos, como el Plan de transporte activo regional, el Plan de calidad del aire para mitigar la congestión (CMAQ), el Plan de seguridad regional y el Proceso de gestión de la congestión para abordar los problemas de congestión, calidad del aire y seguridad en nuestra región. Para obtener más detalles, consulte los apéndices del 2045RTP en
http://www.2045rtp.com/documents.aspx.)
I am disappointed that with the expected population growth and knowledge of the negative impact cars have on the environment, the transportation plan is largely focused on highways. Expanding the highway system will only encourage more driving, therefore causing further environmental harm to our communities. Our region can do better than this. It would be good to see improvements and expansions of our public transportation system, for example. Why not invest in passenger/commuter trains, more efficient bus routes, and safer bike lanes? Please consider approaches with the goals of improving health, equity, and air quality for our and future generations, as opposed to creating more traffic on more highways.
Thank you for your interest in the 2045 RTP. H-GAC appreciates you taking the time to express your concerns. These comments will be considered for the 2050 RTP. The 2045 RTP includes more focused plans such as Regional Active Transportation Plan, Congestion Mitigation Air Quality (CMAQ) Plan, Regional Safety Plan and Congestion Management Process to address the congestion, air quality and safety concerns in our region. For more details please see appendices to the 2045RTP at http://www.2045rtp.com/documents.aspx.
I would strongly urge consideration for the preservation of the valuable natural habitat maintained by the Katy Prairie Conservancy. Gulf coastal prairie and grassland habitats are critical to hundreds of migratory and resident bird species and support a diverse, specialized ecosystem. The Katy Prairie Conservancy has assembled broad community support, political favor, and financial donations for the preservation of this critical habitat. To undermine this work goes against nearly 30 years of hard work.
Thank you for your participation and comment. We will take the points of your comment into consideration. As stated in Transportation Policy Council Resolution 2014-01 (attachment) “the Katy Prairie is a significant natural regional resource that should be preserved and enhanced for the benefit of current and future generations and, although all feasible alternatives should be investigated in this study, it is neither the intention nor in the regional interest to build 36A on land that is currently under control or ownership of the Katy Prairie Conservancy.” H-GAC is committed to an inclusive “grass roots” planning process utilizing the guidance of key stakeholders at the corridor and segment level.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. Our study methodology always seeks to avoid potential impacts. If impacts cannot be reasonably avoided, we try to minimize the impact; and only then do we mitigate the impacts of a project. This alternatives alignment process is very prescribed and consistent with federal and state practices. The process also includes extensive stakeholder and public engagement.
The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
The Regional Transportation plan proposed by the Council includes a number of proposals that are not only outdated, but dangerous to the health and the long-term solvency of the region and its residents. The plan's prioritization of single-occupancy vehicles above more efficient and cost-effective forms of transportation contributes to a self-perpetuating loop of induced traffic demand, ballooning maintenance costs, increased flooding, air quality issues and other negative outcomes.
The H-GAC assumes a 61% increase in population will lead to a corresponding 61% increase in single-occupancy vehicle travel. The projects in the RTP should be determining future outcomes, not being influenced by presumed outcomes. Please provide a data based justification used to estimate a 61% increase in vehicle usage.
The Proposed Amendment to the 2045 RTP should not include Segment 3 of the NHHIP because of the FHWA’s and USDOT’s pause of the project.
Has Texas Central approved the Hempstead Road elevated managed lanes project? The construction of a highway next to US290 appears to be redundant and wasteful. Please provide record of input from Texas Central on project #18706, and justification for 18701, 18702, 18703, 18704, and 18705.
Please provide and explain the relationship between the two air quality standards in question—the EPA’s NAAQS ozone standard and TCEQ’s MVEB targets
Please include discussion of air quality related health risks and benefits- a 61% increase in single occupancy vehicles, even including greater adoption of electric vehicles, would be catastrophic to air quality and health in the Houston-Galveston region. The council should work to address the air quality issues that already exist and embrace new travel solutions, rather than advocating for continuous highway expansion that will induce worse traffic and incur high maintenance costs in the future.
