Indirect Impacts Technical Report - 183 North · 08/04/2016  · substantial indirect effects, and...

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Indirect Impacts Technical Report 183 North Mobility Project, Travis and Williamson Counties From SH 45/RM 620 to Loop 1 (MoPac) Austin District CSJs: 0151-05-100 & 3136-01-185 April 2016 The environmental review, consultation, and other actions required by applicable Federal environmental laws for this project are being, or have been, carried-out by TxDOT pursuant to 23 U.S.C. 327 and a Memorandum of Understanding dated December 16, 2014, and executed by FHWA and TxDOT

Transcript of Indirect Impacts Technical Report - 183 North · 08/04/2016  · substantial indirect effects, and...

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Indirect Impacts

Technical Report

183 North Mobility Project, Travis and Williamson Counties

From SH 45/RM 620 to Loop 1 (MoPac)

Austin District

CSJs: 0151-05-100 & 3136-01-185

April 2016

The environmental review, consultation, and other actions required by applicable Federal environmental laws

for this project are being, or have been, carried-out by TxDOT pursuant to 23 U.S.C. 327 and a Memorandum of

Understanding dated December 16, 2014, and executed by FHWA and TxDOT

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TABLE OF CONTENTS

1.0 INTRODUCTION ............................................................................................................. 1

2.0 GUIDANCE ..................................................................................................................... 1

3.0 SCOPING ........................................................................................................................ 3

3.1 Summary of Scoping Activities Completed ................................................................... 3

3.2 Description of the Project’s Area of Influence ............................................................... 4

4.0 RESOURCES ANALYZED FOR INDIRECT IMPACTS ................................................... 8

5.0 GOALS AND TRENDS .................................................................................................... 9

5.1 Goals ..........................................................................................................................12

City of Austin ..................................................................................................................12

Travis County .................................................................................................................12

Travis County and City of Austin – Balcones Canyonlands Conservation Plan (BCCP) ..13

City of Jonestown ...........................................................................................................14

City of Cedar Park ..........................................................................................................14

City of Leander ...............................................................................................................14

City of Liberty Hill ...........................................................................................................15

City of Bertram ...............................................................................................................15

City of Burnet..................................................................................................................16

Williamson County ..........................................................................................................16

Williamson County Conservation Foundation – Regional Habitat Conservation Plan......16

Burnet County ................................................................................................................16

Capital Area Metropolitan Planning Organization (CAMPO) ...........................................17

5.2 Trends ........................................................................................................................17

5.2.1 Population and Housing Development .................................................................17

6.0 IMPACT-CAUSING ACTIVITIES TABLE AND SUMMARY .............................................23

7.0 POTENTIALLY SUBSTANTIAL INDIRECT IMPACTS ....................................................25

7.1 Methodology ...............................................................................................................31

7.2 Access Alteration (Induced Growth) ............................................................................31

7.2.1 Quantification of Developable Land .....................................................................31

7.2.2 Planning Expert Questionnaire and Responses ...................................................34

Common Threads from Survey Responses: ...................................................................35

Other Main Points made by Survey Respondents: .........................................................35

7.2.3 Likelihood of Induced Growth on Developable Land ............................................37

7.3 Indirect Effects Potentially Resulting from Induced Growth .........................................39

Threatened and Endangered Species ............................................................................39

Water Resources ............................................................................................................40

8.0 MINIMIZATION AND MITIGATION .................................................................................40

8.1 Threatened and Endangered Species .........................................................................40

8.2 Water Resources ........................................................................................................41

8.3 Various Municipal Codes and Land Development Regulations ...................................44

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8.3.1 Municipalities .......................................................................................................44

8.3.2 Counties ..............................................................................................................45

9.0 CONCLUSIONS .............................................................................................................45

10.0 REFERENCES ...............................................................................................................47

LIST OF TABLES

Table 1: Public Stakeholder Meetings ........................................................................................ 4

Table 2: Agency Stakeholder Meetings ...................................................................................... 4

Table 3: Risk Assessment Screening Tool – Induced Development ........................................... 8

Table 4: Current and Historic Population Growth in the AOI ......................................................18

Table 5: Projected Population Growth in the AOI, 2010-2040 ...................................................19

Table 6: Single-Family New Home Construction Building ..........................................................20

Table 7: Year Structure Built/Percent Built within Decade for Jurisdictions in AOI, 1970 - 2013 21

Table 8: Projected Employment by County into 2035 ................................................................22

Table 9: Impact-Causing Activities ............................................................................................23

Table 10: Resources Analyzed for Indirect Impacts ..................................................................26

Table 11: Acres of Land Available for Project-Influenced Development within AOI ..................32

Table 12: Indirect & Cumulative Effects Questionnaire Recipients ............................................34

LIST OF FIGURES

Figure 1: Area of Influence ......................................................................................................... 7

Figure 2: Political Jurisdictions in the AOI .................................................................................11

Figure 3: Developable Land in the AOI .....................................................................................33

LIST OF ATTACHMENTS

Attachment 1: Questionnaire and Map

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1.0 INTRODUCTION

This technical report summarizes the detailed analysis conducted to assess potential

indirect impacts associated with the 183 North Mobility Project. It provides a discussion of the

potential for impacts to sensitive resources, impact-causing activities, analysis of potential

substantial indirect effects, and minimization and mitigation opportunities. This analysis aims to

address the degree to which indirect impacts could occur in the area surrounding the project and

to what degree sensitive resources could be affected as a result.

2.0 GUIDANCE

This technical report was developed using the Texas Department of Transportation’s

(TxDOT) September 2010 Revised Guidance on Preparing Indirect and Cumulative Impact

Analyses, which is based on the 2002 National Cooperative Highway Research Program

(NCHRP) Report entitled NCHRP Report 466: Desk Reference for Estimating the Indirect Effects

of Proposed Transportation Projects (NCHRP 2002). Other sources of guidance include the

NCHRP Project 25-25, Task 22 report entitled Forecasting Indirect Land Use Effects of

Transportation Projects (NCHRP 2007). This analysis was also developed using the American

Association of State Highway and Transportation Officials’ (AASHTO’s) Practitioner’s Handbook

12: Assessing Indirect Effects and Cumulative Impacts Under NEPA (April 2011).

The following discussion generally follows TxDOT’s September 2010 Revised Guidance

on Preparing Indirect and Cumulative Impact Analyses. It also incorporates information from

March 2014 updates to TxDOT’s Cumulative Impact Analysis guidance, which emphasize a focus

on the most sensitive resources. Together, these documents are hereafter referred to as “TxDOT

ICI guidance.” This technical report presents a fusion of TxDOT’s seven-step process with the

four key steps for indirect impact analysis in the 2011 AASHTO Practitioner’s Handbook. The four

keys tasks identified by AASHTO are:

1) Assess the Potential for Increased Accessibility

2) Assess the Potential for Induced Growth

3) Assess the Potential for Impacts on Sensitive Resources

4) Assess the Potential Minimization and Mitigation Measures

This analysis utilizes elements of both TxDOT and AASHTO guidance documents and

contains the following sections which address the key tasks articulated by AASHTO:

Scoping

Resources Analyzed for Indirect Impacts

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Goals and Trends

Impact-Causing Activities

Potentially Substantial Indirect Impacts

o Access Alteration

o Effects Resulting from Induced Growth

Minimization and Mitigation

The following indirect impact analysis is based on several central definitions. In addition

to direct effects, major transportation projects may also have indirect effects on land use and the

environment. As defined by the Council on Environmental Quality (CEQ), indirect effects are

“caused by an action and occur later in time or farther removed in distance, but are still

reasonably foreseeable. Indirect effects may include growth-inducing effects and other

effects related to induced changes in the pattern of land use, population density or growth

rate, and related effects on air and water and other natural systems, including ecosystems”

(40 CFR §1508.8).

It should be noted that guidance documents use different terms, including “indirect effects”

(AASHTO guidance) and “indirect impacts” (TxDOT guidance). For the purposes of this analysis,

both terms are used and the meanings are the same.

NCHRP Report 466 (2002) identifies three broad categories of indirect effects:

1. Encroachment-alteration effects: These effects may result from changes in

ecosystems, natural processes, or socioeconomic conditions that are caused by the proposed

action but occur later in time or farther removed in distance. One example of this type of effect

would be a change in habitat or flow regime downstream resulting from installation of a new

culvert.

2. Project-influenced development effects: Sometimes called induced growth or the

“land use effect.” For transportation projects, induced growth effects are most often related to

changes in accessibility to an area, which in turn affects the area’s attractiveness for development.

Indirect impacts associated with induced development are also similar to direct impacts but would

occur in association with future land use development undertaken by others over the development

horizon within a larger study area beyond the direct footprint of the proposed project.

3. Effects related to project-influenced development: These are impacts to the natural

or human environment that may result from project-influenced changes in land use.

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Probability is important in providing a distinction between direct and indirect effects

because direct effects are generally inevitable, while indirect effects are merely probable.

According to NCHRP Report 466 (2002), the term “reasonably foreseeable” means that effects

are “sufficiently likely to occur that a person of ordinary prudence would take them into account in

making a decision;” such effects are probable, not just possible. Further, “effects that can be

classified as possible but not probable may be excluded from consideration” (NCHRP, 2002).

According to TxDOT's Guidance on Indirect and Cumulative Impacts Analysis (2010),

"[t]he common definition of ‘substantial’ is ‘of ample or considerable amount, quantity, size, etc.’

Substantial impacts are those that are noteworthy.” TxDOT rules define the term “significant” as

it has been interpreted under the National Environmental Policy Act of 1969 (NEPA) and its related

regulations. See 43 TAC 2.5 (26). That interpretation includes the definition used in 40 CFR

1508.27, which focuses on context and intensity considerations. An agency must examine the

context or setting in which the action occurs (e.g. national, regional, affected interests, and

locality) and consider short- and long-term effects of the action. An agency must also analyze

the intensity, or severity of the impact, considering: both beneficial and adverse impacts to public

health and safety; unique geographical characteristics; controversy related to effects on human

environment, uncertainty or unknown risks involved; precedent that may be set; relatedness of

the action to other actions for a cumulative impact that may be significant (significance exists if it

is reasonable to anticipate a cumulatively significant impact on the environment, and significance

cannot be avoided by terming an action temporary or by breaking it down into small component

parts); impacts to or loss of scientific or cultural resources; endangered species impacts; and any

other violation of any other environmental protection law.

For the current (183 Mobility Project) analysis, encroachment-alteration effects were

discussed in the resource-specific technical reports (per current TxDOT direction) and are

summarized in this technical report. Project-influenced development effects are discussed in the

access alteration section (Section 7.2). Effects related to project-influenced development are

discussed within the section on indirect effects potentially resulting from induced growth (Section

7.3). Planning judgment, collaborative judgment, and cartographic techniques were employed in

this analysis.

3.0 SCOPING

3.1 Summary of Scoping Activities Completed

The scoping process has two overall goals: (1) determining the level of effort and approach

needed to complete the analysis, and (2) determining the location and extent of the indirect impact

study area. Scoping has been ongoing since the earliest stages of project development for the

183 North Mobility Project. Scoping for the project, including indirect impacts, was conducted via

the following methods:

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Regular coordination among the project’s sponsors, stakeholders and study team;

Agency stakeholder/technical work group meetings;

Public involvement through public information meetings; and

Distribution of a questionnaire to local agencies and organizations.1

The public and stakeholder meetings were used to introduce the project to the general

public and to solicit comments and input on the project as it progressed. Meetings with

neighborhood associations, civic groups, and other stakeholders have also been ongoing

throughout the project.

Table 1 shows the public meetings held to date:

Table 1: Public Stakeholder Meetings

Meeting Type Date Public Open House #1 2/18/2014

Public Open House #2 7/8/2014

Public Open House #3 3/10/2015

Agency scoping and outreach in the environmental analysis process has occurred through

Technical Work Group meetings. Attendees from local, state, and federal agencies and

jurisdictions were present at these meetings to provide input. The following Technical Work Group

meetings have occurred to date (Table 2):

Table 2: Agency Stakeholder Meetings

Meeting Type Date Technical Work Group Meeting #1 1/14/2014

Technical Work Group Meeting #2 6/24/2014

Technical Work Group Meeting #3 2/24/2015

These meetings have documented that, from an agency standpoint, the key areas of

interest or concern are associated with bicycle/pedestrian accommodations, tolling operations

and pricing, and project cost and schedule.

