The Livable Oak Hill plan is the Community's preferred alternative.
Hazard to the Barton Springs Edwards Aquifer
Save Barton Creek Association has serious concerns about the Oak Hill Parkway project, a Texas Department of Transportation (TxDOT) plan at the intersection of U.S. Highway 290 and State Highway 71. While we recognize the need for improvements in the area, TxDOT’s plan for an elevated and excavated 12-lane highway is overbuilt and not appropriate for the environmental and community context is lies in. This large scale project presents potential hazards to the Barton Springs Edwards Aquifer, Williamson Creek and nearby neighborhoods.
We are especially concerned with the planned excavation in the contributing zone of the Barton Springs Edwards Aquifer, impacts to water quality, increased impervious cover and associated flood risk, and removal of heritage trees many of which are riparian habitat. To protect our community and environment, TxDOT needs to work with community and environmental groups on an alternative such as the Livable Oak Hill plan.
Joint Letter to CAMPO and Austin City Council
December 21, 2018
Re: Oak Hill Parkway
To: CAMPO Members, Austin City Council, Mike Kelly, Chris Herrington, Rob Spillar
CAMPO Members, and Austin City Council Members and staff,
Our organizations share a collective concern about the Oak Hill Parkway project(US 290/ SH 71). We recognize and applaud recent efforts of the City of Austin and TxDOT to collaborate on this project, but also recognize that there is more to be done for the construction plan to be acceptable.
We urge CAMPO to postpone voting on the TIP amendment for this project until after the Austin City Council has had an opportunity to discuss and vote on its MOU with TxDOT. This letter details some remaining concerns about the project and additional features that may be added to that agreement. Given our serious concerns about the project design itself, we also ask that your agencies evaluate the “Livable Oak Hill” alternative.
CAMPO members received a correspondence dated December 12th, 2018 from City of Austin Transportation and Watershed Protection staff. This letter was a response to issues raised by Save Barton Creek Association (SBCA) in a letter to Austin City Council on October 29th, 2018 about the Oak Hill Parkway. SBCA, Environment Texas, Sierra Club Austin Regional Group Save Our Springs Alliance, and others expressed our concerns about the project at the December 10th CAMPO Meeting.
We are glad that TxDOT has been responsive to working with COA on an Memorandum of Understanding (MOU) for this project and future projects within the Austin District. We further appreciate that these negotiations have led to incorporating many of the environmental protections Save Barton Creek Association requested into this MOU.
We still hope the following additional measures might be incorporated into such an MOU.
- Limits on excavation, especially in the recharge zone of the Barton Springs Edwards Aquifer
- That this project either meet the City’s water quality standards for the Barton Springs Zone; or an agreement is reached about an alternative equivalent that TxDOT will contribute through upgraded water quality treatment facilities on other roads in the recharge zone and/or purchase of Water Quality Protection Lands. The alternative equivalent should fully offset the amount of impervious cover added by this project.
- Avoidance of bottomland riparian habitat including trees along Williamson Creek near William Cannon and Old Bee Caves Rd intersections.
We question whether this project as conceived by TxDOT is compatible with COA transportation and land-use policies. We hope that either the current MOU being considered, or a separate one, can define COA and TxDOT’s relationship in a way to ensure that this project and others are in alignment with such policies. For example, this plan appears incompatible with the “Oak Hill Activity Center” identified in the Imagine Austin Comprehensive Plan as well as the recently adopted “Project Connect Vision Plan” which shows transit-oriented development at the Y and 290. It is not in alignment with Austin’s Vision Zero policy, to prevent traffic deaths. The “shared use path” is not sufficiently safe or accessible enough to meet Austin’s goals of having an “all-ages and abilities network” of parkland or urban trails.
The potential connectivity for a variety of road users and the recreational opportunity presented by Williamson Creek are not valued in this plan. The “Livable Oak Hill” alternative created by Save Oak Hill shows how these community values can be preserved. For instance, the current TxDOT plan includes zero north – south connections across 290 for non-motorized users that could be considered part of an “all ages and abilities network.” The Livable Oak Hill identifies two such connections, as well as a third connection across 71, that would equitably improve the overall connectivity of the community.
We think it an unfair characterization that the project is “negotiated” and “collaborative.” It is remarkable that the “90 individual stakeholder meetings, 34 e-newsletters, 14 issue-specific workshops, six Open Houses, seven Virtual Open Houses, and a Public Hearing” TxDOT mentions have yielded no significant design changes since 1995. The one significant change is the large degree of excavation which is far worse environmentally.