Thank you for your comment on the Regional Transportation Plan and Air Quality comment page. H-GAC values your input. The 61% growth in single -occupancy vehicle usage coming from fact sheet 2 (http://www.2045rtp.com/documents/2045-fact-sheet2.pdf) was developed as a promotional material for first round of public involvement meetings conducted during the development of 2045 RTP process in spring of 2018. 61% of estimated population growth was applied to vehicle ownership (5.5 million) data from 2017. This estimated vehicle ownership growth was not used in the project selection process. The agency provides a public data lab (Link) and documentation (Link) explaining its forecasting processes.
The 2045 RTP includes more focused plans such as Congestion Mitigation Air Quality (CMAQ) Plan, Regional Safety Plan and Congestion Management Process to address the congestion, air quality and safety concerns in our region. For more details please see appendices to the 2045RTP at http://www.2045rtp.com/documents.aspx.
The NHHIP is included in the Regional Transportation Plan, TxDOT only seeks to update the existing project. Texas Central is not responsible for the approval of capital projects, nor is the organization’s input required. The Hempstead Road construction will provide traffic an alternate route to US 290.
For your comment regarding the relation between the national ambient air quality standard (NAAQS) and the motor vehicle emission budgets (MVEBs):The air quality state implementation plan (SIP) is the state's comprehensive plan to clean the air and meet federal air quality standards. Our region is in nonattainment for ozone and TCEQ is the state agency to prepare the air quality SIP. To prepare the SIP, the state agency must consider all sources of air pollution in the region, like industrial emissions, mobile on-road emissions, non-road emissions (construction equipment}, off-road emissions (locomotives, airports, commercial marine), area emission (residential and small business). The emission inventories for the sources of air pollution are generated and input into the photochemical model to get the concentration of ozone for the attainment year. Air quality control strategies are being also included into the model to attain the standard. Based on this exercise, on-road mobile sources get a quota of up to how much they can emit to reach the standard and that quota is called the Motors Vehicle Emission Budget (MVEB). Conformity is the exercise that shows that all the emissions coming from the transportation plan for a given year do not exceed the MVEB, in other words, the emissions coming from the transportation plan do not delay the attainment of the ozone standard. For our next conformity determination, H-GAC will consider the addition of a discussion regarding air pollution and health effects.
See response for your comments on NHHIP segment 3 and Hempstead Road projects from TxDOT below:
IH 45, Segment 3 (North Houston Highway Improvement Project)
Segment 3 of the of the NHHIP is already included in the 2045 RTP. This amendment includes a change to the existing project. The Federal Highway Administration's review of the NHHIP does not preclude the projects inclusion in the 2045 RTP.
Hempstead
The Hempstead project from I-610 to BW 8 currently exists in the 2045 RTP. Hempstead Road between I-610 and Beltway 8 will undergo a feasibility study to determine potential scope changes. The study has not commenced, but it will include significant stakeholder and public involvement.
I've read through these plans and they do not seem to address congestion or environmental issues. As a planner (Masters in Planning from University of Tokyo) who enjoys seeing how systems fit together, there are a few things that I don't understand.
Why would we spend money on adding lanes to roadways rather than diversifying modes? Can anyone provide a single example when that has worked over the long term? Is there any information on the air quality changes that would come from that kind of encouragement for driving?
The information all seems to assume a huge increase in private car usage. Why would it be based on presumptions rather than looking at movement patterns and future options.
It just looks like more congestion in the making.
Thank you for your comment on the Regional Transportation Plan and Air Quality comment page. H-GAC values your input. The 61% growth in single -occupancy vehicle usage coming from fact sheet 2 (http://www.2045rtp.com/documents/2045-fact-sheet2.pdf) was developed as a promotional material for first round of public involvement meetings conducted during the development of 2045 RTP process in spring of 2018. 61% of estimated population growth was applied to vehicle ownership (5.5 million) data from 2017. This estimated vehicle ownership growth was not used in the project selection process. The agency provides a public data lab (Link) and documentation (Link) explaining its forecasting processes.