3.2 Description of the Project’s Area of Influence

NCHRP Report 466 suggests that because indirect effects associated with a project can

occur at a distance in time or space from the project itself, the study area for determining indirect

effects is often broader than the study area associated with direct effects analysis. In order to

1 The questionnaire was distributed to local land use planning experts, agencies, and organizations to gather input on areas that would be likely to develop as a result of the proposed project, areas of planned capital improvements, and areas currently undergoing development. The questionnaire and responses are discussed in Section 7.2.2.

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distinguish it from the study areas considered for the analysis of direct effects of the project, the

study area for the indirect effects analysis will be referred to as the Area of Influence (AOI). The

AOI encompasses approximately 233 square miles (149,030.5 acres) in Travis, Williamson, and

Burnet counties. The AOI was delineated based on the presence of protected lands, major

roadways, extraterritorial jurisdiction (ETJ) limits, and journey-to-work patterns as reported by the

US Census Bureau. The northern boundary of the AOI follows SH 29 and the land within the ETJs

of Burnet, Bertram, and Liberty Hill; this land is outside the cities’ full purpose boundaries. Land

within the ETJs may be annexed into these cities in the future. Data collected by the US Census

Bureau indicates that the majority of workers in each of these three municipalities travel southeast

over 25 miles to work, suggesting that these workers’ destinations are in or near the Austin metro

area. Additionally, nearly a third of workers in Bertram, 18 percent of workers in Burnet, and 18

percent of workers in Liberty Hill are employed in the city of Austin itself (US Census, 2013).

Interviews with Burnet County and Williamson County development services and/or infrastructure

staff indicate that development is already occurring north of SH 29 – unrelated to planned US 183

improvements. Staff anticipate growth would continue regardless of whether the proposed project

is constructed (Herb Darling, Burnet Co., personal communication, March 24, 2015; Bob Daigh,

Williamson County, personal communication, March 26, 2015). Because the area north of SH 29

is already developing and that development is unrelated to the proposed US 183 improvements,

the US 183 improvements would not be expected to influence development in the area; thus, it

was not included in the AOI.

To the west, the AOI is delineated by US 281 through Burnet and County Road (CR) 340

south of Burnet as drivers west of CR 340 would be more likely to utilize US 281 than US 183 to

reach Austin. The AOI boundary then borders lands protected from development within the

Balcones Canyonlands National Wildlife Refuge and parcels owned by Travis County as part of

the Balcones Canyonlands Preserve (BCP). The AOI follows Big Sandy Creek between the

National Wildlife Refuge and the BCP lands.

The eastern boundary of the AOI is Parmer Lane/Ronald Regan Boulevard north of RM

620/SH 45. This roadway parallels US 183 from the project limits to SH 29. Areas to the east of

this roadway are better served by roadways other than US 183 and improvements to roadways

other than US 183 would be considered more likely to influence development in these areas.

The AOI also incorporates neighborhoods west of US 183 along RM 620 and Anderson

Mill Road as the proposed direct connectors along RM 620 could reduce cut through traffic on

Anderson Mill Road and would provide additional access to the proposed 183 express lanes and

existing general purpose lanes for travelers along RM 620. South of RM 620 along US 183, the

AOI consists of parcels adjacent to the roadway within the project limits, ending at the terminus

of the proposed project’s transition zone along MoPac at RM 2222.

The AOI includes some or all of the cities of Austin, Cedar Park, Leander, Liberty Hill,

Bertram, and Burnet, and unincorporated parts of Travis, Williamson, and Burnet counties. During

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the investigation process, these jurisdictions received questionnaires regarding potential induced

development impacts that also contained questions on the boundaries of the AOI. Subsequent

discussions were held between the project team and the City of Burnet’s Director of Community

Development regarding Burnet’s inclusion in the AOI. The decision was made to retain Burnet

within the AOI due to journey-to-work information and the City’s expectation that Burnet would

see more commuters traveling to Austin in the longer term as the region’s transportation network

expands (Mark Lewis, City of Burnet, personal communication, January 16, 2015). Williamson

County and Williamson County Conservation Foundation respondents indicated that areas north

of SH 29 along US 183 should be included in the AOI. Upon further discussion, given the distance

between the habitat areas and the proposed project/Austin, it was determined that the area in

question is farther north than project-related induced growth would be expected (Gary Boyd,

WCCF, personal communication, January 16, 2015). Therefore, these additional areas were not

included in the boundaries of the AOI, which is delineated based on areas where indirect impacts

and induced growth might be expected to occur. City of Austin respondents suggested delineating

the AOI boundaries along watershed lines and including nearby springs and tributaries. Because

the area of indirect impact analysis focuses on the potential for induced land development, the

boundaries are drawn based on the potential of the land to be developed as a result of the

proposed project. Watershed-based impacts would be analyzed within the context of what land

could be expected to develop. Analyses of watershed-wide impacts would be studied in the

context of cumulative impacts, which are resource-specific.2

See Figure 1 for a map of the AOI.

2 Cumulative impacts are discussed in the 183 North Mobility Project Environmental Assessment.

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Figure 1: Area of Influence

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4.0 RESOURCES ANALYZED FOR INDIRECT IMPACTS

The risk assessment screening tool summarized in Table 3 confirms the need to conduct

induced development analysis.

Table 3: Risk Assessment Screening Tool – Induced Development

Does the Purpose and Need include economic development, or is the project proposed to serve a specific development?

No

Are economic development or new opportunities for growth/development cited as benefits of the project?

No

Is land in the project area available for development and/or redevelopment?

Yes

Does the project add capacity? Yes

Is the project located in a rural area outside of the MPO boundary? No

Does the project substantially increase access or mobility in the project area?

Yes

Is the project area experiencing population and/or economic growth? Yes

Note: Per TxDOT guidance, if the answer to any of these questions is “yes,” additional indirect impact analysis is “warranted” (TxDOT, 2010).

Questionnaires and cartographic analysis show that there is land available for induced

development in the AOI, but the degree to which that development is specifically attributable to

construction of the proposed project is limited. There is a high growth rate in the area in general,

70 percent of questionnaire respondents do not anticipate the project would have an effect on

development in their jurisdictions, and projects are already planned or underway in the AOI even

without the proposed project.

TxDOT (2010, 2014) and AASHTO (2011) indirect impact assessment guidance require

consideration of potential impacts to sensitive resources. According to TxDOT’s guidance, indirect

impact analysis involves considering in particular features in the AOI that may highlight sensitive

resources with a high likelihood of being adversely affected as a result of indirect impacts and

therefore merit particular attention:

Sensitive Species and Habitats generally refers to ecologically valuable species

and habitat, and/or those that are vulnerable to impacts. Sensitive Species and

Habitats include state and federally-listed threatened and endangered species and

their habitats.

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Valued Environmental Components are characteristics or attributes of the

environment that society seeks to use, protect, or enhance, such as a protected

park or a conservation easement.

Relative Uniqueness, Recovery Time, and Unusual Landscape Features are

concepts intended to aid the analyst in identifying a resource that may be in decline

in the AOI. Relative uniqueness refers to how many comparable examples of the

element exist at different levels of scale. Recovery time refers to how long it would

take to replace the landscape element if it were disturbed or destroyed. Unusual

landscape features are those that occur once, or only a few times, across a

landscape, such as a single river passing through a landscape.

Vulnerable Elements of the Population may include the elderly, children,

persons with disabilities, minority groups, or low-income groups. These

populations may be more susceptible to environmental conditions, more

dependent on non-vehicular forms of transportation, or underrepresented in the

decision-making process.

Any of these factors or a combination of these factors can exist in the AOI such that certain

resources warrant detailed analysis. Rather than try to distinguish one type of sensitivity from

another, for this analysis, sensitive resources are characterized as “At Risk” and described with

respect to the aspects that characterize them as sensitive. Resources that were analyzed with

respect to encroachment-alteration effects include historic resources, archeological resources,

community resources, residences and businesses, neighborhoods, environmental justice

populations, parks and recreational resources, soils and geology, water resources (groundwater

and surface water), floodplains, threatened and endangered species, vegetation and wildlife

habitat, noise, air quality, and visual/aesthetic quality. A discussion of these resources and the

potential for encroachment-alteration effects to these resources is provided in Section 7.0.

5.0 GOALS AND TRENDS

The purpose of this section is to describe the general trends and community goals within

the AOI, including community planning goals, demographic and development trends, factors

influencing growth, and areas of environmental or social sensitivity. A key question to be

addressed in this analysis is whether or not land use growth and development is anticipated and

planned for within the AOI and whether or not protection of sensitive resources is among the goals

and trends for the communities in the AOI. Information contributing to this description comes from

local planning documents, agency goals and mission statements, local and/or regional trend data

collected for the proposed study area, and communications with local planners. This analysis

uses a temporal boundary of 2035 (in order to identify reasonably foreseeable future

development), which coincides with the planning horizon for the Capital Area Metropolitan

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Planning Organization’s (MPO’s) current Regional Transportation Plan (RTP). Figure 2 shows

various municipalities and political jurisdictions within the AOI.

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Figure 2: Political Jurisdictions in the AOI

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5.1 Goals

City of Austin

Approximately 5.5 percent (8,228.1 acres) of the AOI lies within the City of Austin’s full

purpose or limited jurisdictions. Less than one percent (1,182.9 acres) of the AOI falls within the

City’s ETJ, where the City has no zoning authority but where development is subjected to city

subdivision and water/wastewater regulations. Land within a city’s ETJ may be annexed in the

future, bringing development in these areas under the City’s zoning and permitting requirements.

The City has enacted several watershed protection ordinances over the last three decades

to protect water quality through land use and development controls. To this end, the western

Drinking Water Protection Zone (DWPZ) – in which the AOI is located – and the eastern Desired

Development Zone (DDZ) were created with the goal of funneling development into the DDZ

through use of development incentives (City of Austin, 2012). This goal of directing growth east

and south into the DDZ is echoed in the Imagine Austin Comprehensive Plan, adopted in 2012 to

guide growth and development in the city of Austin.

The Imagine Austin plan has eight priority programs:

Invest in a compact and connected Austin;

Sustainably manage our water resources;

Continue to grow Austin’s economy by investing in our workforce, education

systems, entrepreneurs, and local businesses;

Use green infrastructure to protect environmentally sensitive areas and integrate

nature into the city;

Grow and invest in Austin’s creative economy;

Develop and maintain household affordability throughout Austin;

Create a Healthy Austin Program;

Revise Austin’s development regulations and processes to promote a compact and

connected city (City of Austin, 2012).

Travis County

Approximately 4.0 percent (5,942.5 acres) of the proposed project’s AOI lies within the

unincorporated areas of Travis County, outside city limits or ETJs.

Travis County’s Department of Transportation and Natural Resources (TNR) is

responsible for:

Engineering, design, construction, and maintenance of Travis County roads,

drainage and bridges;

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Fleet services for all county vehicles and equipment;

Environmental protection;

Solid waste management and resource conservation;

Parks and natural resource preservation;

Capital improvement projects;

Land development review, permits and floodplain management regulations in

Travis County (Travis County, 2014).

According to Travis County’s list of capital improvement projects (2015), the following

project is included within the AOI:

Big Sandy Drive at Long Hollow Creek Low Water Crossing – improve existing low

water crossing to all-weather crossing (active status).

Less than one percent of the AOI lies within Lago Vista’s ETJ (349.3 acres). The city’s

2008 comprehensive plan does not specify future land uses for the portion of its ETJ within the

proposed project’s AOI (City of Lago Vista, 2010).

Travis County and City of Austin – Balcones Canyonlands Conservation Plan (BCCP)

In recognition of the common goal of protecting endangered species with habitat located

in Austin and in Travis County, the City and County created a regional habitat conservation plan

as a vehicle for compliance with the Endangered Species Act (ESA). These entities wrote the

Balcones Canyonlands Conservation Plan (BCCP) to obtain an incidental take permit for Golden-

cheeked Warblers, Black-capped Vireos, and six species of federally endangered karst

invertebrates under section 10(a)(1)(B) of the ESA. The permit covers direct and indirect takes

associated with grading, clearing, or other earth-moving activities necessary for residential,

commercial, or industrial development and infrastructure projects as well as indirect impacts, such

as noise, predation, and harassment from the occupancy and use of these structures. Under the

BCCP, approximately 30,428 acres of Golden-cheeked Warbler and Black-capped Vireo habitat

will be protected within a preserve system called the Balcones Canyonlands Preserve (BCP). The

BCCP also includes the goal of protecting 62 caves. The habitat protected by the BCP is

considered to be some of the highest quality and least fragmented habitat of any county in the

Golden-cheeked Warbler’s range. Areas covered by the BCCP in the event of incidental take

include all of Travis County with the following exceptions: the BCP, portions of the Balcones

Canyonlands National Wildlife Refuge that fall within Travis County, and areas within city limits

and planning jurisdictions of municipalities that are not participating in the BCCP. The permit will

last for 30 years (City of Austin & Travis County, 1996).