Neighbors in the “Fix 290” and “Save Oak Hill” coalitions have been asking for an at-grade parkway for decades, which they visualized in the Livable Oak Hill Concept you’ve all received. Instead of six lanes of frontage road, the design improves connectivity through a local complete street, allowing residents to bypass the parkway for short trips. This design would include less impervious cover, preserve many more trees, protect Williamson Creek, and avoid excavation. In other words, it is considerably better for the health of the Barton Springs Edwards Aquifer and the wider natural environment.
We would like to understand how this community-driven design has been considered. The DEIS did not analyze the community’s parkway alternative. The October 12th response letter claims that “the design with a fully at-grade roadway showed significantly more impact to Williamson Creek and its floodplain and riparian zone.” This is because the at-grade alternative referred to here includes the same 12 lanes; This is not the community’s alternative.
In summary, we appreciate the effort of all parties to begin to discuss how to make this a better project. Despite the agreement to the watershed protections in the proposed MOU, we cannot support this project.
We encourage further negotiations and continued conversations including a fair assessment of the community Livable Oak Hill alternative. We hope that the TIP amendment will not be approved until these issues are resolved. To that end, we suggest delaying a vote on the TIP amendment related to this project until an MOU between the City of Austin and TxDOT is finalized, and you are able to see what provisions are contained within it.
Save Barton Creek Association
Clean Water Action
Sierra Club, Austin Regional Group
Save Our Springs Alliance
Save Oak Hill
South Windmill Run Neighborhood Association
Vision Zero ATX
Scenic Brook Neighborhood Association
SBCA’s Position on the Oak Hill Parkway
Save Barton Creek Association
October 29, 2018
Re: Environmental Concerns regarding Oak Hill Parkway
To: Mayor Adler and Austin City Council
Cc: Mike Kelly, Ed Peacock, Chris Herrington, Environmental Commission
Save Barton Creek Association (SBCA) has serious concerns about the “Oak Hill Parkway” project. This construction project on highways US 290 and State Highway 71 West in Austin has a huge footprint in an environmentally sensitive area. It is likely to significantly degrade the Barton Springs Edwards Aquifer, local springs and wells, and waterways, especially Williamson Creek. The City of Austin and its citizens will be greatly affected by this project. We implore the Austin City Council to get involved and work with TxDOT to improve the project.
The proposed highway expansion is over the Trinity and Barton Springs Edwards Aquifers. According the Draft Environmental Impact Statement (DEIS), 64 percent (255.55 acres) of the project area lies over the contributing zone of the Barton Springs Edwards Aquifer, while 36 percent (140.09 acres) is in the recharge zone.
The project intersects with Williamson Creek which is hydrologically connected to Barton Springs and Cold Springs. According to Nico Hauwert, preeminent hydrogeologist studying the aquifer, “Since we started tracing Williamson Creek in 1997, we showed a much higher sensitivity to Barton Springs than what was previously known. Groundwater from Williamson Creek could reach it as fast as 1-2 days as opposed to years referenced in the 1989 SH45SW EIS.”
This fast recharge means that construction sediment, run-off pollution, or spills from the highway would affect local wells and Barton Springs Pool almost immediately. The project area also crosses over the Barton and Slaughter Creek watersheds.
The DEIS lists 6 known karst recharge features in the project area. Several are immediately adjacent to proposed excavation. The DEIS did not discuss the impacts to nearby Gaines Sink and Flea Market Sink, which could also be affected.
This project proposes approximately 74 acres of new impervious cover. Impervious cover decreases recharge by blocking recharge features and removing vegetation; and decreases water quality through run-off pollution.
While SBCA encourages the use of Best Management Practices (BMPs) during construction and water quality ponds to treat run-off, even the best BMPs and water quality treatment features will not be able to fully mitigate the enormous environmental impacts of this project. For example, construction BMPs may fill large voids (recharge features), but the karst environment will transport pollutants through small unmitigated features as well. Further, lack of available land in the right locations will render it impossible to fully treat all of the run-off from this project.
Below, we make recommendations for substantive project changes and for mitigation through BMPs that would lessen environmental harm. Save Barton Creek Association implores the City of Austin not to enter into contracts or dedicate funds to this project unless TxDOT will work with the City on the below recommendations.
Recommendations for TxDOT
- Remove the 2.65 miles of excavation from the project. Excavation is arguably the most significant impact this project will have on water quality and quantity in the Barton Springs and Trinity Aquifers. The proposal would dig up and remove 1,968,000 cu yards of earth and rock, digging 25 ft into rock above the aquifers. For perspective, that is more than the entire volume from floor to ceiling of the Astrodome, 3/5 the size of the Great Pyramid of Giza, or more than three feet depth covering I35 from Austin to San Marcos.