The 2045 RTP includes more focused plans such as Regional Active Transportation Plan, Congestion Mitigation Air Quality (CMAQ) Plan, Regional Safety Plan and Congestion Management Process to address the congestion, air quality and safety concerns in our region. For more details please see appendices to the 2045RTP at http://www.2045rtp.com/documents.aspx.
As a former resident of the Houston area I have seen tremendous habitat destruction in the Katy Prairie area over the last 30 years. Proposing a highway through the middle of it seems appalling. It will only lead to more loss of habitat not just from highway construction but with the development it will promote in the future. Please find an alternate route.
Thank you for your participation and comment. We will take the points of your comment into consideration. As stated in Transportation Policy Council Resolution 2014-01 (attachment) “the Katy Prairie is a significant natural regional resource that should be preserved and enhanced for the benefit of current and future generations and, although all feasible alternatives should be investigated in this study, it is neither the intention nor in the regional interest to build 36A on land that is currently under control or ownership of the Katy Prairie Conservancy.” H-GAC is committed to an inclusive “grass roots” planning process utilizing the guidance of key stakeholders at the corridor and segment level.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. Our study methodology always seeks to avoid potential impacts. If impacts cannot be reasonably avoided, we try to minimize the impact; and only then do we mitigate the impacts of a project. This alternatives alignment process is very prescribed and consistent with federal and state practices. The process also includes extensive stakeholder and public engagement.
The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
No time for a proper comment except to register opposition to road-building across such a valuable asset as the Katy Prairie. It presents the ability to absorb storm waters, feed and shelter migratory birds and improve the Houston area ability to attract 'birders', with their associated spending. The same comments that apply to considering alternative forms of transport to the widening of I-45 apply here. Building roads simply increases overall traffic volume and diminishes our assets. You can do better!
Thank you for your participation and comment. We will take the points of your comment into consideration. As stated in Transportation Policy Council Resolution 2014-01 (attachment) “the Katy Prairie is a significant natural regional resource that should be preserved and enhanced for the benefit of current and future generations and, although all feasible alternatives should be investigated in this study, it is neither the intention nor in the regional interest to build 36A on land that is currently under control or ownership of the Katy Prairie Conservancy.” H-GAC is committed to an inclusive “grass roots” planning process utilizing the guidance of key stakeholders at the corridor and segment level.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. Our study methodology always seeks to avoid potential impacts. If impacts cannot be reasonably avoided, we try to minimize the impact; and only then do we mitigate the impacts of a project. This alternatives alignment process is very prescribed and consistent with federal and state practices. The process also includes extensive stakeholder and public engagement.
The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
I’m a former vice-president of the board of the Gulf Coast Bird Observatory, a former president of Houston Audubon, and life-long advocate for the Katy Prairie. I’ve spent a lifetime studying the flora and fauna of the Katy Prairie, and I’ve written numerous articles about it in magazines and the newspaper. It is a priceless heritage to future generations, a remnant of a once vast prairie ecosystem. HWY 36A would erase the most valuable section of what’s left of that ecosystem. Surely, you don’t want that on your conscience.
Thank you for your participation and comment. We will take the points of your comment into consideration. As stated in Transportation Policy Council Resolution 2014-01 (attachment) “the Katy Prairie is a significant natural regional resource that should be preserved and enhanced for the benefit of current and future generations and, although all feasible alternatives should be investigated in this study, it is neither the intention nor in the regional interest to build 36A on land that is currently under control or ownership of the Katy Prairie Conservancy.” H-GAC is committed to an inclusive “grass roots” planning process utilizing the guidance of key stakeholders at the corridor and segment level.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. Our study methodology always seeks to avoid potential impacts. If impacts cannot be reasonably avoided, we try to minimize the impact; and only then do we mitigate the impacts of a project. This alternatives alignment process is very prescribed and consistent with federal and state practices. The process also includes extensive stakeholder and public engagement.