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City of Jonestown

Approximately 1.0 percent (1,518.7 acres) of the AOI lies within Jonestown’s full purpose

boundaries, another 1.3 percent (1,892.4 acres) lies within the city’s ETJ.

The City adopted a comprehensive plan in 2013 that includes the following goals:

Continue to work towards RM 1431 improvements;

Develop a wastewater system serving the RM 1431 corridor;

Review and update RM 1431 overlay and zoning;

Continue to expand park and recreation amenities;

Work to recruit desirable new businesses (City of Jonestown, 2013).

It is clear from these goals that the City expects to focus growth and development in the

RM 1431 corridor, which runs through the center of the city and intersects 183A in Cedar Park as

Whitestone Boulevard.

City of Cedar Park

Approximately 8.7 percent (12,978.8 acres) of the AOI lies within Cedar Park’s full purpose

boundaries, another 3.4 percent (5,119.8 acres) lies within the city’s ETJ.

Cedar Park’s most recent comprehensive plan update was adopted in 2006. Goals

include:

Update ordinances and regulations to address current needs, including new types of

development

Diversify and broaden the city’s economic base to keep up with anticipated growth

Develop a transportation network that enhances Cedar Park and offers alternate modes

of transport

Prepare for future commercial redevelopment and encourage redevelopment where

possible

Prepare for future residential redevelopment, examining and preparing infrastructure

where appropriate

Improve the appearance of existing corridors and ensure the aesthetically pleasing visual

appearance of future corridors into the city (City of Cedar Park, 2006).

City of Leander

Approximately 11.0 percent (16,396.3 acres) of the AOI lies within Leander’s full purpose

boundaries, another 12.2 percent (18,171.8 acres) lies within the city’s ETJ.

Leander’s comprehensive plan was adopted in 2009 and contains several goals pertaining

to its future land use plan. These goals emphasize planning for anticipated growth while ensuring

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that historic and residential areas are protected from incompatible uses. As part of this effort, the

plan suggests utilizing a nodal approach to development that encourages density at major

intersections. The City has also adopted a form-based code in its Transit Oriented Development

district and a new zoning ordinance to be applied elsewhere in the city. The plan also suggests

methods for preserving important environmental features, including riparian corridors and old

growth trees (City of Leander, 2009).

City of Liberty Hill

The AOI encompasses Liberty Hill’s city limits and ETJ. Liberty Hill’s city limits comprise

one percent (1,550.8 acres) of the AOI and its ETJ comprises 11.1 percent (16,585.6 acres).

The City of Liberty Hill is currently creating its comprehensive plan (its first since the city’s

incorporation in 1999). The 2014 draft is organized along four major themes:

Preserve and build upon character and heritage – new development should take a “small

town” form

Expand the economy – anticipation of future growth and business development

Improving the transportation system – SH 29 and US 183 will be expanded; other areas

of concern include providing a better east-west alternative to SH 29, expanding alternative

transportation modes, developing hike and bike routes, and creating a vision for the SH

29-US 183 intersection

Manage growth that is compatible with vision – creating and enforcing design standards

for non-residential development and signage (City of Liberty Hill, 2014).

City of Bertram

The AOI encompasses Bertram’s city limits and ETJ. Bertram’s city limits comprise 0.7

percent (988.9 acres) of the AOI and its ETJ comprises 3.7 percent (5,446.5 acres).

The City of Bertram does not have an adopted comprehensive plan. Its zoning ordinance

was adopted in 2001 to promote several purposes, including:

Conserve existing and future neighborhoods

Protect and preserve places and areas of historical and cultural importance and

significance to the community

Lessen congestion in the streets and provide convenient, safe, and efficient circulation of

vehicular and pedestrian traffic,

Promote compatible residential, commercial, and industrial uses to harmoniously relate

future development and redevelopment to the existing community and facilitate the

development of adjoining properties (City of Bertram, 2001).

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City of Burnet

Approximately 1.4 percent (2,087.6 acres) of the AOI lies within Burnet’s full purpose

boundaries, another 5.0 percent (7,395.2 acres) lie within the city’s ETJ.

The City of Burnet does not have an adopted comprehensive plan. However, Burnet’s

future land use map (adopted in 2012) indicates that most of the city and its ETJ will be the site

of residential land uses, with commercial and industrial development concentrated along the

major corridors of SH 29 and US 281 (City of Burnet, 2012).

Williamson County

Approximately 9.1 percent (13,622.3 acres) of the proposed project’s AOI lies within the

unincorporated areas of Williamson County, outside city limits or ETJs.

The Williamson County Department of Infrastructure oversees the building and

maintenance of county roads and bridges and enforces subdivision regulations and federal

floodplain regulations in the unincorporated portions of the county.

According to the Active Capital Projects List (Williamson County, 2013), several roadway

extension projects are planned or under construction within the AOI. The majority of these

roadway projects are concentrated around the 183A or US 183 corridors.

Williamson County Conservation Foundation – Regional Habitat Conservation Plan

The Williamson County Conservation Foundation (WCCF) is a non-profit organization

established by the County Commissioners Court to administer the Regional Habitat Conservation

Plan (RHCP), adopted in 2008. Like the BCP, the Williamson County RHCP was created to

provide an incidental take permit for activities in Williamson County that may result in the take of

Golden-cheeked Warblers, Black-capped Vireos, three endangered karst invertebrate species,

and the Georgetown salamander, a candidate species (WCCF, no date).

Burnet County

Approximately 19.6 percent (29,223.6 acres) of the proposed project’s AOI lies within the

unincorporated areas of Burnet County, outside city limits or ETJs.

The Burnet County Environmental Services Department is responsible for the following

areas: development permits, subdivision regulations, and floodplain management, among other

duties.

The Burnet County Comprehensive Transportation Plan (2010) includes widening SH 29

to five lanes from the Williamson County line to Burnet as an on-system priority. Off-system

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priorities in the AOI include improvements to CR 330 and CR 340. Other improvements include

bike/pedestrian accommodations and public transit with commuter service to Austin (Burnet

County, 2010).

Capital Area Metropolitan Planning Organization (CAMPO)

CAMPO is responsible for transportation planning in the Austin metro region, which

includes Travis and Williamson counties. The planning area now also includes Burnet County,

although this county was not included in the MPO boundaries during the 2035 long range planning

process. The vision statement for the 2035 Regional Transportation Plan (RTP) is: “Develop a

comprehensive multimodal regional transportation system that safely and efficiently addresses

mobility needs over time, is economically and environmentally sustainable, and supports regional

quality of life” (CAMPO, 2010). The plan calls for constructing one managed lane in each direction

along US 183 from RM 620 to MoPac, with a let year of 2015 and open year of 2017. Efforts to

update the RTP are ongoing; the proposed project will be included in the 2040 RTP as

constructing two managed lanes in either direction from RM 620 to MoPac.

5.2 Trends

5.2.1 Population and Housing Development

This section includes information about trends that characterize the AOI over time. In

general, the area encompassed by the AOI has grown considerably over the past decades as

shown in terms of population change, housing starts and predominant construction periods, and

employment growth over time.

The Austin area has experienced significant and sustained growth over the last four

decades, with the populations of Travis and Williamson counties increasing by 247 percent and

1,033 percent, respectively, over the period 1970 to 2010. The city of Austin grew by more than

200 percent, while some outlying towns (Cedar Park and Leander) have seen rates of growth in

excess of 1,000 percent. Historic population change for the counties and cities within the AOI is

shown in Table 4 and projected population change is shown in Table 5.

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Table 4: Current and Historic Population Growth in the AOI

City or County

Total Population by Year % Change from

1970-2010 1970 1980 1990 2000 2010

Austin 251,808 345,890 465,622 656,562 790,390 +214%

Cedar Park N/A 3,474 5,161 26,049 48,937 +1,309%*

Liberty Hill N/A N/A N/A 1,409 967 -31%*

Leander N/A 2,179 3,398 7,596 26,521 +1,117%*

Bertram N/A 824 849 1,122 1,353 +64%*

Burnet 2,864 3,410 3,423 4,735 5,987 +109%

Jonestown N/A N/A 1,250 1,681 1,834 +47%*

Travis County 295,516 419,573 576,407 812,280 1,024,266 +247%

Williamson County

37,305 76,521 139,551 249,967 422,679 +1,033%

Burnet County 11,420 17,803 22,677 34,147 42,750 +274%

N/A = no Census counts available for these jurisdictions during these years. *For those jurisdictions with no available population count in 1970, % change calculated for earliest year available. Source: US Census, 1980 Census of Population, Vol 1: Characteristics of the Population. Ch A, Texas, PC80-1-A45,”Table 5 Population of Places 1960 to 1980”; 1990 Census of Population. General Population Characteristics, Texas, 1990 CP-1-45. “Table 1 Summary of General Characteristics of Persons: 1990”; 2000 Census, Summary File 1, “Profile of General Demographic Characteristics”, DP-1; 2010 Census, Summary File 1, “Profile of General Population and Housing Characteristics: 2010”, DP-1.

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Table 5: Projected Population Growth in the AOI, 2010-2040

City or County

Total Population by Year (Projected 2020-2040) % Projected Change

from 2010-2040

2010 2020 2030 2040

Austin 790,390 976,418 1,153,977 1,330,492 68%

Cedar Park 48,937 81,069 89,517 90,287 85%

Liberty Hill 967 1,479 1,858 2,330 141%

Leander 26,521 50,562 94,378 158,728 499%

Bertram 1,353 1,681 2,034 2,331 72%

Burnet 5,987 7,438 9,000 10,317 72%

Jonestown 1,834 1,987 2,125 2,255 23%

Travis County 1,024,266 1,273,260 1,508,642 1,732,860 69%

Williamson County

422,679 632,433 794,478 987,495 134%

Burnet County 42,750 53,114 64,268 73,673 72%

Sources: Texas Water Development Board,” Population Projections for 2020-2070,” 2016 Regional Water Plan https://www.twdb.texas.gov/waterplanning/data/projections/2017/popproj.asp, (Accessed February 2, 2015).

Austin is expected to continue to grow into 2040; its population increasing by 68 percent.

The outlying cities are projected to see even stronger growth, with Leander’s population

increasing by nearly 500 percent and Liberty Hill’s by 141 percent over the same period (Table

6). This trend is also seen at the county level: Travis County’s population is projected to grow by

69 percent, while Williamson County’s population is projected to more than double. To the west,

Burnet County and the cities of Bertram and Burnet are expected to grow at rates similar to those

seen in Austin and Travis County (Table 5).

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Residential new home construction is also an indicator of growth trends in the AOI. See

Table 6 for new home construction by year between 1997 and 2012. While new housing starts

declined over the period 2008-2011 due to the nationwide economic recession, they began to

rebound beginning in 2012.

Table 6: Single-Family New Home Construction Building

Year Austin Cedar Park Leander Burnet

1997 2,380 1,003 144 16

1998 3,521 1,246 193 18

1999 3,302 1,462 179 27

2000 3,361 1,280 530 21

2001 2,119 967 472 27

2002 2,431 988 773 41

2003 3,117 1,072 627 24

2004 3,533 698 584 42

2005 4,569 1,270 824 33

2006 4,340 1,216 1,131 50

2007 3,155 989 611 60

2008 1,928 660 396 32

2009 1,951 544 367 28

2010 1,664 595 242 19

2011 1,713 506 325 11

2012 2,539 688 420 13

Total 45,623 15,184 7,818 462

Source: City-Data.com, http://www.city-data.com/city/ (Accessed February 2, 2015) Note: No data available for Liberty Hill, Jonestown, or Bertram

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Table 7 contains data from the US Census Bureau’s American Community Survey 2009-2013 five-year estimates on the year

housing structures in the various AOI jurisdictions were built, from 1970 to 2013. The table shows that the period between 2000 and

2009 was the decade in which the largest portion of development occurred within the AOI. This decade saw the most development in

the larger cities in the AOI (Austin, Cedar Park, and Leander), while the decade 1970-1979 saw more development in the smaller cities

(Bertram and Burnet).

