Houston Parks Board in comments submitted to Quincy Allen, Houston District Engineer Texas Department of Transportation, has raised several significant issues with the highway expansion project and its impact on local parks. It includes several disturbing before and after images of the impact of the project.
You can read the full comments here.
Some highlights:
The EIS (Environment Impact Statement) remains flawed in failing to acknowledge White Oak Bayou Greenway north of UHD (University of Houston Downtown) as public parkland, thereby triggering the requirements of Section 4(f) of the U.S. Department of Transportation Act of 1966. Per the Federal Transit Administration:
Section 4(f) of the U.S. Department of Transportation (USDOT) Act of 1966 prohibits the FTA and other USDOT agencies from using land from publicly owned parks, recreation areas (including recreational trails), wildlife and water fowl refuges, or public and private historic properties, unless there is no feasible and prudent alternative to that use and the action includes all possible planning to minimize harm to the property resulting from such a use.
The NHHIP reroutes 20 lanes of highway with some 7 new overpasses directly over the presently open parkland upstream of UHD. That impact is far more significant both qualitatively and in its overall scope and scale than what would be removed. HPB had previously noted a net impact to 18 acres of open space.
HPB had commissioned its own visual impact analysis of NHHIP at White Oak Bayou Greenway Park (Exhibit A). We have shown it to a number of community groups over the past year. At each showing it elicits strong reactions of surprised shock. Again, the visual impact analysis should have been included in the DEIS (Draft Environmental Impact Statement) so that the public could understand the significant impact during the main comment period.
We maintain our position that TxDOT has not met its responsibilities under Section 4(f) to avoid and mitigate impacts on parkland as the DEIS and the recent additional technical reports fail to acknowledge these impacts. The impacts to parkland are not just visual and noise but extend to habitat, flooding and water quality as well. Even where TxDOT has the opportunity to mitigate through landscape or use of detention as parkland, the analysis minimizes or dismisses the opportunity.