NEPA Comments
TTC-35 Tier One DEIS
August 21, 2006 has filed additional written comments on behalf its members.





AUGUST 21, 2006


Comments made on behalf the more than 5,000 members of who live and/or own land in 186 Texas counties including all 38 counties within the preferred corridor and reasonable corridor alternates the subject of this TTC-35 Draft Environmental Impact Statement.

TIER ONE DRAFT ENVIRONMENTAL IMPACT STATEMENT COMMENTS is extremely concerned about the potential environmental and community issues related to the development of the Trans Texas Corridor (TTC). We are particularly concerned about the lack of planning coordination demonstrated from the conception of this proposed project. That lack of planning coordination undermines early identification of fatal flaws; decreases opportunities to identify and avoid environmental and community issues; and, therefore prevents the mitigation of those issues.

It is important to recognize that state transportation officials adopted the TTC plan and advanced it well beyond the plan development stage without seeking or receiving any significant public comment. Before the initiation of the NEPA process there was virtually no dialogue with public officials or the general public that resulted in meaningful public comment. This project has rapidly progressed from concept, to execution of a development agreement, and to Tier One DEIS without public debate of need and purpose. Accordingly, public input now sought and received is coming from public officials and a general public that are not informed adequately to understand the TTC, the scope of the project or the potential environmental and community risks. Despite the poor level of public communication, public comments that have been made during Tier One public hearings have overwhelmingly opposed all twelve build alternatives. is particularly concerned about:

  • Quality of life impacts;
  • Impact and costs to the natural environment and wildlife;
  • Impact to watersheds;
  • Loss of valuable natural and recreational areas;
  • Loss of private property and subsequent dislocation of families, businesses, small towns and communities;
  • Loss of valuable farm land;
  • Destruction of the viability of farms and ranches;
  • Speculative nature of acquiring land well in advance of any reasonably projected or demonstrated need;
  • Impact to tourism;
  • Disruption of existing local and regional transportation routes; and,
  • Costs to counties and communities along the alignment. does not believe that these issues were properly nor fully taken into consideration during any period of developing the TTC plan.

Existing environmental review processes in Texas are not equipped to handle a project of this scope. The multiple components such as highway, rail, pipeline, and transmission lines require analysis performed in an all inclusive approach to properly address the combined affect these multiple components will have on environmental issues.

The size of the proposed TTC will unavoidably impact every community in the central Texas corridor. The development of a multi-modal corridor will have substantial costs to the citizens of Texas that may not be offset by equal benefit. believes that there is insufficient data available to judge the overall feasibility.

Community issues include loss of a sense of place, loss of community fabric, dislocation and other quality of life concerns. These issues are of the same importance as other environmental effects in determining the overall impact and feasibility of the TTC.

The TTC alignment is predominately within undeveloped and rural land. Future development pressures near the corridor will increase the potential for inappropriate conversion of undeveloped land into sprawling, low-density development. While access to the TTC would likely be limited to few locations, there will be pressure for development where adequate public facilities and service do not exist and cannot be provided in an efficient manner.

The TTC has not been coordinated with regional, county nor city transportation plans. This lack of coordination threatens the efficiency of the overall transportation objectives.

The TTC has the potential to redirect traffic and resulting economic development away from existing regions and communities. The result would be a substantial threat to business retention and a loss of economic opportunities for existing communities and businesses.

By design the TTC takes an excessive right-of-way (ROW) width for its alignment. Every proposed element/facility in the TTC plan for construction over the next 50-years can be built inside a typical ROW of 756-feet. No justification, purpose, or need has been identified or disclosed for taking the additional 435-feet of ROW width. This excessive taking of private property is an abuse of economic and personal rights of property owners.

The TTC will impact recreational opportunities through loss of open space and by creating an access barrier.

The TTC will adversely impact fish and wildlife habitat and migration patterns.

The TTC will adversely impact air quality by providing alignments that increase the travel distance between metropolitan centers. Longer travel distances will generate additional air pollution from the consumption of gasoline and diesel fuels. As proposed the TTC will adversely impact air quality by allowing higher vehicle speeds that will increase the generation of air pollution resulting from diminished combustion engine vehicle efficiency.

As an unprecedented large state-wide project impacting a large segment of the state’s population, the TTC requires significant effort to involve the public in all stages of planning. No such effort has been made, nor has the state demonstrated any responsiveness to the small amount of public input that has been received prior to the Tier One public hearings.

TTC planning has not adequately considered social and economic effects. Various population groups within the region may be affected quite differently in terms of mixes of socioeconomic effects.

Transportation corridors do not automatically create private sector investments and jobs.

The TTC will have negative impacts on the socioeconomic fabric of nearby communities. A lack of accessibility along the new corridor will create a number of social and economic impacts on those communities. Both access to the TTC and the ability to transverse the TTC at reasonable intervals will have substantial impact to rural Texas.

Social impacts include a loss of community cohesion, loss of land and diminished access as well as barrier effects. Travel patterns, accessibility, mobility, social cohesion of established communities, and economic viability of established businesses will be indirectly impacted by the TTC.

Many rural citizens derive their sense of place from the geographic isolation that will be disrupted by proximity to the TTC.

The TTC will result in the loss of farm and ranch land. Texas farms and ranches represent a unique combination of residence and business. Unlike urban and suburban residences and businesses, farms and ranches cannot be relocated. This will leave the owners without homes or income.

The TTC will create a barrier effect in several respects. It will divide large properties, including farms and ranches rendering the properties useless or diminishing their current use. The separation of farm land could take farms out of production by preventing the efficient movement of farming equipment between fields separated by the corridor.

The TTC will inhibit localized movement of people and commerce. Neighborhoods and areas such as church parishes and public school districts could be separated. Access to family, schools, doctors, hospitals, stores and other local destinations will be inhibited. Delivery of emergency services such as fire, emergency medical, and law enforcement will be impacted by the barrier effect, especially in rural Texas. The result will be reduced community cohesion and lowered qualify of life.

Land values adjacent to the TTC will likely decline in value as function of their proximity to the TTC and the undesirable visual, noise and air quality impact to the environment. Land values may also significantly decline as the result of access and their local barrier effect.

The proposed TTC would be a significant alteration of the current surface transportation system in the State of Texas. While it has the potential to improve the movement of freight and people across the state, it also has the resulting potential for extensive impacts to existing environmental and community resources. As discussed, these potential impacts are directed upon multiple issues and resources in both the natural environment and the communities in and around the proposed corridor area. These potential impacts play a significant role in determining the overall corridor’s feasibility. They warrant further study to increase the overall understanding of the full potential effect of the TTC.

For these and other reasons, strongly supports the No-Build Alternative.

Respectfully submitted,


David K. Stall

On Behalf of:
Fayetteville, TX 78940-5468

August 21, 2006
By U.S. Priority Mail




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