Table 7: Year Structure Built/Percent Built within Decade for Jurisdictions in AOI, 1970 - 2013

Geography Total Homes

Year Structure Built/Percent of Houses Built in that Decade

2010 or later 2000-2009 1990-1999 1980-1989 1970-1979

# % # % # % # % # %

Austin 366,459 3,655 1.0% 80,587 22.0% 59,223 16.2% 77,484 21.1% 72,123 19.7%

Bertram 793 0 0.0% 116 14.6% 101 12.7% 47 5.9% 128 16.1%

Burnet 2,333 0 0.0% 526 22.5% 206 8.8% 191 8.2% 565 24.2%

Cedar Park 19,741 919 4.7% 9,514 48.2% 5,493 27.8% 2,473 12.5% 870 4.4%

Leander 9,025 289 3.2% 5,451 60.4% 1,603 17.8% 1,011 11.2% 400 4.4%

Liberty Hill 511 28 5.5% 45 8.8% 93 18.2% 109 21.3% 65 12.7%

Jonestown 1,083 10 0.9% 409 37.8% 139 12.8% 207 19.1% 128 11.8%

Travis Co 447,616 5,213 1.2% 114,961 25.7% 80,054 17.9% 90,406 20.2% 77,718 17.4%

Williamson Co 165,125 3,783 2.3% 68,911 41.7% 38,948 23.6% 27,716 16.8% 15,650 9.5%

Burnet Co 20,987 147 0.7% 6,055 28.9% 3,175 15.1% 3,584 17.1% 3,873 18.5%

AOI 1,032,590 14,034 1.4% 286,166 27.7% 188,896 18.3% 203,021 19.7% 171,392 16.6%

Source: ACS 2008-2012 (B25034 - Year Structure Built). *Note: Decade with Highest Percentage in Bold. Travis County data includes some City of Austin data.

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Table 8 contains information on employment projections from CAMPO’s 2035 regional

transportation planning process and the Burnet County Comprehensive Transportation Plan

(2010). The table shows that Williamson and Burnet counties’ total employment is projected to

increase significantly over 2005 employment numbers. Further, between 2015 and 2035,

employment in Williamson County is predicted to more than double (143.6 percent increase). In

Travis County, employment growth over this same period is projected to be slower: a 45 percent

increase in employment is projected, in keeping with the population projections expected for the

region.

Table 8: Projected Employment by County into 2035

Projected Employment

County 2005

(base year) 2015 2025 2035

% change 2005 – 2035

Travis 534,887 709,513 845,806 1,028,745 92.3%

Williamson 100,089 163,401 250,710 398,069 297.7%

Burnet* 14,260 -- -- 34,010 138.5%

*Burnet County was not part of the five-county CAMPO area at the time the 2035 RTP process occurred. Burnet County employment projections are taken from the Burnet County Comprehensive Transportation Plan, which only provides projections for 2035. Sources: CAMPO, 2010, 2005 to 2035 Plan Amendment 1110 [computer file]; Burnet County, December 2010, Burnet County Comprehensive Transportation Plan.

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6.0 IMPACT-CAUSING ACTIVITIES TABLE AND SUMMARY

Several general categories of impact-causing activities are relevant to the proposed

project, as shown in Table 9. These are likely to occur as a result of transportation projects and

other similar development. According to TxDOT (2010), impact-causing activities include all of the

activities involved in the project, from clearing to maintenance of vegetation once the project is

finished. These activities are relevant to encroachment-alteration effects and access-alteration

effects. These ten categories of impact-causing activities are also identified in the NCHRP Report

466 and are described in Table 9.

Table 9: Impact-Causing Activities

Type of Activity Project Specific Activity Relevant Information

Modification of Regime

Removal of vegetation and wildlife habitat

Various types of vegetation would be removed in the existing median for roadway construction and in proposed water quality pond locations.

Alteration of surface drainage BMPs would be put in place to reduce and minimize any adverse impacts to water quality.

Land Transformation and Construction

Direct impacts from construction; construction noise and vibration

Noise and vibration would result from construction equipment trenching, excavation, backfilling, grading, and pavement laying activities.

Resource Extraction Excavation for embankment fill material; ponds

Surface and subsurface excavation would be required throughout the project limits for construction.

Processing

Storage of construction materials including aggregate, concrete pipes, traffic control barricades, steel rebar, road signs, etc., temporary construction office trailers equipped with temporary utility service including some means of sanitary waste disposal

Material storage areas and construction office trailers are commonly located within the project ROW during construction.

Land Alteration

Erodible materials exposed to surface runoff

Erosion Control and Sedimentation Control BMPs would be implemented and maintained until construction is complete. Post-Construction Total Suspended Solids Control BMPs would be implemented as well.

Landscaping Landscaping in accordance with TxDOT specifications.

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Table 9: Impact-Causing Activities cont’d

Type of Activity Project Specific Activity Relevant Information

Access Alteration Changes in access, circulation patterns, or travel times to major attractors

The proposed express lanes would improve mobility on the facility and enhance access by providing direct connectors to/from SH 45/RM 620 on the north and MoPac on the south. Although existing points of access would be enhanced, new points of access are not proposed. Traffic modeling indicates that the enhanced access at RM 620 would result in a reduction of cut-through traffic on Anderson Mill Road and adjacent neighborhoods.

Chemical Treatment

Fertilization

When used, fertilizers are generally only used during the revegetative phase of the project, after which the use of fertilizers is discontinued.

Deicing

For ice control in the Austin metropolitan area, TxDOT typically uses magnesium chloride (with added buffering agents to mitigate negative environmental and/or corrosive effects).

Source: NCHRP 466.

The primary impact-causing activity would be access alteration through construction of

new express lanes that improve mobility and direct connectors that reduce cut through traffic on

local roadways.

Impact-causing activities (or, generally speaking, development activities) have the

potential to be substantial and could affect sensitive resources in the AOI, so potentially

substantial indirect impacts are discussed below.

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7.0 POTENTIALLY SUBSTANTIAL INDIRECT IMPACTS

This section examines potentially substantial indirect impacts to the sensitive resources

identified within the AOI. As discussed in Section 2.0, types of indirect effects include

encroachment-alteration effects, which are discussed in the resource-specific technical reports

and are summarized in Table 10 of this technical report to the extent that they contribute to the

need for detailed analysis for indirect impacts. Access alteration effects (also known as project-

influenced effects or induced growth effects), and effects related to project-influenced

development (or effects related to induced growth) are discussed in this section.

Individual resources were analyzed with respect to encroachment-alteration effects in the

resource-specific technical reports. Table 10 provides a description of resources analyzed for

potential indirect impacts from induced development, including consideration of those

encroachment-alteration issues documented in the technical reports. Resources that have been

investigated in more detail for potential indirect impacts are identified in the table with a “yes” in

the final column. Resources that either have no direct effects or no substantial potential to result

in indirect effects, and that are therefore not analyzed in detail in this technical report are identified

with a “no.”

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Table 10: Resources Analyzed for Indirect Impacts

Resource/Impact

Area Would this resource be directly impacted?

Would this resource experience encroachment-

alteration impacts?

Is this a sensitive resource/is this resource at

risk?

Is this resource included in

detailed indirect impact

analysis?

Historic Resources

Based on information available, there is one National Register of Historic Places (NRHP)-listed resource, the Aynesworth-Wright house (THC Atlas # 80004156), which is located within the Area of Potential Effect (APE) for this project. This resource would not be directly impacted by construction as planned.

The increased APE in this area that establishes the inclusion of the NRHP-listed Aynesworth-Wright house is due to the proposed construction of a water quality pond to catch run-off and floodwaters from US 183. Therefore, the impact of the construction activity would be a decreased risk of flooding which might occur at the NRHP-listed property. The primary expected impact would be one of benefit to the NRHP-listed Aynesworth-Wright house because of the proposed construction of detention ponds that would limit future flood occurrences at or near the property.

There are neither other NRHP-eligible historic resources nor any State Antiquities Landmarks (SALs) are known in the project vicinity; therefore, no other encroachment-alteration impacts are anticipated.

No; NRHP eligible and listed historic resources are protected by State and Federal regulations for publicly funded projects.

No

Archeological

Resources

The current condition of three sites within or adjacent to the APE is currently unknown, but they appear in aerial photography to have been completely removed by the construction of US 183. While aerial photography indicates that development has likely removed any trace of sites 41TV297, 41TV1087, and 41WM757 from the project area, further investigation will be necessary to confirm the condition and NRHP or SAL eligibility status of these sites

One archaeological site (41TV1087) of unknown antiquity is adjacent to the US 183 APE southeast of the US 183 and Loop 360 intersection. Aerial photography depicts commercial development adjacent to the frontage road at this location. Further investigation will be necessary to confirm if the site extends into the APE, site type, condition, and NRHP or SAL eligibility status of site 41TV1087. However, it is anticipated that none of the site remains within the APE due to commercial development and previous roadway construction. Therefore, encroachment-alteration impacts are not anticipated.

No; based on extensive urban development and previous roadway and utility construction, significant archaeological resources are not anticipated within the US 183 North APE.

No

Community

Resources No displacements of community facilities would occur. No encroachment-alteration impacts are anticipated. No No

Residences and

Businesses No displacements of residences or businesses would occur. No encroachment-alteration impacts are anticipated. No No

Neighborhoods Changes in access would occur at the three entry/exit points to the express lanes, where access would be improved by providing a link to the proposed express lanes.

The proposed project could alter travel patterns along Anderson Mill Road as many drivers who currently use the roadway to reach US 183 would instead utilize RM 620 in order to access the direct connectors linking to both the proposed Express Lanes and existing general purpose lanes. Neighborhoods along Anderson Mill Road would experience benefits associated with decreased cut through traffic. Drivers north of SH 45 who currently travel to Lakeline Mall Drive to access US 183 would be able to access the proposed express lanes north of Lakeline Mall Drive at their connection to 183A, decreasing cut through traffic along the neighborhood roadways these drivers currently use to access the Lakeline Mall Drive entrance ramp.

No; the proposed project would be constructed in the median of an existing roadway; no changes to existing access points to the roadway’s general purpose lanes would occur and no existing neighborhoods would be bisected as a result of the proposed improvements.

No

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Table 10: Resources Analyzed for Indirect Impacts cont’d

Resource/Impact

Area Would this resource be directly impacted?

Would this resource experience encroachment-

alteration impacts?

Is this is a sensitive resource/is this resource at

risk?

Is this resource included in

detailed indirect impact

analysis?

Environmental Justice

Populations

No low-income or minority populations would be disproportionately impacted by the construction of the proposed project.

One block group in the AOI contains a low-income population, defined by FHWA as 50 percent of the population living in households with incomes at or below the 2015 DHHS poverty guideline (BG 3 CT 17.52). While the block group lies adjacent to the roadway, no access changes would occur under the proposed project. Additionally, no impacts to community cohesion would occur under the project.

While concentrated minority populations do exist within the AOI, and would be included in outreach efforts, minority status alone would not result in disproportionate or adverse impacts associated with tolling, which would be more detrimental to low-income populations.

No encroachment-alteration impacts are anticipated.

EJ groups are comprised of vulnerable populations, including minorities and low income persons, and are therefore considered to be sensitive and at risk. TxDOT follows principles in E.O. 12898 and Title VI to provide protections for EJ populations. Project-induced growth is not anticipated to have a significant effect on neighborhoods, including those in EJ communities. Displacements from project-induced growth are not anticipated.

The Project Level Toll and EJ Analysis did not identify a disproportionate, adverse effect to low-income or minority populations. Therefore, it is not anticipated that induced growth would disproportionately impact EJ communities.

No

Parks and Recreational

Resources No parkland would be acquired for this project, nor would access changes to park facilities occur.

No encroachment-alteration impacts are anticipated.

Parklands are an important (sensitive) resource but are not vulnerable (or at risk) because public parklands in the AOI are protected by municipal codes and federal laws such as the Land and Water Conservation Act, and Section 4(f) for federally funded transportation projects.

No

Soils and Geology

Soils may be subject to erosion and sedimentation due to the proposed project; however, these impacts would be minimized through the use of construction and post-construction BMPs.

The likelihood of recharge from the project area to the main body of the Edwards Aquifer is thought to be low to moderate. No point source karst features were identified in the project area and impervious cover and fill material cover much of the project area.

No encroachment-alteration impacts to soils or geologic resources are anticipated.

Recharge features, including fractures, sinkholes, and caves, contribute to the unique hydrogeology typical of karst systems and allow for recharge to the underlying Edwards Aquifer. Karst features can also provide habitat for karst species.

Recharge features allow for rapid infiltration and recharge to the underlying Edwards Aquifer. Due to the rapid rates of recharge and groundwater flow, the Edwards Aquifer, like other karst aquifers, is highly productive but also vulnerable to contamination. The species that depend on karst habitats are also sensitive due to their specific habitat needs.

No

(Karst Geology to be addressed in conjunction with groundwater

recharge features)

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Table 10: Resources Analyzed for Indirect Impacts cont’d

Resource/Impact

Area Would this resource be directly impacted?

Would this resource experience

encroachment-alteration impacts?

