TxDOT is seeking new input on the North Houston Highway Improvement Project (NHHIP) as part of the annual public comment period on the state’s 10-year Unified Transportation Program (UTP). The agency has provided an opportunity to participate in a survey regarding the future of the NHHIP – as well as a controversial highway project in El Paso – and has stated that it will consider removing funding for the projects depending on the results of the open comment period. 

Unfortunately, the flawed design of their survey clearly demonstrates that TxDOT is proving once again that they do not have the Houston region’s best interests at heart. 

The poor survey design is an insult to communities

In question 7 of the comment form, (see image below), residents are asked to identify their “role as it relates to the comments,” with the commenters able to choose from one of five options: 

While answering this question is optional to the completion of the survey, the framing of the question is exclusionary to a large portion of Houston-area residents, and will discourage full participation by many of the very communities that stand to be most impacted by this project.

Houston and Texas are home to a large immigrant community, many of whom may be directly affected by any number of projects available for comment. Language asking commenters to identify as “Citizens” or “Other” discourages broad participation from community members and is totally irrelevant to the issue at hand. Although this question is optional to the completion of the survey, that fact is not necessarily obvious to most participants. Asking this unnecessarily discriminatory question and then requiring the names and addresses of participants perpetuates paranoia and chills participation in the public discourse among immigrant communities. 

Whether this exclusionary choice was purposefully intended to deter participation or is simply poor wording, the distribution of this language on the TxDOT comment form is unacceptable, and such carelessly discriminatory language could arguably invalidate the results of the survey. AAH strongly opposes the inclusion of this question and will advocate for its consideration in the ongoing Title VI review of the NHHIP project.

In addition, because the survey is only available online, it inherently excludes the full participation of persons that have minimal access to the internet or the limited technological skills needed to access and complete the survey – attributes that are most prevalent among socially vulnerable demographics.

The binary choice given is misleading

In regards to the NHHIP, TxDOT only offers two options: “Support maintaining project and funding as proposed” or “Support removing project and funding.” By framing it as a binary option – either support the project as proposed or lose the allocated transportation funding for the Houston area entirely – TxDOT is forcing an impossible choice on our region’s residents. 

Community members, stakeholders, and local elected officials have all repeatedly pleaded with TxDOT to work with communities on improving the design. We’ve all expressed concerns about the aging infrastructure along the I-45 corridor and would support desperately needed improvements for safety and mobility. The City conducted an almost year-long additional community engagement process and outlined an alternative project vision that would improve mobility, connectivity and safety, while helping to address climate change impacts in more equitable ways. However, TxDOT has repeatedly refused to meaningfully engage in good faith. 

Now, the agency is refusing to acknowledge any of the nuances to the opposition of the NHHIP project as it is currently designed. Instead, they are asking the region to either support a project that may violate civil rights or lose out on funding for any improvements to the corridor whatsoever.

This simplistic binary framing is misleading and in bad faith. 

The integrity of the whole survey is questionable

Finally, the integrity of the online survey is not secure and allows for multiple submissions, which allows the results to be easily manipulated by any person with the capacity and motive to do so. Given the unprecedented amount of public infrastructure funding at stake in this project, the motive for fraudulent participation is easily identified and bad-faith manipulation is anticipable. 

In short: 

TxDOT’s latest public comment effort is discriminatory, manipulative, and lacks scientific integrity to be used as an honest decision-making tool. We are confident that an unbiased assessment of public opinion would show overwhelming opposition to the NHHIP project as it is currently designed – and that may very well be sentiment expressed as a result of this public comment period. However, we also contend that this sloppy and disingenuous attempt at public participation is not designed to accurately gauge public opinion and is not an adequate substitute for meaningful public discourse on a project that will reshape the Houston-area for the better half of the next century.

Due to the glaring flaws in this public comment period, the results of this survey should be voided. Please join us in expressing your concerns to TxDOT. The comment period will end at 4:00 PM on August 9, 2021. A virtual public hearing will take place August 2, at 3:00 PM. For any special accommodations, call (800) 687-8108 at least 3 business days before the public hearing.SUBMIT YOUR COMMENT