Air Alliance Houston analysis shows NHHIP MOUs do little to protect communities

AAH Statement on the City and County NHHIP MOUs with TxDOT

For Immediate Release
December 22, 2022
CONTACT: Riikka Pohjankoski, 713-589-7079, [email protected]

Earlier this week, Harris County and the City of Houston made a surprise announcement about the signing of two separate Memoranda of Understanding (MOUs) with the Texas Department of Transportation (TxDOT), effectively approving the North Houston Highway Improvement Project (NHHIP). This morning, the Harris County Commissioners’ Court unanimously voted to approve their MOU. The City signed its own MOU on Monday. While each party celebrated these agreements as transformational resolutions to long-standing issues with the project, our detailed analysis reveals that the MOUs will do very little to protect Houston communities from the harms posed by this project. Furthermore, the MOUs are non-binding, unenforceable, and offer no recourse if TxDOT fails to uphold its agreements.

While there were some positive elements, such as requiring TxDOT to ensure the I-45 corridor is Bus Rapid Transit (BRT)-ready, bikeway and trail improvements, and encouraging language accessibility via a “Multilingual Website,” we have several concerns regarding key provisions in both MOUs: 

  • Neither of these MOUs address air quality concerns. The County’s MOU provides additional air monitoring along the corridor, but this will do nothing to address the sources of the pollution – it will only make clear how badly air quality is affected. 
  • TxDOT has merely agreed to “consider” reducing the right-of-way (ROW) width in Segments 1 and 2 as long as it does not impede other project goals, such as expanding capacity for all modes. This makes any alternative design that reduces the ROW width or number of displaced homes, businesses, and churches highly unlikely and vests the ultimate decision-making authority with TxDOT. 
  • The MOUs make clear upfront that the Segment 3 design is not to be touched by this or any future agreement, despite the fact that a majority of the displacements occur in Segment 3 and this Segment is the primary focus of the ongoing civil rights investigation by the Federal Highway Administration (FHWA). 
  • TxDOT’s commitments to net-zero housing loss and ensuring community members can relocate within their own neighborhood lack specificity and accountability. $30 million for replacement housing is still woefully insufficient to address all projected housing loss. Much of the language in the City’s MOU is merely describing required federal regulations for relocation, not above-and-beyond concessions by TxDOT.
  • The MOUs lack clarity about life-saving flood prevention measures. For example, the County’s MOU specifies that TxDOT need only incorporate Atlas 14 rainfall data into Segment 1, not all three Segments. More specifics are needed about this major project concern.

It would be difficult to overstate our disappointment in the contents of these two MOUs, the closed-door manner in which they were created and signed, the lack of sufficient time for the public to read and respond to them, and the tone with which they were presented. The “solutions” provided in these MOUs should in no way be considered sufficient mitigation of the civil rights concerns in this project. Except for the BRT-readiness provision, few of the outlined changes bring the NHHIP more in line with City goals outlined in numerous planning documents, such as Resilient Houston or the Houston Climate Action Plan. In fact, by signing this agreement, the City and County are giving TxDOT greater license and legitimacy to cause harm to Houston communities.

We urge the City and County to act with greater transparency on any future decisions about this project. We will continue to work with partners to support the FHWA investigation and to ensure that community members have the opportunity to weigh in on such consequential decisions as the NHHIP.

Read our full analysis of the MOUs HERE


Air Alliance Houston is a non-profit advocacy organization working to reduce the public health impacts from air pollution and advance environmental justice through applied research, education, and advocacy. For more information and resources, please visit

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