Is this is sensitive resource/is this resource at

risk?

Is this resource included in

detailed indirect impact

analysis?

Water Resources:

Groundwater

The project is located over the Edwards Aquifer Recharge Zone and would meet all requirements necessary to comply with water quality standards. Potential for pollutants in stormwater runoff from the construction site and completed roadway to enter the aquifer and potential for reductions in recharge to the aquifer resulting from increases in impervious cover would be minor. Impacts would be minimized by the use of BMPs during roadway construction and operation. A Water Pollution Abatement Plan (WPAP) would be implemented. Due to implementation of permanent, post construction BMPs, the incremental increase in TSS load generated by the new impervious cover that would be added by the proposed project would be reduced by 80 percent before being discharged into area waterways. Post-construction TSS BMPs would include retention ponds for sediment settlement and removal before discharging into other waterways which would reduce water quality impacts to surrounding waterbodies. Wherever and whenever necessary, feasible and practical BMPs would be incorporated during construction of the proposed project. For example, permanent vegetation (seeding mix) would be utilized for stabilization where necessary for erosion control. Therefore, direct impacts are not expected to be significant.

Encroachment-alteration impacts to water quality could occur primarily due to increased impervious cover or removal of vegetation that results in increased runoff and altered recharge (flow and quality) to the aquifer. Placement of the roadway could encroach on the surface or subsurface drainage areas of adjacent caves/karst features, altering the hydrologic regimes in those features.

Groundwater resources in the study area primarily include the Trinity and Edwards Aquifers. The Trinity Aquifer is an important source of groundwater for public use both in the study area and the region, but the Edwards Aquifer is the primary focus of conservation concerns due to its ecological significance and vulnerability to contamination. The Edwards Aquifer is not a sufficiently productive water source within the study area to satisfy current demand for human consumption, but it is an important source of groundwater for ecological purposes. It supplies numerous low-flow springs that provide habitat for rare and listed wildlife species including the Jollyville Plateau Salamander (JPS) which was listed as threatened under the Federal Endangered Species Act.

Yes

Water Resources:

Surface Water

This project crosses or has existing easements that have connectivity to Lake Creek, two tributaries to Lake Creek, a tributary to Walnut Creek, and Shoal Creek. There are 11 water and wetland features within the study area. It is anticipated Feature 1, if permanently impacted by project activities, could be permitted under Nationwide Permit (NWP) 14, with a Pre-Construction Notice (PCN). The remaining waters of the U.S. (Features 6-11) would be avoided.

Surface waters within the study area can be affected in numerous ways by the operations of the proposed US 183 facility. Impacts to surface water quality could arise during construction activities. During construction, potential spills would be mainly limited to fuels (i.e., petrochemicals) and lubricants used for construction equipment. Construction in the immediate area of wetlands and other waterbodies can be assumed to generate additional sediment loads to the waterbodies if bare earth is exposed for an extended period of time and not controlled using erosion control facilities. During operation, the use of fertilizers, herbicides and/or pesticides could result in reduced water quality due to runoff.

Temporary impacts to surface water quality could include potential stormwater runoff and contamination during construction. These impacts would be minimized through required utilization of BMPs during construction.

Encroachment-alteration impacts associated with the proposed project could occur as increased impervious cover causes increased runoff and decreased water quality downstream. Impacts may also occur where vegetation has been cleared during construction, as removal of vegetation could accelerate off-site erosion.

According to the Texas Commission on Environmental Quality (TCEQ) 2012 Section 303(d) list, a tributary within the project area drains to impaired Water Quality Segment 1428B_05 – Walnut Creek (impaired due to bacteria levels). The impaired segment is 2.8 miles downstream from the proposed project.

Due to connectivity with groundwater (see Groundwater Technical Report by Cambrian Environmental and SWCA Environmental Consultants in December, 2014), surface water quality and quantity are also pertinent to threatened and endangered species issues. This connectivity occurs where karst features provide habitat to karst species and aquifers provide habitat for aquifer-dwelling species.

Yes

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Table 10: Resources Analyzed for Indirect Impacts cont’d

Resource/Impact

Area Would this resource be directly impacted?

Would this resource experience

encroachment-alteration impacts? Is this is sensitive resource/is this resource at risk?

Is this resource included

in detailed indirect impact

analysis?

Floodplains

The project would cross three areas designated as special flood hazard areas inundated by the 100-year flood as either Zone A, no base flood elevations determined, or Zone AE, base elevations determined. There are approximately 5.7 acres of 100-year floodplain within the study area.

The floodplain areas are located where the project limits or retention ponds cross or connect to the following waterways: Lake Creek, Tributary to Walnut Creek, and Shoal Creek.

No encroachment-alteration impacts are anticipated.

The hydraulic design for this project would be in accordance with current FHWA and TxDOT design policies, laws, regulations, and standards. The proposed project would be in compliance with 23 C.F.R. 650 regarding location and hydraulic design of highway encroachments within the floodplains. The proposed project would comply with EO 11988 which requires federal agencies to avoid to the extent possible the long- and short-term adverse impacts associated with the occupancy and modification of floodplains and to avoid direct and indirect support of floodplain development wherever there is a practicable alternative. The facility would permit the conveyance of the 100-year flood, inundation of the roadway being acceptable, without causing significant damage to the facility, stream, or other property. The proposed project would not increase the base flood elevation to a level that would violate applicable floodplain regulations and ordinances.

Roadway encroachments on floodplains would be analyzed to determine any effects caused by the proposed facility should a 100-year flood occur. Inundation of the approaches, without causing significant damage to the approach roadway, is considered acceptable. For these reasons, the proposed project is not anticipated to create a significant encroachment on any area floodplains as defined in 23 CFR 650.

No

Threatened and Endangered Species

Direct effects are not expected to occur to the Jollyville Plateau salamanders since this species is not known to occur within the project area, in either surface or subsurface habitats. Direct effects to listed karst species are not expected to occur since no karst features were identified during the karst feature survey completed within the project area.

Encroachment-alteration impacts to the Jollyville Plateau salamander are not likely to occur. Encroachment-alteration effects to the listed karst species could potentially occur from increased impervious cover, effects to cave systems’ temperature and humidity conditions from grading and milling, and degradation of groundwater quality due to roadway contaminants or increased sediments in runoff.

The Jollyville Plateau salamander and listed karst species (Bee Creek Cave harvestman, Bone Cave harvestman, Tooth Cave ground beetle, and Tooth Cave spider) are federally listed species at risk of extinction.

Yes

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Table 10: Resources Analyzed for Indirect Impacts cont’d

Resource/Impact

Area Would this resource be directly impacted?

Would this resource experience

encroachment-alteration impacts?

Is this is sensitive resource/is this resource at

risk?

Is this resource included

in detailed indirect impact

analysis?

Vegetation and Wildlife

Habitat

Approximately 724.6 acres would be directly impacted by the proposed project, including existing drainage easements. Of this, 14.48 acres of vegetation are composed of vegetation types for which TPWD coordination thresholds exist under the current TxDOT-TPWD MOU. These MOU types include Edwards Plateau, Savannah, Woodland, and Shrubland; and Riparian. The vegetation type present in the project area for which no coordination thresholds exist is Urban. Urban vegetation types comprise the largest share of vegetation in the project area (700.97 acres or 96.7%).

Encroachment-alteration impacts stemming from the proposed project could result in additional loss and fragmentation of vegetation and habitat types on developable lands within the study area.

There is similar habitat found throughout the project study area and the AOI. Based on Texas Natural Diversity Database (TXNDD) data, there is no remnant vegetation found within the study area (TPWD, 9/2014).

No

Noise

The current noise conditions would be altered with the addition of the proposed roadway. Additional traffic noise, defined as unwanted sound, would be generated throughout the study area. Projected traffic data have been utilized in noise modeling software [Traffic Noise Model (TNM) 2.5] in accordance with TxDOT’s Guidelines for Analysis and Abatement of Roadway Traffic Noise to predict the traffic noise impact on noise sensitive receivers. Twenty-one of 34 receivers would experience a noise impact. A barrier analysis indicates that noise barriers would not be feasible and reasonable.

No encroachment-alteration impacts are anticipated.

No; the proposed project would comply with noise requirements, which are designed to help protect the public health and safety and prevent disruption of certain human activities. These criteria are based on such known impacts of noise on people as speech interference, sleep interference, physiological responses, hearing loss and annoyance. Projected traffic data have been utilized in noise modeling software to determine if receivers in the study area are vulnerable to noise impacts. Twenty-one receivers would be impacted; noise barriers would not be feasible and reasonable for any of these receivers.

No

Air Quality

The purpose of this project is to facilitate congestion management, provide a reliable route for transit, and facilitate reliable emergency response by constructing express lanes in the median of the existing facility. This project has been determined to generate minimal air quality impacts for Clean Air Act criteria pollutants and has not been linked with any special MSAT concerns. As such, this project will not result in changes in traffic volumes, vehicle mix, basic project location, or any other factor that would cause an increase in MSAT impacts of the project from that of the no-build alternative. Moreover, EPA regulations for vehicle engines and fuels will cause overall MSAT emissions to decline significantly over the next several decades. Based on regulations now in effect, an analysis of national trends with EPA’s MOVES model forecasts a combined reduction of over 80 percent in the total annual emission rate for the priority MSAT from 2010 to 2050 while vehicle miles of travel are projected to increase by over 100 percent. This will both reduce the background level of MSAT as well as the possibility of even minor MSAT emissions from this project. A carbon monoxide (CO) analysis for the project indicates that the proposed improvements would not result in CO levels exceeding the National Ambient Air Quality Standards (NAAQS) for CO.

No encroachment-alteration impacts are anticipated.

The potential indirect impacts on air quality and MSATs are primarily related to any expected development/redevelopment resulting from the project’s increased accessibility or capacity to the area. However, any increased air pollutant emissions resulting from the potential development or redevelopment of the area must meet regulatory emissions limits established by the TCEQ and EPA, as well as obtain appropriate authorization from the TCEQ. Regulatory emission limits set by TCEQ and EPA are established to attain and maintain the NAAQS by assuring any emissions sources resulting from new development or redevelopment will not cause or contribute to a violation of those standards.

No; the Austin-Round Rock-San Marcos MSA is currently in attainment or unclassifiable for all air pollutants under the National Ambient Air Quality Standards (NAAQS).

Because the project’s potential direct and indirect impacts on air quality and MSATs are projected to be offset by federal fuel and vehicle control programs or state and federal regulatory programs, negative impacts on air quality are not anticipated.

No

Visual/Aesthetic Quality The visual quality in the vicinity of the project would not be significantly affected since there would be no major elevation or geometric changes relative to the existing conditions.

No encroachment-alteration impacts are anticipated.

No; visual/aesthetic quality is not a sensitive resource and is not at risk.

No

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7.1 Methodology

The techniques utilized for this analysis are primarily Planning Judgment, determined

through holding meetings, administering questionnaires and conducting phone interviews with

planning professionals in the project vicinity; Collaborative Judgment to the extent that numerous

professionals were contacted as part of this analysis, including several representatives from

agencies such as municipal planning departments; and Cartographic Techniques, in addition to

expert technical analysis consistent with the methods described in NCHRP Report 466 and

NCHRP Report 25-25.

This section includes a discussion of currently developed land within the AOI versus land

available for development within the AOI. This Cartographic Technique exercise utilized

Geographic Information Systems (GIS) software to analyze data collected remotely and in the

field, combined with various constraints layers and the proposed alignment outline. In addition,

the results of questionnaires sent to planning experts were incorporated to the extent the

information could be mapped. Additional technical analysis has been provided by project analysts,

and a summary of the questionnaire responses received is included in Section 7.2.2.

Land that is already planned or platted for development was not included in the total

amount of developable land as it is assumed that this land will be developed. The land available

for development was identified through cartographic analysis and questionnaires, and its

development is considered possible but not necessarily probable (as opposed to land that is

already planned or platted, which is considered probable and reasonably foreseeable, regardless

of whether the proposed 183 North project is constructed). Development of the land considered

developable is not necessarily causally connected to the proposed roadway improvement project.

Nonetheless, cartographic techniques were used to assess the sensitive resources that could be

found within that developable land area. This analysis is followed by a discussion of the

minimization and mitigation tools that would apply to development proposed by others in those

areas.

7.2 Access Alteration (Induced Growth)

Also referred to as induced growth effects, access alteration effects can result from

changes in traffic, access, and mobility. Transportation projects may provide new or improved

access to adjacent land, or may induce development on surrounding land by effecting a reduction

in the time-cost of travel (NCHRP, 2002). Transportation projects may also affect the rate at which

planned development is implemented.

