People Organized in Defense of Earth and her Resources
December 5, 2006
Senator Gonzalo Barrientos, Chair
CAMPO Board
P.O. Box 1088
Austin, TX 78767
Mr. Bob Tesch, Chair
CTRMA Board
301 Congress Ave., Suite 650
Austin, TX 78701
Dear Senator Barrientos and Mr. Tesch:
I am writing on behalf of PODER to provide comments on the Analysis of Effects of the Austin Regional Toll System on Environmental Justice Populations so that these comments may be considered as CAMPO and the CTRMA deliberate on the Phase II Toll Road Plan. We strongly feel that the Phase II Toll Road Plan, if implemented as currently proposed, will have a disparate negative impact on low-income and minority communities in Austin.
On August 14, 2006, PODER delivered a letter to the CAMPO board conveying our concerns about the disproportionate adverse impacts that the toll road system would have on low-income and minority populations. These comments were submitted before the above-referenced document, hereinafter referred to as The Toll System EJ Study, was made available to the public. The Toll System EJ Study suggests that the proposed plan would not have and adverse impact on low-income and minority populations. We strongly feel that this analysis is fundamentally flawed and would like to point out some of the specific shortcomings in the study. We urge CAMPO and CTRMA to requests that the authors of this report revise their analysis for the purpose of addressing the issues raised below. We further request that CAMPO and CTRMA take no action on the Phase II Toll Road Plan until these issues have been adequately addressed.
Lane Mile Distribution
The authors of the Toll System EJ Study claim that there exists no quantitative data that may be used to assess the effect of the regional toll system on environmental justice populations (pg. 6 and pg. 45). The authors of this report used this finding as a reason to fail to conduct a thorough analysis of the geographical impact of the toll system.
The study very clearly lays out the location of environmental justice populations, as well as the breakdown of the lane miles of the toll system located within EJ areas and outside EJ areas (see attached maps and figures). Because the authors analysis considered the distribution of the entire toll system and not Phase I and Phase II portions of the system separately, it failed to identify the disparate effect of the Phase II Toll Road Plan.
If you consider Phase I separately, the report indicates that 265 lane miles are located within EJ areas and 271 lane miles are located outside EJ areas.
Before tallying the lane miles inside and outside EJ areas for the Phase II Toll Road Plan, it is beneficial to consider what roads constitute Phase II. The roads typically associated with Phase II are:
SH 45 SW
SH 71 W
US 290 E
US 290 W
Loop 360
US 183 S
SH 71 E
Because it has been widely reported that no funding has been included in the Phase II Toll Road Plan for Loop 360, the lane miles for this road should not be included in the comparison of lane miles inside and outside EJ areas for the Phase II Toll Road Plan. Further, since it appears that there is insufficient right-of-way to provide a non-toll alternative to SH 45 SW, then the future of this road is also highly uncertain, and thus the lane miles for this road should not be included in a comparison of lanes miles inside and outside EJ areas for the Phase II Toll Road Plan.
If you compare the remaining toll roads that comprise Phase II, you discover that
143 miles are located within EJ areas and only 36 miles are located outside EJ areas.
In other words, of the roads that comprise the Phase II Toll Road Plan, 80% of the lane miles will be located within EJ areas.
Revenue Generation
The Draft Mobility Alternatives Finance Study (MAFS) provides some relevant revenue information for the Phase II Toll Road Plan. The MAFS assumes that the revenues produced by the proposed Phase II Toll Roads will be as follows:
SH 45 SW 12 %
SH 71 W 3 %
US 290 E 14 %
US 290 W 6 %
Loop 360 33 %
US 183 S 18 %
SH 71 E 15 %
However, if we make the same assumptions for Phase II regarding SH 45 SW and Loop 360 that we outlined in the previous section on Lane Mile Distribution, we find that:
83.9% of revenues for Phase II will come from the toll roads inside EJ areas and only 16.1% will come from toll roads outside EJ areas.
The Toll System EJ Study does not consider the issue of toll revenues from toll roads inside EJ areas being used to fund toll roads outside EJ areas. This is a significant oversight.
Time Travel Analysis
The travel time analysis also seems to have possibly overlooked some very important factors. The study found that the Toll Build Alternative (vs. the No Toll Build Alternative) did not cause greater than a 5-minute delay or greater than a 28% delay for persons residing in EJ areas. We find this difficult to believe if one considers the fact that a high proportion of the residents of the EJ areas are of low and moderate income. If these residents choose to use the non-toll alternative (e.g., choose to not pay the toll and use the access roads), it seem reasonable to assume that they will be delayed by more than 5 minutes. For this reason, it appears that there are some flaws with regard to the assumptions made in the travel time analysis with regard to persons living in EJ areas.
Public Involvement
The Toll System EJ Study found that there had been adequate opportunities for persons residing in EJ areas to provide meaningful input into the process. The Toll System Plan has gone through many different changes since the public dialogue on the proposal began. Thus, the input received regarding the overall toll road plan may differ significantly from the input that would be received if a concerted public involvement campaign were to be conducted regarding Phase II as currently proposed. Given the potential adverse impact of the Phase II Toll Road Plan on environmental justice populations that were outlined above, it appears that CAMPO and the CTRMA should seek further input from these stakeholders before proceeding.
There is a huge difference between East Austin tolls and other tolls that will be created across Austin. None of the other tolls in Phase I or II were 100% funded. Phase I doesnt take already funded public highways and shift them to toll ways. Shifting our East Austin expressways such as US 290 East, US 183 East and SH 71, to tolls roads will impact low-income and people of color communities while other, more affluent communities drive their expressways for free. Tolling and privatizing East Austin public highways is environmental injustice.
I hope that you will give serious consideration to these issues as you move forward with your deliberations on the Phase II Toll Road Plan. Please do not hesitate to contact me if you have any questions.
Sincerely,
Susana Almanza
Executive Director
P.O. Box 6237 Austin, Texas 78762-6237
Email: poder@austin.rr. com
website: www.poder-texas.org
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1 comment:
Dear Susana: Thank you for your thoughtful and complete analysis of the Austin Boondoogle Tolls. It is excellent. I'm going to use this to hopefully bring my husband around to our point of view. he currently believes the TTC and tolling our roads is ok. i believe it is not.
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