Excavation poses numerous problems. During construction, scraping this much earth will lead to significant sedimentation in the aquifer, creek, and recharge features. The excavation will also cut off underground flow paths. Based on his hydrologic studies, Nico Hauwert says that water held in the Upper Glenrose Formation “typically discharges from springs or may flow in the subsurface to the Edwards Aquifer. Excavations in the Upper Glen Rose Formation may potentially redirect shallow flows from their original destination or replace it with new sources such as roadway runoff.”
Excavation was not in the original project scope and was only included in the most recent proposal due to neighborhood concerns about a triple decker highway at the Y. Neighborhood residents were seeking an at-grade parkway, not excavation.
When asked what the alternatives to excavation could be, TxDOT team said “The alternative to excavating would be to have the mainlanes raised which is opposite of the community feedback we have received through the years. Currently we are going no higher than the existing Pizza Garden. Otherwise, the overall height would be increased.”
This response is not an adequate analysis of alternatives. The original twelve lanes in the project incorporated six tolled mainlanes and six non-tolled parallel frontage road lanes. This is now planned as a completely untolled project and citizens in the Fix 290 coalition have argued that therefore access lanes are unnecessary in the critical piece of the project near the Y which sits between a cliff and Williamson Creek. We agree.
TxDot should not excavate. Instead, they should remove access lanes between the “Y” intersection and the US 290 bridge over Williamson Creek. They are already acquiring two commercial properties and one residential property as part of this project. Buying out three more businesses eliminates the need for access roads in this area. If absolutely necessary, they should return to entirely elevated lanes instead of depressed lanes in other areas of the project.
While we hold that no excavation is necessary in this project, it is especially important that no excavation is done from the Y to William Cannon, because the Balcones Fault Zone will rush this sediment into the aquifer. The DEIS lists 6 known karst recharge features in the project area, including several immediately adjacent to proposed excavation.
Furthermore, the DEIS recognizes several endangered species including the Austin Blind Salamander and Barton Springs Salamander that could be impacted by this project. We know that these amphibians are very sensitive to pollution. This project is in an environmentally sensitive ecoregion, and as such it is not appropriate to excavate.
- Act sensitively toward Williamson Creek. This should include a detailed mitigation and restoration plan for areas altered through overbank mitigation to increase ecological function over pre-construction conditions; as well as preservation of bottomland riparian vegetation and creek ecology; and preserving adequate space on either side of the creek for riparian habitat and a greenbelt trail.
The current plan calls for conducting overbank mitigation of Williamson Creek in 4 locations, or for a total of 2,700 feet. TxDot says that they are revising their schematics so this number may change. Overbank mitigation, also called benching, widens the channel starting 5 feet above the bottom of the creek. This preserves the ecology at the center of the creek, and if properly planned, allows the riparian ecosystem to heal.
According to the Watershed Protection Department at the City of Austin(COA Watershed), “The worst losses, from a floodplain and riparian perspective are in and around the 290/William Cannon intersection, where some of the best bottomland vegetation occurs in the wide channel there…there will be significant removal of mature riparian vegetation, including large sycamores, willows and cottonwoods.” Local citizens are also aware of mature bottomland vegetation and bedrock lined pools, with possible recharge features, upstream of Old Bee Caves road that is also slated for overbank mitigation. For this reason, TxDot should re-evaluate their plan by more accurately describing the conditions in these two areas and avoiding damaging this high quality riparian habitat.
In the other overbank mitigation locations, TxDOT should provide a detailed mitigation and restoration plan as part of the Construction Environmental Compliance Plan and also include these actions in bid items and call-outs on the construction plan sets. TxDOT did this in the SH45 project. Through these actions, the benched areas will be able to recover.
Austin’s Watershed Protection Department “expects to see these benched areas recover, assuming they get robust restoration treatment, including follow-up to insure sufficient diversity, cover and removal of invasive species.”
We also suggest preserving adequate greenbelt on either side of creek that supports ecological function and improves the atmosphere around the proposed shared use path. SCBA does not support the channelization of Williamson Creek near William Cannon or in healthy bottomland habitat upstream of Old Bee Caves Road, and instead recommends that the design avoid this sensitive habitat. We also want to see a restoration plan that includes the input of COA Watershed Protection.
