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Dave Dobbs critiques S.H. 130
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Dave Dobbs

Texas Association for Public Transportation

9702 Swansons Ranch Road

Austin, Texas 78748-1424

(512) 282-1149

Fax (512) 282-5621

ddobbs@bga.com

20 March 2000

Mr. Brett Jackson
Federal Highway Administration
Room 826, Federal Building
300 East 8th Street
Austin, Texas 78701
 
Ref: (A) Our phone conversation of Friday, March 17, 2000
       (B) My fax of Union Pacific Railroad‚s criteria for freight rail
 
Dear Mr. Jackson:
 
In reference (A) we discussed SH 130 design relative to the requirements for freight railroad as laid out by Union Pacific, this region's only major freight railroad company. Officially, I repeat what I said to you on the phone; SH 130 as currently designed does not meet the gradients and curvatures Union Pacific requires for freight operations. Enclosed here is a copy of the document I faxed you which contains this information. [Write to Dave if you would like a copy of this document.] This document was a part of an ATS/CMTA sponsored regional transportation charrette, at the Capitol Marriott, May 22/23, 1997 that I attended.
 
During our phone conversation you raised the suitability of SH 130 ROW [right of way] for passenger rail and I agreed that it probably could be used for that. In reality, once the road is constructed, it is highly unlikely this will ever happen. One reason, of course, is the cost of accessessing highway ROW after the fact vis-a-vis stations as opposed to designing and building a road/rail facility from the outset. Proposed light rail stations for the center of U.S. 183 in the Transit Corridor Analysis Project (1986-1989) were estimated in excess of $1 million apiece. Another reason urban rail transit becomes less likely once the road is in place has to do with the sprawl land use impacts engendered by the highway. The real return from rail transit is from the high density high tax return on low capital infrastructure costs that are possible by reducing auto usage and parking lots. The pay back from an-after-the-fact urban rail installation in SH 130 will be far slower if strip development and traditional suburban development has taken place, as it no doubt will under the current state and federal funding arrangements that puts disproportionate funding into pavement. This fact prompted acting Capital Metro General Manager Norma Robinson in a 1988 letter to various public bodies concerned with Mokan (SH 130), to point out that highway would have to be constructed without frontage roads in the urbanized area if it was ever to be suitable for transit. Like the freight parameters, this requirement, too, has been mostly ignored by TxDot in the design throughout road‚s urban area transit. This is history repeating itself with respect to TxDOT ignoring official requests from governmental bodies. In 1983 and 1984 we pointed out that the proposed U.S. 183 need to have 33 feet in the center throughout its entire length if two way transit was to be installed in the future. Two designs were possible; one with 7 feet and the other with 33 feet in the middle between Burnet Road and IH35. After at least two letters from local FWHA administrator, John Conrado, and resolutions from Capital Metro, the Travis County Commissioner's Court and the Austin City Council calling for the 33 feet, the 7 foot option was built.
 
Now I would add my voice, as I told you on the phone, to those would pointed out the falsehood of claiming this facility will relieve congestion on IH 35 when the TxDOT numbers show only 8% relieve at the bridge if SH 130 were a regular freeway and then ignore the fact that SH 130 is being put forth as a toll road. Besides, with traffic growing at 3% per year on IH35, SH 130‚s billion dollar cost for even 8% relieve is ridiculous. As Rob Dickson‚s letter points out in citing 15 years of Texas Transportation Institute studies of 70 cities, roads cause, not solve congestion. There is, of course, the farmland issue, both the loss of farmland and the failure of the DEIS to address the Farmland Protection Act as noted by Jim Vance.
 
In closing, it seems unconscionable to take a perfectly good urban rail option and essentially trash it for a road that will return far far less for the money. The DEIS takes no account of the secondary infrastructure and service costs put on local governmental taxing bodies and the resulting years of debt service while local government waits for the new development to reach the critical mass necessary to pay for itself. With energy prices going in only one direction-up, for the foreseeable future, SH 130 is an extremely unwise decision especially when the alternatives are clearly so much wiser.
 
Sincerely,
 
Dave Dobbs
Executive Director

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