7.2.1 Quantification of Developable Land

Some changes in land use could occur within the AOI if undeveloped areas are developed

as a result of enhanced access to this land. To identify areas where project-influenced

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development might occur in the AOI, data on existing and planned developments were analyzed

to determine areas of vacant land that could be developed in the future. Land within the AOI was

classified as developed or undeveloped based on existing land use, zoning, and tax code

information. Undeveloped lands that are set aside as protected open space, parks, or drainage

areas, as well as land within the 100-year floodplain, were classified as undevelopable. The

remaining undeveloped land was classified as developable. Figure 3 shows developable land

within the AOI.

Within the 149,030.5 total acres of the AOI, approximately 78,746.0 acres (52.8 percent)

are already developed. Approximately 8,047.4 acres (5.4 percent) are undevelopable including

parks, floodplains, and protected open space. Developable land accounts for 62,237.1 acres (41.8

percent) of the AOI. Based on information provided by the jurisdictions located within the AOI,

several projects are in various stages of development, ranging from under review to under

construction. Removing these projects from the stock of developable land in the AOI yields

approximately 54,615.7 acres available for future development (36.6 percent of the AOI). Table

11 shows these land use categories and the amount of land available for development (also

mapped in Figure 3).

Table 11: Acres of Land Available for Project-Influenced Development within AOI

Existing Land Uses Acres Percentage of

Total

Total Developed Land 78,746.0 52.8%

Total Undeveloped Land 70,284.5 47.2%

Undevelopable Land 8,047.4 5.4%

Developable Land

Planned Projects 7,621.4 5.1%

Land with no projects planned

54,615.7 36.6%

Total Area within AOI 149,030.5 100.0%

Note: Developable and Undevelopable Land subtotals equal 47.1% due to rounding Calculations made using data from: City of Austin, 2012, 2014; City of Leander, 2015; City of Cedar Park, 2014; CAPCOG, 2010; FEMA, 2014; Williamson County, 2015; Travis County, 2015

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Figure 3: Developable Land in the AOI

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7.2.2 Planning Expert Questionnaire and Responses

A questionnaire was sent to agencies, organizations, and governmental jurisdictions within

the project’s AOI. The questionnaire and AOI map (Attachment 1) were emailed to each

organization listed in Table 12 on December 5, 2014. Follow up telephone calls and emails were

sent to those organizations that had not replied by January 19, 2015.

The questions were designed to identify available resources and solicit input concerning

how the project might affect growth and development within the region. In addition to identifying

available information and data, the questionnaire specifically focused on how each agency or

organization viewed the potential impacts of the project. See Attachment 1 for the contact letter

form. The full text of all received responses is available for review in the project files at TxDOT

Austin District.

Table 12: Indirect & Cumulative Effects Questionnaire Recipients

Organization Primary Point of Contact Response Received*

City of Austin Ed Peacock, Supervising Engineer, Watershed Protection Department

3/6/2015

Travis County Mike Wallace, Environmental Specialist

Williamson County Joe England, County Engineer 12/18/2014

Williamson County Conservation Foundation

Gary Boyd, Environmental Program Coordinator

12/18/2014

City of Cedar Park Amy Link, Assistant Director of Development Services

2/4/2015

City of Leander Robin Griffin, Senior Planner 1/28/2015

City of Liberty Hill Jim Bechtol, Senior Planner 12/17/2014

City of Bertram Adam Lambert, Public Works Director

City of Burnet Mark Lewis, Director of Community Development

12/11/2014

Burnet CISD Jerry Blizzard, Director of Facilities and Operations

AISD Paul Turner, Executive Director of Facilities

Leander ISD Bret Champion, Superintendent

Liberty Hill ISD Rob Hart, Superintendent

Round Rock ISD Ramiro Flores, Superintendent 2/2/2015

Capital Metro John-Michael Cortez, Community Involvement Manager

CAMPO Lisa Weston, Senior Planner

CAPCOG Michael Hennig, Director of Community & Economic Development

* Blank cells are still awaiting responses.

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Five out of the eight respondents (≈63 percent) did not expect the proposed project to

induce development in their jurisdictions. Two of the eight respondents (25 percent) were unsure

whether the project would affect the rate or intensity of development; four of the eight (50 percent)

responded that the project would not affect the rate or intensity of development in their

jurisdictions. One respondent, the City of Austin, indicated that the project would be expected to

induce development near the Lakeline Mall area and could affect the rate and intensity of

development as well.

The Williamson County Conservation Foundation and Williamson County pointed to areas

of protected habitat in the AOI as factors that may limit growth. Williamson County also cited

floodplains as a limiting factor. Additionally, respondents provided information on residential and

commercial developments that are underway or planned for the area, as well as some capital

improvement projects.

Common Threads from Survey Responses:

Four respondents indicated that the proposed project would not induce

development in the jurisdictions in the AOI; one respondent indicated the proposed

project would induce development (in the Lakeline Mall area)

Two respondents were unsure as to whether the project would affect the

rate/intensity of development; four responded that the project would have no effect;

one respondent indicated the project would be expected to affect the rate/intensity

of development in its jurisdiction

Development is focused along the 1431 corridor in Cedar Park and in close

proximity to 183A and Ronald Reagan Boulevard in Leander

Infrastructure improvement projects are planned in Leander near the project

Project anticipated to be beneficial for commuter traffic

Floodplains and areas protected by federal regulations as habitat for threatened or

endangered species (including karst zones) are limiting factors on growth

Other Main Points made by Survey Respondents:

City of Austin

Project may increase likelihood of development of Lakeline regional activity center

identified in Imagine Austin’s Growth Concept Map (2012)

Due to the additional general purpose lanes proposed, the project could encourage

development in a more low-density, auto-oriented pattern, which would not be

consistent with Imagine Austin Comprehensive Plan

No capital improvement projects listed in City’s infrastructure coordination system

or any water quality/stream restoration projects are planned for the project area

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Three high priority localized storm drain problem areas are located in the vicinity

of the project: West Cow Path and Oak Knoll storm drainage issues are being

considered; Bell Avenue storm drainage issues are also on the Watershed

Protection Department’s priority list

Additional runoff from the proposed improvements could impact streams and

floodplains in the area

The AOI boundaries should extend down MoPac to Enfield Road due to a high

likelihood that increasing capacity on US 183 would increase traffic volumes on

MoPac

The AOI should ideally be drawn on a watershed basis and include watersheds

and properties with significant environmental resources that are within the

drainage of the project even if not immediately adjacent, including springs in

tributaries of Bull Creek3

City of Cedar Park

Project not expected to induce development in the city

No factors limiting growth

FM 1431 corridor is primary development corridor

Unsure whether the project would influence rate or intensity of development

City of Leander

City is currently experiencing a lot of residential growth in close proximity to 183A

and Ronald Reagan Boulevard

Unsure whether the project would influence rate or intensity of development

Various infrastructure improvements are planned near the project

Project would be beneficial for commuter traffic

City of Liberty Hill

Project not expected to impact development in the city

City of Burnet

Project not expected to impact development in the city

Williamson County Conservation Foundation

Karst zones, endangered species habitat are limiting factors on growth

Areas north of SH 29 along US 183 should be included in the AOI4

3 For a discussion of AOI boundaries in light of respondents’ input, see Section 3.2. 4 For a discussion of AOI boundaries in light of respondents’ input, see Section 3.2.

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Williamson County

Project not expected to induce development in the county

Project not expected to influence rate or intensity of development

No capital improvements projects are planned for the area

Floodplains, USFWS regulations are limiting factors on growth

Areas north of SH 29 along US 183 should be included in AOI5

Round Rock ISD

District has no plans for school construction in the AOI

Minimal impact to District expected as result of proposed project

Area is fairly well developed – project would not be expected to influence amount

or rate of development

Overall, respondents do not expect the proposed project to influence development in their

jurisdictions, many of which are already seeing growth concentrated around the FM 1431, 183A,

and Ronald Reagan Boulevard corridors.

7.2.3 Likelihood of Induced Growth on Developable Land

While a substantial amount of the AOI contains developable land, responses received

from local land use planning experts indicate that the likelihood is low that the proposed project

would induce development on much of this land. Jurisdictions close to Austin – such as Cedar

Park, Leander and Jonestown – are already seeing strong growth in the vicinity of the US 183

facility and other transportation corridors such as Ronald Reagan Boulevard and FM 1431.

Jurisdictions farther from Austin – including Liberty Hill and Burnet – do not anticipate that the

project would impact growth in their communities. While journey-to-work data indicates that

commuters to Austin comprise 18 percent of the city of Burnet’s workers (US Census, 2013), the

city’s planning experts do not foresee this single project inducing growth or accelerating the

amount or pace of development over the coming years. Rather, outlying cities like Burnet may

become more attractive to Austin commuters as the region’s transportation network expands

(Mark Lewis, City of Burnet, personal communication, January 16, 2015).

The City of Austin indicated in its questionnaire responses that the Lakeline regional

activity center could be expected to develop as a result of the proposed project. Regional activity

centers are described in the Imagine Austin Comprehensive Plan as “the most urban places in

the region…the retail, cultural, recreational, and entertainment destinations for Central Texas”

with the “greatest density of people and jobs and the tallest buildings” (City of Austin, 2012, pg.

5 For a discussion of AOI boundaries in light of respondents’ input, see Section 3.2.

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104). Thus, intense development is already expected to occur in this area into 2035. However,

the rate of development may be affected by the proposed project.

Areas near the enhanced access points to the proposed express lanes may be more likely

locations of project-related induced growth. Developments in these areas may occur at a slightly

more rapid pace when compared to other developable land in the AOI since they are connected

to the proposed US 183 express lanes via direct connectors or entrance/exit ramps. These access

points – direct connectors at SH 45/RM 620, ramps northbound and southbound between

Anderson Mill Drive and McNeil Drive, and direct connectors to the MoPac express lanes – are

located in one of the more heavily developed areas of the AOI in Austin’s city limits. Therefore,

the amount of nearby developable land is relatively small. Within half a mile of the proposed direct

connector on RM 620, two parcels totaling 12.5 acres are characterized as developable land

based on the analysis described in Section 7.2.1. According to the City of Austin’s Emerging

Projects database, an additional 172 acres of retail, office, and multifamily developments are

already planned or under construction in this area (City of Austin, 2014).

Between Anderson Mill Road and McNeil Drive, in the area of the proposed entrance/exit

points to the express lanes, there is one developable parcel totaling 5.7 acres on the southbound

side of the facility. Because the southern terminus of the proposed project consists of direct

connectors linking to express lanes on MoPac, another limited access facility rather than a

frontage road or arterial, this access point is not expected to be more attractive for development

with the construction of the proposed US 183 express lanes, since access to the facility from

adjacent parcels would not be possible here.

In sum, while approximately 41.8 percent of the AOI can be classified as developable,

much of these lands are not likely to develop as a result of the proposed project. A few

developable parcels near the express lane access points may be more likely to develop, or to

develop more quickly, due to their proximity to the proposed express lanes. However, this

represents a very small fraction (less than one percent) of the total amount of developable land

in the AOI.

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7.3 Indirect Effects Potentially Resulting from Induced Growth

As discussed in Section 2.0, indirect effects can also result from project-related induced

development. Based on the analysis presented in Table 4, threatened and endangered species

and water resources are considered sensitive resources in the AOI that should be analyzed for

indirect effects. Impacts to these resources resulting from induced growth are discussed in the

following sections. Because the proposed project is not anticipated to generate significant

amounts of induced growth, or to significantly affect the amount or pace of development in the

AOI, indirect impacts to these resources stemming from induced growth are not anticipated to be

substantial.

Threatened and Endangered Species

Jollyville Plateau Salamander

Within the AOI, there are approximately 14.2 acres of surface critical habitat (out of 410.0

acres total) and approximately 639.2 acres of subsurface critical habitat (out of 4,332.6 acres

total) for the Jollyville Plateau salamander (JPS). Within the developable areas in the AOI, there

are approximately 11.7 acres of subsurface critical habitat, but no surface critical habitat.

Although approximately 36.6 percent of the AOI is comprised of developable land on which

no projects are currently planned, input from multiple land use planning experts in the area

indicate that substantial development induced by the proposed project is unlikely to occur in these

areas (see Section 7.2.3). Therefore, the likelihood of stormwater runoff from project-induced

developments in the AOI reaching occupied JPS habitat and adversely affecting JPS by disrupting

essential breeding, feeding, or sheltering behaviors is very low.