The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
The Katy Prairie Conservancy has worked with groups throughout Texas in attempts to preserve the critical habitat required to assure that valuable lands are preserved in perpetuity that support a large portion of migrating birds - cranes, ducks and geese as well as other wildlife. The Katy Conservancy lands have been the major source of survival for these migrating birds and are in danger once again of being destroyed - and along with that destruction the loss of not only this critical habitat but the birds that rely upon it for their survival and the opportunity that thousands of individuals would have to continue to see these magnificent creatures in their beauty in a natural prairie habitat.
As a member of The Gulf Coast Bird Observatory - another organization that works hard to preserve land valuable for the sustainment of migrating birds - I wish to give my strong opposition for the proposed highway cutting through these lands. The last remnants of the Katy Prairie simply cannot and should not be put in jeopardy and an alternative plan should be created that will assure this preservation.
Thank you for your participation and comment. We will take the points of your comment into consideration. As stated in Transportation Policy Council Resolution 2014-01 (attachment) “the Katy Prairie is a significant natural regional resource that should be preserved and enhanced for the benefit of current and future generations and, although all feasible alternatives should be investigated in this study, it is neither the intention nor in the regional interest to build 36A on land that is currently under control or ownership of the Katy Prairie Conservancy.” H-GAC is committed to an inclusive “grass roots” planning process utilizing the guidance of key stakeholders at the corridor and segment level.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. Our study methodology always seeks to avoid potential impacts. If impacts cannot be reasonably avoided, we try to minimize the impact; and only then do we mitigate the impacts of a project. This alternatives alignment process is very prescribed and consistent with federal and state practices. The process also includes extensive stakeholder and public engagement.
We value the Katy Prairie from a Gulf Coast Bird Observatory perspective and are very upset by the current hwy 36A expansion plans
Thank you for your participation and comment. We will take the points of your comment into consideration. As stated in Transportation Policy Council Resolution 2014-01 (attachment) “the Katy Prairie is a significant natural regional resource that should be preserved and enhanced for the benefit of current and future generations and, although all feasible alternatives should be investigated in this study, it is neither the intention nor in the regional interest to build 36A on land that is currently under control or ownership of the Katy Prairie Conservancy.” H-GAC is committed to an inclusive “grass roots” planning process utilizing the guidance of key stakeholders at the corridor and segment level.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. Our study methodology always seeks to avoid potential impacts. If impacts cannot be reasonably avoided, we try to minimize the impact; and only then do we mitigate the impacts of a project. This alternatives alignment process is very prescribed and consistent with federal and state practices. The process also includes extensive stakeholder and public engagement.
The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
I think the proposed route of highway 36A running through the Katy Prairie is very short-sighted. This route would remove what little prairie that is left in the area that has thousands of wintering cranes, ducks, and geese. There also other wildlife that uses this habitat year-round. The support of our elected officials in the past for the Katy Prairie Conservancy areas was vital and is still needed to keep the prairie a viable eco-area. Once a highway goes through this region, then many housing subdivision, strip malls, and other support industries will start appearing (i.e., look what happened as soon as Beltway 8 was built and is currently happening around the Grand Parkway) which means the end of the Katy Prairie as a viable wildlife habitat. This would be a shame to let it happen. There needs to be strong leadership to take a stand and allow wildlife to be a guiding (and remaining) force for this world instead of faster transportation (and mega profits for the a few land grabbing people.)
Thanks for your attention,
Tony Frank
Houston, Texas
Gtbc03@aol.com
Thank you for your participation and comment. We will take the points of your comment into consideration. As stated in Transportation Policy Council Resolution 2014-01 (attachment) “the Katy Prairie is a significant natural regional resource that should be preserved and enhanced for the benefit of current and future generations and, although all feasible alternatives should be investigated in this study, it is neither the intention nor in the regional interest to build 36A on land that is currently under control or ownership of the Katy Prairie Conservancy.” H-GAC is committed to an inclusive “grass roots” planning process utilizing the guidance of key stakeholders at the corridor and segment level.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. Our study methodology always seeks to avoid potential impacts. If impacts cannot be reasonably avoided, we try to minimize the impact; and only then do we mitigate the impacts of a project. This alternatives alignment process is very prescribed and consistent with federal and state practices. The process also includes extensive stakeholder and public engagement.
