Re-Imagine Gulf Freeway i-45 South

Dear Community Members: Friends of Fonde Park invites you to join a coalition of organizations and residents to oppose the current TXDOT's I-45S Expansion project Alternatives C and F.  Please read the comment below.

From: Karina Yonekawa-Blest <karina@friendsoffondepark.org> To: HOU-PIOwebmail@txdot.gov

The email was copied to the following City and State elected officials:

district6.alvarado@senate.texas.gov, districti@houstontx.gov, atlarge1@houstontx.gov, atlarge2@houstontx.gov, atlarge3@houstontx.gov, atlarge4@houstontx.gov, atlarge5@houstontx.gov, Christina.Morales@house.texas.gov on Oct 3, 2025, 9:32 AM

FORMAL COMMENT on Gulf Freeway PEL Study (CSJ: 0500-03-633) Opposing Recommended Alternatives C and F—A Violation of Environmental Justice and Public Trust

mailed-by:friendsoffondepark.org

To the Texas Department of Transportation, Houston District,

FORMAL COMMENT on Gulf Freeway PEL Study (CSJ: 0500-03-633) Opposing Recommended Alternatives C and F—A Violation of Environmental Justice and Public Trust

My name is Karina, and I serve as the President of the Friends of Fonde Park . Our organization advocates for the residents in Superneighborhood 69 which borders I-45 South (Gulf Freeway) from Spur 5 to 610 South, a community that stands to be permanently destroyed and severely impacted by the proposed expansion. We submit this formal comment, which must be postmarked on or before Friday, October 3, 2025, to vehemently oppose the recommendation of Alternatives C and F.

TxDOT’s Prioritization of "Stakeholders" Over the Community

The process used by TxDOT to select the recommended alternatives fundamentally violates the spirit of true public engagement. The evaluation results from the June 2024 outreach confirmed that Alternatives A and D were the highest rated by the public.

• The public overwhelmingly chose alternatives that protect our neighborhoods: Alternative A maintains existing facilities and, along with the no-build option, requires no reconstruction.

• Alternative D would actually remove one general purpose lane in each direction, demonstrating the community’s desire to scale down, not dramatically expand, this facility.

Yet, TxDOT chose Alternatives C and F as the recommended alternatives because they were the highest rated by the stakeholders.

It is shameful and wrong that TxDOT does not consider the public, the residents whose homes will be taken and whose health will decline, as the primary "stakeholders" in this process. When the public’s clear choice minimizes displacement and avoids massive construction, but is ignored in favor of alternatives (C and F) that include full reconstruction and the addition of four elevated managed lanes, we must ask: Who are TxDOT's "stakeholders" that are making these decisions? The decision suggests that government agencies, local officials, or other non-resident entities were prioritized over the families living here.

What is the point of spending public money on community engagement meetings if TxDOT will not honor the people's choice and instead prioritizes costly, massive expansion plans? This action demonstrates a failure to comply with the mandated requirement to fully assess and study all reasonable community-developed alternatives.

A Continuation of Redlining and Environmental Injustice

Our community, which has already suffered from historic disinvestment and "redlining" due to previous freeway construction, will be further redlined and suffer devastating environmental impacts by this expansion.

TxDOT is operating under the NEPA Assignment MOU, which subjects it to the same procedural and substantive requirements as the USDOT Secretary, specifically including those related to environmental justice. This includes compliance with Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low Income Populations.

Choosing Alternatives C and F—which involve massive full reconstruction, result in significant negative community impacts, and necessitate the taking of private property—is a direct contradiction of TxDOT’s obligation to ensure meaningful public engagement, including with environmental justice communities.

Imminent Domain and Refusal of Transparency

The recommendations confirm that this expansion directly threatens our homes and civic institutions:

1. Both Alternatives C and F explicitly state they require additional right-of-way.

2. Alternative F, which adds one general purpose lane in each direction, is anticipated to require more right-of-way than Alternative C.

As President of the Civic Club, I attended the last public meeting and asked TxDOT staff how much additional right-of-way Alternatives C and F are going to take. The leading TxDOT staff in the room said they did not know and were not willing to give even an approximation.

This deliberate refusal to provide critical R.O.W. data is an obstruction of the public process. How can folks know if they will lose their homes or businesses if TxDOT refuses to disclose the anticipated footprint? This lack of transparency is fundamentally wrong and prevents the public from providing informed input necessary for any genuine environmental review.

Legal Mandates Regarding Eminent Domain

We remind TxDOT and the FHWA that this aggressive approach triggers critical clauses in the NEPA Assignment MOU:

• Any project that includes residential displacements via eminent domain is specifically excluded from the list of highway projects for which TxDOT assumes environmental review responsibilities.

• If the preferred alternative identified in the environmental review process (C or F) is a highway project that is specifically excluded in subpart 3.3.2, the FHWA shall withdraw assignment of the responsibilities assumed by TxDOT for that project.

We demand that TxDOT immediately abandon Alternatives C and F. The department must honor the public's preference for Alternatives A or D, which maintain existing facilities or reduce capacity, thereby avoiding the use of eminent domain and minimizing environmental and community impacts.

Karina,

President Friends of Fonde Park

From TXDOT:

Houston: Public gets a look at Gulf Freeway’s future

In Houston, TxDOT unveiled two proposals for the future expansion of the I-45 Gulf Freeway between downtown and Beltway 8. The 14-mile corridor—passing key landmarks like the University of Houston, Texas Southern University, and Hobby Airport—could see the addition of two elevated managed lanes in each direction to ease congestion and improve safety.

One proposal retains current lane counts, while another adds a general-purpose lane in each direction. Both would include continuous sidewalks and improved frontage road access. The project remains in environmental review, with construction likely more than a decade away.

(https://www.txdot.gov/about/newsroom/stories/txdot-marked-major-progress-across-texas-in-september.html#:~:text=On%20San%20Antonio's%20far%20West,are%20expected%20to%20be%20complete. Accessed on 10-09-25

The purpose of the Gulf Freeway PEL Study is to explore transportation alternatives to address the growing safety, mobility, multimodal, and infrastructure needs along the corridor due to the projected population and employment growth in the Houston metropolitan area. The study corridor has been identified as a 14-mile stretch of I-45 South from I-69 / US 59 in Downtown Houston to BW 8 South. A series of three Public Meetings were held between 2020 and 2024 and public input from those events has been considered in the study findings. No changes will be made or proposed to the existing roadway at this time. Alternatives recommended at the conclusion of the PEL study may become future projects and would be subject to modification during the project development process.

Any environmental documentation or studies, maps and drawings showing the study location and design, tentative construction schedules, and other information regarding the study are on file and available for review by appointment Monday through Friday between the hours of 8 a.m. to 5 p.m. at the TxDOT Houston District Office, 7600 Washington Avenue, Houston, Texas 77007. Please contact the TxDOT Public Engagement Coordinator, at 713-802-5199 or by email 

as shown in the notice.

(https://www.txdot.gov/projects/hearings-meetings/houston/2025/gulf-freeway-pel-study-i45-s-from-i69us-59-to-beltway-8-south-091625.html#:~:text=The%20purpose%20of%20the%20Gulf,existing%20roadway%20at%20this%20time.)

Fact Sheet:

https://ftp.txdot.gov/pub/txdot/get-involved/hou/gulf-freeway-i-45-s/091625-fact-sheet.pdf