Any developments constructed in the AOI, whether induced by the proposed project or

not, would be subject to multiple local, state, and federal regulations to protect water quality and

endangered species habitat. These regulations are discussed in detail in Section 8.1. For more

information on potential impacts to JPS, please refer to the following technical report: Potential

for Impacts to the Jollyville Plateau Salamander from the Proposed US Highway 183 North

Mobility Improvement Project, Travis and Williamson Counties, Texas.

Federally Listed Endangered Karst Species

Increased impervious cover could result in indirect effects to endangered karst

invertebrates. Surface water reaching the interiors of caves does so through a diffuse network of

fractures which have been buried beneath varying amounts of imported pavement, fill material,

and topsoil by original highway construction. The addition of impervious cover could retard the

rate and reduce the amount of recharge through fill material reaching a cave (Cambrian and

SWCA, 2015). However, as stated in Section 7.2.3, input from multiple land use planning experts

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in the area indicate that substantial development induced by the proposed project is unlikely to

occur in the AOI. Therefore, indirect impacts to karst invertebrates caused by project-induced

development [such as increases in impervious cover, reduction of trogloxene foraging habitat (or

other sources of nutrient input), or enhancement of habitat for invasive species such as the red-

imported fire ant] are not expected.

Any developments constructed in the AOI, whether induced by the proposed project or

not, would be subject to multiple local, state, and federal regulations to protect water quality and

endangered species habitat. These regulations are discussed in detail in Section 8.1. For more

information on potential indirect impacts to listed karst species, please refer to the following

technical report: Potential for Impacts to Endangered Karst Invertebrates from the Proposed US

Highway 183 North Improvement Project, Travis and Williamson Counties, Texas.

Water Resources

In general, increased impervious cover resulting from additional development can result

in impacts to groundwater resources by impeding recharge to the Edwards Aquifer and increasing

the amount of pollutants in stormwater runoff that eventually reaches the aquifer. Increased

development can also result in impacts to surface water resources by increasing stormwater

runoff (contributing to flooding) or increasing the amount of pollutants in runoff that enter surface

waterbodies.

As discussed in Section 7.2.3, although approximately 36.6 percent of the AOI is

comprised of developable land on which no projects are currently planned, input from multiple

land use planning experts in the area indicate that substantial development induced by the

proposed project is unlikely to occur in these areas. Therefore, indirect impacts to groundwater

or surface water resources from project-induced development are not expected.

Any developments constructed in the AOI, whether induced by the proposed project or

not, would be subject to multiple local, state, and federal regulations to protect water quality and

water resources. These regulations are discussed in detail in Section 8.2.

8.0 MINIMIZATION AND MITIGATION

Numerous minimization and mitigation measures are in place that would apply to any

developer who proposes to build in the AOI. In addition, there are a variety of land development

requirements that are in place at the municipal level that would also apply to developers in those

jurisdictions. These are discussed by resource below.

8.1 Threatened and Endangered Species

Projects moving forward as a result of induced growth from the proposed 183 North

Mobility Project would be subject to regulation under the ESA if it is anticipated that they would

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affect either the JPS or endangered karst invertebrates or their habitat. The ESA prohibits take of

listed threatened and endangered species (except in certain cases where prior approval allows

for the “incidental taking” of protected species). The ESA defines “take” as “to harass, harm,

pursue, hunt, shoot, wound, kill, trap, capture, or collect, or attempt to engage in any such

conduct” (ESA, 1973).

Water quality measures proposed for the 183 North Mobility Project would treat the new

impervious cover associated with the project by slowing runoff so that at least 80 percent of TSS

and associated pollutants would be removed from stormwater... Water quality BMPs are also

proposed and may include expanding existing water quality ponds, expanding existing

underground sand filters systems, enhancements to detention ponds, cisterns, bio-filtration

swales, and/or new water quality ponds. These water quality measures and BMPs would help

reduce the likelihood of indirect impacts to the Jollyville Plateau salamander.

The potential for these impacts from both project construction activities and from post-

construction spills on the proposed roadway would be minimized by the implementation of a Water

Pollution Abatement Plan (WPAP) and the use of BMPs in accordance with the TCEQ Edwards

Aquifer Protection Program (EAPP) and associated Edwards Rules for the entire project area.

The EAPP is based on state regulations (Texas Administrative Code Chapter 213) stipulating

water quality protection for storm water entering the Edwards Aquifer. According to Section 213.1,

paragraph 2 of the Texas Administrative Code, Title 30, Part 1, the Edwards Rules and EAPP

have been determined to be a non-degradation regulation. This determination is based on the

use of temporary erosion and sedimentation controls, and the construction of permanent BMPs

(in accordance with an approved WPAP). Collectively, these water quality controls serve to

remove sediments and roadway pollutants arising from normal roadway usage and from

accidental spills (Cambrian and SWCA, 2015).

8.2 Water Resources

Mitigation for potential water quality impacts occurs in the form of regulations and

ordinances enforced by TCEQ and various local entities. The individual and combined effect of

these regulatory programs is to protect water quality and/or mitigate the adverse effects to water

quality from development activities.

TCEQ regulations to protect the Edwards Aquifer are contained in the Edwards Aquifer

Rules (30 TAC 213). These rules require developers who are planning to construct on the

Recharge Zone of the Edwards Aquifer to prepare and submit a Water Pollution Abatement Plan

(WPAP) to TCEQ for review and approval. This plan must include a Geologic Assessment

describing site-specific geology and identifying all potential pathways for contaminant movement

to the Edwards Aquifer. The rules also require submission of aquifer protection plans for activities

over the aquifer’s Contributing Zone (known as “contributing zone plans”). Unlike WPAPs,

contributing zone plans to not contain a geologic assessment.

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The Edwards Aquifer Rules require the use of permanent stormwater BMPs that are able

to remove 80 percent of the incremental increase of TSS in runoff from the regulated site. No

additional permanent BMPs are required for single-family residential developments that are 20

percent or less impervious cover. Additionally, TCEQ has issued two optional guidance

documents, Optional Enhanced Measures for the Protection of Water Quality in the Edwards

Aquifer and Optional Enhanced Measures for the Protection of Water Quality in the Edwards

Aquifer and Related Karst Features that May Be Habitat for Karst Dwelling Invertebrates. These

documents provide optional enhanced water quality measures and BMPs for protecting the

Edwards Aquifer that may be implemented in areas subject to the Edwards Aquifer Rules. The

optional enhanced measures are consistent with TCEQ’s goal of non-degradation of groundwater

quality and may be used to further protect the Edwards Aquifer, including public health and

welfare, terrestrial and aquatic life, and the environment (TCEQ, 2007).

Water quality at wells and in the Edwards Aquifer is protected by the Safe Drinking Water

Act of 1974 and the 1996 Amendments to the Act (Public Law 104-182), laws that protect drinking

water and provide source water protection. The 1996 Amendments provided new and stronger

approaches to prevent contamination of drinking water, including a strong emphasis on source

water protection. These rules required states to delineate source water areas of public water

systems and assess the susceptibility of such source waters to contamination. The source water

assessment results would then be used to implement source water protection programs. TCEQ’s

Source Water Protection Program was created by the 1996 Amendments and sets into motion a

voluntary process by which local governments and suppliers of drinking water are encouraged to

take proactive steps to protect local drinking water supplies before costly treatment

enhancements are required. These supplies are defined primarily as water systems serving at

least 15 connections or at least 25 persons at least 60 days per year.

At the local level, the City of Austin has passed a number of watershed ordinances aimed

at protecting the water supply and environmentally sensitive watersheds in the Austin area from

water quality degradation. The most recent City of Austin ordinance was passed on October 17,

2013; this ordinance aimed to improve creek and floodplain protection, prevent unsustainable

public expense on drainage systems, simplify development regulations where possible, and

minimize the ordinance’s impact on the ability to develop land (City of Austin, 2013b).

The Balcones Canyonlands Conservation Plan (BCCP), a regional habitat conservation

plan administered by the City of Austin and Travis County, protects over 28,000 acres in Travis

County as the Balcones Canyonlands Preserve. The BCCP includes requirements to protect

caves and other karst features where endangered species or species of concern have been found

(City of Austin & Travis County, 1996).

For surface water, additional regulations are in place to avoid or minimize impacts to water

quality. EPA’s National Pollutant Discharge Elimination System (NPDES) permit program,

authorized by the Clean Water Act (CWA), controls water pollution by regulating point sources

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that discharge pollutants into waters of the US. In Texas, the NPDES program is administered by

TCEQ, as part of the Texas Pollutant Discharge Elimination System (TPDES). A NPDES permit

may be required if wastewater is discharged into the stormwater system. The CWA established

the basic structure for regulating discharges of pollutants into the waters of the US. The Municipal

Separate Storm Sewer (MS4) program applies to cities and counties and is overseen by TCEQ.

As an MS4 operator, Travis County implements a Stormwater Management Plan (SWMP), a

comprehensive long-range plan to prevent and reduce stormwater pollution in the county (Travis

County, 2014b). Williamson County is also an MS4 operator and administers its own SWMP.

Section 404 of the CWA gives US Army Corps of Engineers (USACE) authority to regulate

the discharge of dredged or fill material into waters of the US, including wetlands. Impacts to

waters of the US could require USACE authorization. Executive Order 11990 Protection of

Wetlands (issued in 1977) requires federal agencies to minimize the destruction or modification

of wetlands. Any future development project in the AOI would be required to comply with USACE

regulations.

TCEQ’s Total Maximum Daily Load (TMDL) Program works to improve water quality in

impaired or threatened water bodies in Texas. A TMDL defines an environmental target by

determining the extent to which a certain pollutant must be reduced. TMDLs are developed for

surface waters that are quality-limited due to a pollutant or adverse condition. Based on the

environmental target in the TMDL, the State develops an implementation plan to mitigate sources

of pollution within the watershed and restore impaired uses. The Texas Water Quality Inventory

and 303(d) List is an overview of the status of surface waters of the State, including concerns for

public health, fitness for aquatic species and other wildlife, and specific pollutants and their

possible sources. The 303(d) List, a subset of the Inventory, identifies waters that do not attain

one or more standards for their use.

Under Executive Order 11988 Floodplain Management, the FEMA requires municipalities

that participate in the National Flood Insurance Program to adopt floodplain ordinances that

prohibit development in existing 100-year floodplain. Coordination with the local floodplain

administrator would be required for developments affecting floodplains.

The City of Austin’s Watershed Protection Ordinance specifies that an environmental

resource inventory would be required for development projects located in a Water Quality

Transition Zone or Critical Water Quality Zone, floodplain, karst region/aquifer, or on a tract with

a gradient of 15 percent or more. The inventory must identify critical environmental features

(bluffs, canyon rimrocks, caves, faults and fractures, sinkholes, springs, and wetlands, as defined

in the ordinance), provide justification for proposed soil disposal locations or roadway alignments,

propose methods to achieve overland flow, and describe proposed industrial uses and the

pollution abatement program. City of Austin requires preparation of an Environmental Assessment

if project impacts would occur within these buffer zones. If work is proposed in a buffer zone

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around a Critical Environmental Feature (as defined by the City of Austin), a variance process

would have to be followed to allow construction within that area.

The City of Austin also has regulations in place for voids and water flow features

discovered during construction. According to Section 1.12.1 of the Environmental Criteria Manual,

"all work must stop if a void in the rock substrate is discovered which is one square foot in total

area, blows air from within the substrate, and/or consistently receives water during any rain event.

At this time it is the responsibility of the Project Manager to immediately contact a City of Austin

Environmental Inspector for further investigation." Development in the city of Austin would be

required to comply with these standards.

The potential for the indirect impacts to surface and groundwater resources from both

project construction activities and from post-construction maintenance and spills on the proposed

roadway discussed in Section 7.3 would be minimized by the development and implementation

of a WPAP and the use of BMPs in accordance with the Edwards Aquifer Rules for the entire

project area. The Edwards Aquifer Rules have been determined to be a non-degradation

regulation; therefore, the construction of temporary and permanent BMPs in accordance with an

approved WPAP would serve to remove sediments and roadway pollutants arising from normal

roadway usage and from accidental spills. Because BMPs would be in place during and after

construction and due to the existing water quality conditions in the highly developed corridor, the

potential for indirect effects from any changes in surface or ground waters caused by the proposed

project is expected to be negligible.

8.3 Various Municipal Codes and Land Development Regulations

In addition to the environmental regulations described in Sections 8.1 and 8.2, the cities

and counties within the AOI also enforce their own land development regulations and ordinances,

many of which seek to mitigate adverse impacts to water quality, flooding, and public health and

safety that may arise from development. Any future developments that may occur within these

jurisdictions would be subject to the appropriate development regulations.