The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
As a resident of Pearland, we are against an elevated segment of SH 35 coming through the City of Pearland. There is too much development South of FM 518 to accomplish this. It was possible 15-20 years ago, but not now. It will either take too many homes or too many business that employ residents. It will divide our community further and create many corresponding nuisances/issues for residents. If an elevated freeway through Pearland is the intent of adding SH 35 to the TIP, please do not consider adding it to the plan. Alternatives could be limited elevated/depressed sections and innovative intersections at existing signals.
Thank you for your input. We will take those comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: The need for SH 35 improvements from Dixie Drive and continuing south to future SH99 is just beginning. The Texas Department of Transportation has scrapped the previous plans for S 35 and is staring over in the feasibility process. Our process for corridor studies involves both a quantitative and qualitative process that features extensive stakeholder and public engagement and input before finalizing a proposed improvement concept. We believe including the project in the 2045 RTP puts the public on notice that we intend to study the corridor because this corridor is vital to the transportation system. Improvements are anticipated to move people and good more reliably.
Attached are Air Alliance Houston’s public comments regarding the Draft 2021 Transportation Conformity and the proposed 2045 Regional Transportation Plan amendments. Also attached is a public comment recently submitted to the EPA regarding the Texas SIP that we would like included as part of our public comment.
View Attached Letter
View Additional Attachment
Thank you for submitting your comments and corections regarding Chapter 4. This chapter has been updated and reposted in the conformity document.
H-GAC also wants to thank you for submitting to us the letter that you, Earthjustice and Sierra Club sent to EPA. H-GAC agrees with you regarding more and new air quality control strategies needed to reach the new ozone standards.
Regarding your comment on NHHIP and IH 10VV/Inner Katy projects, a response from TxDOT is attached.
View Attached Response
Please find attached our comments on the proposed amendments to the 2045 Regional Transportation Plan.
View Attached Letter
A response from TxDOT is attached.
View Attached Response
As a bicyclist I feel that every road in Harris county should have a sidewalk so I don't have to constantly risk being squashed by an aggressive driver feeling he owns my portion of the road.
I see way too much emphasis on automotive traffic in the 2045 RTP. We must consider more bus and train alternatives.
That also includes educating the public on these available alternatives. When I go to jury duty by Park & Ride from Cypress the other jurors are always amazed that there is another method of transportation available. They either did not think of it or were not familiar with Park & Ride.
I also find it difficult to use an HOV or Park & Ride which I'm not familiar with since the signage and information available about HOV lanes and Park & Ride is hard to find or non-existent AND I'M A PARK & RIDE USER!
Thank you for your interest in the 2045 RTP. H-GAC appreciates you taking the time to express your concerns. These comments will be considered for the 2050 RTP. The 2045 RTP includes more focused plans such as Congestion Mitigation Air Quality (CMAQ) Plan, Regional Safety Plan and Congestion Management Process to address the congestion, air quality and safety concerns in our region. For more details please see appendices to the 2045RTP at http://www.2045rtp.com/documents.aspx.
Fellow Houstonians
TxDot grossly overstates the benefits of its NHHIP project. It uses as a base "Do Nothing" case, traffic patterns from a 20 year old H-GAC report designed to support Metro. Back then the Hardy was a ghost road, contributing little to solving congestion. Now finally under construction, the Hardy Downtown Connector project will actually make a huge contribution - carrying two lanes of traffic both ways - a contribution wrongfully claimed by TxDoT.
For example, the FEIS claims that the trip from Crosstimbers to the convention center now takes up to 77 minutes and after NHHIP it will take only 19 minutes. Quite ignored is that the 19 minute trip will actually be possible on the Hardy, long before NHHIP is completed.
