COUNTY OF EL PASO

Jan. 10, 2022

Tomas Trevino, PE, El Paso District Engineer

Texas Department of Transportation
13301 Gateway West
El Paso, Texas 79928

RE: Downtown I-10 Project – El Paso County Public Comment

Dear Mr. Trevino:

Thank you for the opportunity to provide feedback to the District regarding the Downtown 10
project. Interstate 10 moves a significant number of people and commerce throughout our region.
Having a strong, reliable, multimodal infrastructure network that includes roads, streets,
sidewalks, bike lanes, and mass transit is vital to the overall success of our region.

The Commissioners Court has taken previous action to support the Downtown I-10 Project as
one of four keystone projects identified by the El Paso Metropolitan Planning Organization. The
County remains in support of the District identifying thoughtful solutions to reconstruct the aged
infrastructure in our urban core, especially in regards to the Downtown Trench, which your
Department has said is in danger of failing. In analyzing the various alternatives developed
through the design process to date, the Court previously has requested that the District carry
forward previous Alternatives B and F through the entire National Environmental Policy Act
(NEPA) planning process. These alternatives were ranked as the fourth and fifth construction
scenarios behind the three identified as “viable” ahead of the Project’s second public meeting.

Now that you are taking public comment for the scoping of the Environmental Impact Statement,
which includes taking comment on the Need and Purpose of the project, we reiterate the request
to study those alternatives, especially Alternative F, which could be modified from a “tunnel”
concept to an extension of the Downtown Trench concept. Additionally, we request that you
include in the study the reconstruction of the Trench, an option that almost certainly would fit
within the existing budget, without requiring that other local projects be swept. It would be less
time-consuming, and it would allow for reconstruction of the bridges, a significant objective of
the project.

Regarding the Need and Purpose, we ask that you include driver safety, environment, and
connection of the urban street grid as primary objectives. As our previous public comments
indicate, we have significant questions about the congestion in this area and the need for
expansion. While that will remain a primary driver for your studies, equal weight must be given
 COUNTY OF EL PASO

to these other factors, which affect community quality-of-life, especially health, for many
thousands of our constituents. El Paso is an ozone non-attainment area, and I-10 is a major
source of ozone and particulates; mitigating the impact of these substances must be considered a
primary Need of the project. Regarding safety, the Need and Purpose must ensure the project is
aligned with the Texas Transportation Commission’s Minute Order 115481 of May 30, 2019,
which requires cutting traffic deaths on Texas roadways in half by 2035.
(https://publicdocs.txdot.gov/minord/MinuteOrderDocLib/115481.pdf)

Once again, thank you for your critical work on this issue, and we look forward to continuing the
dialogue to make the District’s project successfully meet the present and future needs of all of
our constituents in the El Paso region.