8.3.1 Municipalities

The City of Austin has environmental protection considerations in the Land Development

Portion of the Austin City Code for subdivision development (Title 25-8) including considerations

of water quality, erosion, impervious cover, and handling of wastewater.

https://www.municode.com/library/tx/austin.

Cedar Park’s subdivision regulations are enumerated in Chapter 12 of its Code of

Ordinances. These regulations include stormwater, parkland, and nonpoint source pollution

control requirements. http://z2.franklinlegal.net/franklin/Z2Browser2.html?showset=cedarparkset

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The City of Leander enforces both a composite zoning ordinance and a water conservation

ordinance, applicable to all lands within the city limits excluding parcels zoned in the Transit

Oriented Development district. The water conservation ordinance includes requirements of

minimum percentages of landscaped areas as well as irrigation requirements.

http://www.leandertx.gov/planning/page/zoning

The cities of Burnet,6 Bertram,7 Liberty Hill,8 and Jonestown9 also enforce their own zoning

and/or subdivision regulations, which include requirements for stormwater management and

drainage.

8.3.2 Counties

The Travis County Code includes policies and procedures relating to construction

standards in Chapter 80, which would make them subject to County Development Regulations.

The County Development Regulations (Chapter 82) include provisions relating to the use and

preservation of water resources as well as the amount of impervious cover allowable for projects

within the County. http://www.co.travis.tx.us/tnr/links.asp.

Williamson County’s subdivision regulations also specify construction and engineering

requirements, including drainage and flood control provisions.

http://wilco.org/Portals/0/Departments/URS/WCSR%202013-05-09.pdf

Burnet County also enforces subdivision regulations with provisions regarding floodplain,

drainage, and wastewater issues. http://www.burnetcountytexas.org/users/0013/docs/BCSR.pdf

9.0 CONCLUSIONS

The proposed project’s AOI encompasses 149,030.5 acres in Travis, Williamson, and

Burnet counties. Based on an analysis of land use, zoning, and tax code information, combined

with information on proposed projects, approximately 62,237.1 acres (41.8 percent) of the AOI

may be considered developable [removing planned projects from this stock of developable land

yields 54,615.7 acres (36.6 percent) of developable land on which no projects are currently

planned]. However, based on responses to a questionnaire sent to various land use planning

agencies and organizations, the proposed project is not anticipated to significantly induce

development or accelerate the pace of already planned development in the AOI. Responses from

the City of Austin indicated that project-induced development could occur at the Lakeline regional

activity center, an area already slated for intensive development in the Imagine Austin

6 Subdivision: http://www.cityofburnet.com/planning_zoning/documents/SubDivOrdAdopted02-09-10.pdf; Zoning: https://www.municode.com/library/tx/burnet/code_of_ordinances/coor_ch118zo#TOPTITLE 7 http://www.cityofbertram.org/list-of-common-ordinances.html 8 http://z2codes.franklinlegal.net/franklin/Z2Browser2.html?showset=libertyhillset 9 http://z2.franklinlegal.net/franklin/Z2Browser2.html?showset=jonestownset

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Comprehensive Plan. Areas around the RM 620 direct connector and the ramps between

Anderson Mill Road and McNeil Drive may be more likely to see project-related induced

development, due to the nearby access to the proposed facility. However, this land represents

only a small fraction (less than one percent) of the land available for development in the AOI.

Following TxDOT guidance, the sensitive resources carried forward for indirect impact

analysis were threatened and endangered species (the Jollyville Plateau salamander and several

endangered karst invertebrates) and water resources (both surface and groundwater). Indirect

impacts that could affect these species could result from water quality impacts caused by

increased impervious cover or increased concentrations of pollutants in stormwater runoff, or from

disturbances of caves related to construction of the roadway. However, the water quality

protections, BMPs, and void mitigation protocols proposed as part of the project design would

minimize impacts to water quality and karst habitat. Finally, existing regulations are in place at

the federal, state, and local levels to protect the sensitive resources discussed in this analysis.

Any entity proposing to develop within the AOI must comply with these regulations. Therefore,

based on the preceding analysis, the proposed project would not result in significant indirect

impacts to sensitive resources in the AOI.

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10.0 REFERENCES

AASHTO. 2011. Practitioner’s Handbook #12 Assessing Indirect Effects and Cumulative

Impacts under NEPA.

http://www.environment.transportation.org/pdf/programs/practitioners_handbook_12.pdf,

accessed January 15, 2014.

Burnet County. 2010. Burnet County Comprehensive Transportation Plan.

http://www.burnetcountytexas.org/users/0006/Plan_BurnetCoFinalDec2010.pdf

(Accessed February 13, 2015).

Cambrian Environmental and SWCA Environmental Consultants (Cambrian and SWCA). 2015.

Potential for Impacts to Endangered Karst Invertebrates from the Proposed US Highway

183 North Improvement Project, Travis and Williamson Counties, Texas. March 20,

2015.

Capital Area Metropolitan Planning Organization (CAMPO). 2010. 2035 Regional Transportation

Plan.

City of Austin

2012. Imagine Austin Comprehensive Plan.

http://www.austintexas.gov/department/overview accessed January 16, 2014.

2013a. Watershed Ordinance History. http://austintexas.gov/page/watershed-protection-

ordinance (Accessed November 30, 2013).

2013b. Watershed Protection Ordinance No. 20131017-046.

http://austintexas.gov/page/watershed-protection-ordinance-0. (Accessed November 30,

2013).

2014. Emerging Projects Online Map. August 2014.

http://austintexas.gov/page/emerging-projects. (Accessed October 13, 2014).

City of Austin & Travis County. 1996. Habitat Conservation Plan and Final Environmental

Impact Statement for the Balcones Canyonlands Preserve, Austin, Texas.

City of Bertram. 2001. Ordinance No. 26-2001A. Zoning Regulations.

City of Burnet. 2012. City of Burnet Adopted Future Land Use. March 13, 2012.

http://www.cityofburnet.com/planning_zoning/documents/Adopted_Future_Land_Use.pdf

(Accessed February 13, 2015).

City of Cedar Park. 2006. Cedar Park Comprehensive Plan Update.

http://www.cedarparktexas.gov/modules/ showdocument.aspx?documentid=1211

(Accessed October 22, 2014).

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City of Jonestown. 2013. Jonestown Comprehensive Plan Update.

City of Lago Vista. 2010. Annual Update of the Comprehensive Master Plan 2008.

http://www.lagovistatexas.org/sites/default/files/Comprehensive-Master-Plan.pdf

(Accessed March 18, 2015).

City of Leander. 2009. Leander Comprehensive Plan Update.

City of Liberty Hill. October 2014. Liberty Hill Comprehensive Plan. Draft.

National Cooperative Highway Research Program, National Research Council, Transportation

Research Board (NCHRP). 2002. The National Cooperative Highway Research Program

(NCHRP) Report 466: Desk Reference for Estimating Indirect Effects of Proposed

Transportation Projects. The Louis Berger Group, Inc., National Academy Press,

Washington D.C.

SWCA Environmental Consultants (SWCA). 2015. Potential for Impacts to the Jollyville Plateau

Salamander from the Proposed US Highway 183 North Mobility Improvement Project,

Travis and Williamson Counties, Texas. Draft. March 20, 2015.

Texas Department of Transportation (TxDOT).

2010. Revised Guidance on Preparing Indirect and Cumulative Impact Analyses.

2014. Cumulative Impact Analysis Guidelines (March).

Texas Parks and Wildlife Department (TPWD). 2014. Texas Natural Diversity Database Results.

September 29, 2014.

Travis County

2014. Informational webpage available at http://www.co.travis.tx.us/tnr/, (Accessed

January 16, 2014)

2015. Public Works Capital Improvement Projects (CIP) Summary Table. Revised

February 2, 2015.

US Census Bureau.

2010. Decennial Census of Population and Housing, American Factfinder

2013. On the Map. Longitudinal Employer-Household Dynamics.

http://onthemap.ces.census.gov (Accessed October 8, 2014)

Williamson County. 2013. Adopted Budget: Fiscal Year October 1, 2013 – September 30, 2014.

http://www.wilco.org/Portals/0/Departments/Budget/GFOAFY13.14.pdf (Accessed

February 13, 2015).

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Williamson County Conservation Foundation (WCCF). No date. Williamson County Regional

Habitat Conservation Plan Fact Sheet. http://www.williamson-

county.org/Portals/0/Departments/Conservation_Foundation/Docs/RHCP_Fact_Sheet.p

df (Accessed February 13, 2015).

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ATTACHMENT 1 QUESTIONNAIRE AND MAP

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183 North Mobility Project Indirect Effects Questionnaire

The Central Texas Regional Mobility Authority (Mobility Authority), the Texas Department of Transportation (TxDOT), and the Federal Highway Administration (FHWA) are conducting an Environmental Assessment (EA) for the proposed improvement of US 183 North from Ranch-to-Market Road (RM) 620/State Highway (SH) 45 in Williamson County to Loop 1 (MoPac) in Travis County , Texas. To facilitate congestion management, provide a reliable route for transit, and facilitate reliable emergency response in the US 183 corridor, two variably tolled Express Lanes would be constructed in both directions in the median of the existing roadway. The 183 North Express Lanes would connect to the tolled lanes on 183A in Williamson County and to the Express Lanes currently under construction on MoPac. Direct connectors to the Express Lanes would also be constructed from RM 620, SH 45, and MoPac. The Direct connectors at MoPac would include a transition area extending south to RM 2222. To close an existing gap and provide a continuous four-lane section of general purpose lanes in each direction from SH 45 to MoPac, the proposed project would also include construction of a fourth general purpose lane southbound on US 183 from the south end of the existing fourth general purpose lane north of McNeil Drive to the MoPac exit, a distance of 5.0 miles. Northbound, a fourth general purpose lane would be added on US 183 from the south end of the existing fourth general purpose lane at McNeil Drive to the north end of the existing fourth general purpose lane near Braker Lane, a distance of 3.1 miles. Additionally, several possible enhancements to bicycle and pedestrian facilities, including a shared use path, improved sidewalks and cross street connections, are being evaluated. CP&Y, Inc. is preparing the EA for the proposed project. Under TxDOT guidance, the potential indirect effects of a project must be addressed in the environmental assessment process. Indirect effects are reasonably foreseeable future impacts caused by the proposed project, but that occur later in time and farther away from the project than direct impacts, which are directly caused by the action and occur at the same time and place as the action. Indirect effects may include induced land development and the changes in population density or growth rate that result from this increased development. To aid in assessing the potential direct and indirect impacts of the project, we are contacting your organization to obtain your insight on how the project may affect your community or the region. We have attached a map of the project area showing the proposed roadway and proposed Area of Influence for indirect effects analysis. TxDOT guidance requires that we assess potential indirect effects out to the planning horizon, which has been established as 2035 in keeping with the Capital Area Metropolitan Planning Organization’s (CAMPO’s) current Regional

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Transportation Plan. We are seeking to identify any areas where potential development could occur (whether or not it is currently planned) within this planning horizon that could be attributed at least in part to improvements along US 183 North. Please note that you may have received a similar questionnaire regarding the MoPac South Project. A study to assess reasonably foreseeable indirect and cumulative impacts of that project is being conducted concurrently to the 183 North Environmental Study. We recognize that those who are most knowledgeable about how projects might affect a community are the local experts. With that in mind, we appreciate your time and input in this process. Please complete the following questionnaire to the best of your knowledge; if you are not the best person to answer the questions, please forward this to the appropriate person or persons within your organization. Please submit your answers to the following address (electronic responses are welcomed with legible marked up maps) by December 19, 2014: If you have any questions you may call Lauren Avioli at (512) 492-6848. Lauren Avioli Environmental Planner CP&Y, Inc. 13809 Research Blvd, Ste 300 Austin, TX 78750 (512)-492-6848 | [email protected]

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1. Are you aware of any substantial proposed land developments within your jurisdiction or area? If so, please mark the general areas on the attached (or equivalent) map and provide the location, type, and size (e.g., acres, density, number of units) of any planned developments.

2. On the attached map, please identify areas (if any) that you think would likely be developed as a result of the construction of the proposed project that would not otherwise be developed (please distinguish from developments identified in question 1).

3. Would the proposed project affect the rate or intensity of land development in your jurisdiction? If so, please describe.

4. Are there other capital improvement projects – such as water or sewer infrastructure, school or hospital construction, or roadway improvements – that are planned for the area which might affect development in the project vicinity?

5. Are there any factors that could limit growth in the area, such as floodplains, current development, conservation easements, protected lands, etc.?

6. In your opinion, are there areas not encompassed by the Area of Influence shown on the attached map that would be indirectly impacted by the project and should be included in the Area of Influence?

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