It also predicts that congestion on 610 Loop east of I-45, which now slows to 12 mph, will improve to over 50 mph. Well, of course it’s slow now. Every commuter on the Hardy has to exit on 610 to get downtown and back. Fortunately, long before NHHIP is finished those commuters and thousands of others from north I-45 will be flying over 610 and the 12 mph problem will have been solved, solved once again by the Hardy Connector, not the I-45 expansion.
In thousands of pages TxDot has not credibly estimated the most important part of its project, the congestion benefit. It does not recognize that the Hardy connector, which is not even in the NHHIP budget, will bring just as many lanes and just as much peak traffic downtown as the I-45 expansion will. To make its own project look good, TxDot claims all that benefit for itself.
This is not how the project should be evaluated. NHHIP should not proceed until after the Hardy Connector is finished. Only then can we get a credible projection of its true incremental benefit potential and make a good decision about proceeding.
Thank you for your input. We will take those comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response:
The Hardy Toll Road (HTR) Extension will only function to it’s full potential as a reliever route for the NHHIP. The HCTRA HTR design without NHHIP has the two lanes each direction merging to one lane at I-10/I-69 as it has to tie into the existing I-10 to I-69 connector ramps. This will result in a mixing of traffic between users desiring to get to/from the Hardy Toll Road with users desiring to access I-10 and I-69. The NHHIP plan reconfigures the HTR Extension so that it no longer connects to a freeway to freeway connection, but instead the HTR will have a dedicated connection that gives users the option to connect to downtown or stay on the freeway. This option is ONLY possible through NHHIP.
Request criteria for evaluation of 36 a route Alternatives. To date no response has been received
Please remove TxDot alternative request illustrative route. It is suggesting a preferred route and intrudes on conserved landed, valuable to wildlife, waterfowl and wintering sandhill cranes
Unless you are crazy or stupid, provide ar least a 1 mile buffer from 36a and KPC/conserved lands.
I'd this is needed at all all, a ring by road west of 99? Use 99 and improve as required.
Thank you for your comment. Please see response from TxDOT below.
TxDOT response: While the specific evaluation criteria have not yet been established for the 36A study, these are the general steps and considerations in a feasibility study:
* Assess the need for the project
* Conduct feasibility analysis of the alternatives
* Analyze the impact of the project on the:
- transportation system - changes in travel time, safety, and vehicle operating cost
- social and economic effects - impacts to the community including the human environment, civil rights, and environmental justice, economic impacts/development, etc.
- natural systems - inlcluding air/water quality, endangered species, wildlife, greenhouse gasses, archeological, energy, and cultural and historically significant locations and structures.
While much more goes into the process, our ultimate goal of the study is to describe the potential outcomes of a given alternative so that our regional leadership can make an informed investment decision for the benefit of the region to move people and goods.
Resolution sent as an email attachment
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Thank you for your input. We will take those comment into our consideration for the 2045 RTP Amendments process. Please see the response from TxDOT below.
TxDOT response: At the request of local Fort Bend and Waller Counties leadership, the 36A projects (north and south) are in the planning stage of project development. TxDOT has not identified potential routes or the associated evaluation criteria. The 36A South segment area is experiencing high growth with increasing traffic demands and safety needs. Although less developed than the southern segment, the 36A North segment region is experiencing significant growth and development including retail/commercial and residential developments in the area and is anticipated to need an additional north/south connection to move people and goods. North/south freight movement and system connectivity between these areas is important. Including these projects in the 2045 RTP is the first step to notify the public of our intention to study this proposed corridor. Inclusion in the 2045 RTP is the start of a conversation regarding the potential for a 36A corridor that will include extensive public and stakeholder engagement and input as we consider alternative alignments for this potential project.
1. We need sidewalks all over town. It is not safe to walk anywhere, especially on East Houston Street.
2. The Brazos bus needs to run later and have more stops. My disabled daughter works at Whataburger until evening time. There is no way for her to safely get home because no transportation us available.
3. We need a taxi service available for everyone.
Thank you for your interest in the 2045 RTP. H-GAC appreciates you taking the time to express your concerns. These comments will be considered for the 2050 RTP.
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Houston-Galveston Area Council