- Comply with DEIS Comments from Austin Watershed Protection Department. TxDOT should work with Austin Watershed Protection Department as a partner. Watershed has offered to build and maintain the water quality ponds as a part of this project. This gesture should be met with a commitment by TxDOT to provide funds for the purchase of Water Quality Protection Lands. TxDOT should be asked to provide funding for Water Quality Protection Lands because (1) due to available land area in the right locations, run-off may not be fully mitigated and (2) because this project will speed up development over the Barton Springs Edwards Aquifer, through the proven concept of “induced demand”. Increased highway capacity will lead to increased development and use of that capacity. The City of Austin will need to purchase more water quality lands to maintain water quality at current levels, because of the impact of this project.
TxDOT should comply with the other recommendations in Watershed’s DEIS comments including flood detention requirements, and inviting COA Watershed to contribute as part of design team through design, prevention, inspection, and mitigation of voids. We also recommend TxDOT work closely with the Barton Springs Edwards Aquifer Conservation District(BSEACD) on these plans, also allowing them to participate in design, prevention, inspection, and mitigation of voids.
- Avoid Historic Oak Trees to the maximum extent possible. The DEIS states that the project will remove 281 trees greater than 10 inches DBH. Many of these are trees that are legacy, heritage, or protected trees by City of Austin standards. Oak Hill citizens conducted a tree study that can be found at SaveOakHill.com that geolocates the trees, indicates their size, protected status according to the City of Austin regulations, and includes photographs. We have not yet seen a study from TxDOT that shows exactly which of these trees will be taken by the project. TxDOT should work with the COA arborist to ensure the plans do in fact save trees. For example, it looks like even “saved trees” in the plan will have their root zone cut into, likely killing the trees. They should also pay close attention to the proposed overbank mitigation to avoid these protected trees.
The project should do everything possible to protect legacy and heritage trees and specifically should protect the trees and habitat that are part of the bottomlands of Williamson Creek near William Cannon Drive and upstream of Old Bee Caves Rd.
- Include the points below in the Construction Environmental Compliance Plan. This plan should be drafted through collaborative meetings with COA Watershed Protection, environmental nonprofits, and the Barton Springs Edwards Aquifer Conservation District.
- Utilize Best Management Practice (BMP) construction phase erosion and sedimentation controls to protect aquifer and Williamson Creek to the maximum possible extent.
- Avoid recharge features encountered during construction, not just filling potentially significant features. The design-build nature of this project gives the opportunity to change the design if these features are encountered. Clean water should be diverted to recharge features, avoiding roadway run-off reaching these features.
- Work with Barton Springs District and COA Watershed Protection on Void Mitigation protocol. Allow COA and BSEACD to monitor any voids encountered during construction.
- Hazardous material spill plan and infrastructure, since a spill could almost immediately affect nearby wells and pollute Barton Springs and threaten endangered salamanders within two days. This may include a plan to shut down the water quality ponds if hazardous materials were to enter them.
- Proper protocol for saving protected trees including input from COA arborist
- Proper protocol for restoring creek habitats after overbank mitigation, including appropriate plantings.
- COA environmental staff and BSEACD have the right to oversee construction and environmental compliance.
Save Barton Creek Association strongly urges the Austin City Council to pass a resolution that identifies the City of Austin’s goals as they relate to this project, and direct staff to negotiate with TxDOT for these community and environmental benefits.
A City Council Resolution might include reaffirming the prior council’s support for a ‘parkway concept,’ trying to get this project as close to possible to meeting that ground-level roadway design vision. It should also lay out the priorities for watershed protection above, including a taking position against excavation in this project. It should also ask TxDOT to work closely with COA staff including transportation and environmental staff.
Further, a resolution should give council, not staff, the authority to enter into contracts with TxDOT to ensure that city-wide community needs are being met, and that valuable leverage is not given away. Council approval of any contract or funding connected to this project should be based on a conclusion that the project will improve traffic flow without significantly damaging the aquifer, environmental resources, or nearby neighborhoods. The City needs to be creative in partnering on this project, offering resources and funds including 2016 bond funding only if the project will not harm the qualities that make Austin so special.
In the Imagine Austin Comprehensive Plan, the project area was in the Oak Hill Activity Center, which was defined by a mix of uses and multiple transportation options. This project must be built in such a way that it preserves water and environmental resources and gives future citizens of Oak Hill a high quality of life, including the opportunity to walk and bike along Williamson Creek, and utilize future public transit.
Please consider the importance of this project to Austin’s future. What is Austin without Barton Springs? What is Oak Hill without its heritage oaks?
Thank you for considering this important matter.
Save Barton Creek Association