Dallas Houston HSR needs to return to the drawing board: County Roads cannot be rerouted for project, No sales tax revenue for Dallas or Houston, Project is Net Positive for greenhouse gases in Houston’s Nonattainment Area, No economic benefit forecast, Project needs 8000 acres instead of 3000 acres
Jewett, Texas – Texans Against High-Speed Rail submitted a 504-page document to the Federal Railroad Administration with comments pertaining to its Draft Environmental Impact Statement (DEIS) for the Dallas Houston HSR. With a team of impacted landowners, experts and attorneys, all supported through donations of time and funds from individual landowners, this document identifies the many issues surrounding both the Dallas Houston HSR project as a whole and, specifically, the DEIS document and process.
Kyle Workman, President of Texans Against HSR, noted following the submission of the official TAHSR comments to the Federal Railroad Administration (FRA), “The recently issued DEIS clearly indicates Texas Central is not a railroad. Because the company does not have the power of Eminent Domain, this has led to incomplete environmental assessments throughout the proposed corridor. More than 80 miles of the proposed line has not been surveyed. Additionally, the errors and inconsistencies within the document highlight the systemic flaws in the project and promoter…if they were a railroad company, this document would look like it, as much of the information was provided directly from Texas Central. If they can’t get straightforward concepts correct, how are we to then entrust this company with public safety while operating a railroad if we cannot trust the project has been properly vetted. The FRA needs to go back to the drawing board, correct the errors, and include important information such as ridership and revenue forecasts, then reissue the DEIS for further public comment.”
County Road Authority
One of the most impactful errors of the DEIS is the assumption that Texas Central has any authority or coordination with County Governments to reroute or realign public roads. Under Texas Transportation Code 251, County Governments have general authority of their roads within their jurisdiction. Over the last several weeks, each County has passed or is in the process of passing resolutions clarifying it will not allow the realignment or rerouting of public roads for this proposed HSR project. Further, each County Commissioners Court between Harris and Dallas Counties have relayed to the FRA that it cannot review the DEIS and comment regarding its impact to the County until the document presents a plan that, in accordance to Texas law, is consistent with the County policy. Additionally, the Counties have informed Texas Central that any new or additional roads built to service the project will not be received by the County for ongoing upkeep without a long-term maintenance reimbursement plan in place.
Sales Tax Revenue from Ticket Sales
Texas Central has made very public claims that its project will generate up to $12 million dollars in sales tax revenue from ticket sales exclusively for both the Cities of Houston and Dallas. However, the DEIS failed to realize that transportation services in Texas are not eligible for sales tax. In a different section of the DEIS, it claimed that $16 to $39 billion could be generated in sales and local tax revenue from ticket sales alone.
Within the DEIS, the Vehicle Miles Traveled, which is used to indicate emissions removed from the road, was calculated incorrectly. When calculated correctly, the proposed project is Net Positive, meaning increased greenhouse gases, for greenhouse gases in Nonattainment Areas.
Purpose and Need
When the FRA began its scoping report for the project, economic viability was included as one of the criteria under which the project would be evaluated. However, since the scoping meetings in 2014, that element was removed from the FRA’s consideration for the project’s purpose and need so they did not review the economic viability of the project. The DEIS includes no independent evaluation of Texas Central’s ridership or revenue projects which would confirm that Texas Central’s project would take thousands of acres of Texas private property for a project that is widely known to be projected to fail spectacularly. The project presented in 2014 is not the project that was presented for review in the DEIS.
Texas Central Credibility
Upon publication of the DEIS in December 2017, much of what Texas Central Railway had told the public and elected officials for the previous few years could only be described as fantasy. Texas Central claimed the project would need 3000 acres, but according to the FRA, the number has ballooned to around 8000 acres. Soon after the document was released, Texas Central began claiming information in the FRA document was not accurate…despite the fact that much of the information came directly from Texas Central and their teams. What is the public to believe? Additionally, Texas Central manipulated public comments by offering the chance to win a toy replica of the N700 Shinkansen train for positive comments about the project through the company’s website.
In addition to the comments offered by Texans Against HSR, the following have indicated similar serious concern with the proposed HSR project, with several calling for a fresh start to the EIS process. Texas Commissioner of Agriculture Sid Miller, Texas and Southwestern Cattle Raisers Association, Sheriff’s Coalition and County Commissioners Courts (Ellis, Navarro, Limestone, Freestone, Leon, Madison, Grimes, Waller Counties), Citizens Transportation Coalition, and SNCF America, Inc