June 26, 2018

Freese and Nichols, Inc.

Attn: Dan Sefko, FAICP
10814 Jollyville Rd., Bldg. 4, Ste. 100
Austin, Texas 78759

Comprehensive Plan Advisory Committee

City of Lubbock
1325 13th Street
Lubbock, TX 79401

Submitted via email, with letter to follow

Re: Comments of the Alliance of East Lubbock Neighborhood Associations on

the Comprehensive Plan Advisory Committee process and development of
the City of Lubbock’s 2040 Comprehensive Plan.

Dear Committee and Consultants:

To develop a fair, equitable, and viable comprehensive plan for the City of Lubbock, the
Comprehensive Plan Action Committee (CPAC) process is appropriately built on a foundation of
public input. The advisory committee is designed to “corroborate public input, balance
qualitative and quantitative information, establish the high-level direction of the plan, [and]
identify key issues and strategies based on specialized understanding of the community.”1 To
accomplish this goal, CPAC set standards to “involve the community and stakeholders
throughout the process, create communication channels for residents and stakeholders to provide
input about vision, issues and opportunities, and incorporate input into planning strategies.”2

In accordance with these goals, the Alliance of East Lubbock Neighborhood Associations
(“the Alliance”) submits this public comment as a part of the CPAC public participation process.
The Alliance is a group of distinguished community members in East Lubbock. This group
includes civil rights leaders and the neighborhood association presidents of Chatman Hill,
Dunbar-Manhattan Heights, Parkway-Cherry Point, and Yellow House Canyon.

After reviewing the presentations provided by the consultant for the project, Freese and
Nichols, the Alliance fears that vital issues of equity, infrastructure, and environmental health
will not be properly addressed in the CPAC 2040 Comprehensive Plan. East Lubbock
neighborhoods faces several challenges. It is surrounded by industry, suffers from a shortage of
public and private investment, and lacks sufficient public transit. While the presentations
delivered during the CPAC process over the last year contain ample information and strategies
for dealing with development in Southwest Lubbock, the Alliance is troubled by the lack of

1
CITY OF LUBBOCK, Comprehensive Plan for the Future, CPAC 5–6 (Feb. 21, 2018),
https://clients.freese.com/Lubbock/files/47/Final%20-%20CPAC%20Meeting%209%20(2018_02_21).pdf.
2
Id.

1
thought and planning devoted to development and revitalization in East Lubbock. The decisions
made in the 2040 Comprehensive Plan will govern the health of East Lubbock for decades to
come. Therefore, the Alliance requests more work, research, and funding be dedicated to issues
critical to the east side. Further, the 2040 Comprehensive Plan must lay out how resources will
be allocated and include accountability measures to ensure legitimate follow through. To that
end, this public comment will identify several key areas of concern and provide suggestions for
improvement.

The Alliance’s concerns are: first, the presentations given by Freese and Nichols at
CPAC meetings fail to incorporate an understanding of East Lubbock’s geography, history, and
makeup, or learn from past revitalization plans. Second, the CPAC’s 2018 Interim Land Use
Plan concentrates industrial uses in the east side, disproportionately impacting predominantly
African-American and Hispanic communities. Third, the proposals for improving deteriorating
infrastructure and housing in East Lubbock are woefully inadequate. Fourth, the expansion of the
public transit system is not prioritized even though the current system does not provide access to
new development in Southwest Lubbock.

This comment is offered in the spirit of cooperation. It is the hope of the Alliance to work
with all stakeholders to create an equitable and truly comprehensive plan that will ensure
prosperity for all of Lubbock’s citizens, this generation and beyond.

Figure 1: The Alliance of East Lubbock Neighborhood Associations

I. To develop a truly comprehensive plan, the CPAC and its consultants must devote
more resources to East Lubbock.

The Alliance urges Freese and Nichols to devote more research and time to create a
robust East Lubbock revitalization component for the 2040 Comprehensive Plan. In June 2017,
Freese and Nichols identified “East Lubbock Initiatives” as one of its “core ideas” for the City of

2
Lubbock’s 2040 Comprehensive Plan.3 However, despite its purported focus on East Lubbock,
the research and plans for East Lubbock have been limited and uninformed. To meet the needs of
the historically oppressed neighborhoods of East Lubbock, a substantial amount of research
should be dedicated to the improvement of land use, transportation, infrastructure, and other
tenets of the comprehensive plan specific to East Lubbock. The Healthy Communities Policy
Guide, which the CPAC adopted in earlier meetings, states that improving the health of
communities requires “addressing poverty at its roots” and mitigating “historical injustices . . .
through changes to policy, programs, and practices.”4 If the 2040 Comprehensive Plan does not
include specific, realistic, and measurable goals, it will not accomplish this ideal for the
historically oppressed neighborhoods of East Lubbock.

The need for additional research is clear. First, Freese and Nichols was apparently
unaware of the 2004 North and East Lubbock Master Development Plan.5 This 2004 plan was
extremely detailed and provided dynamic analysis of the challenges facing East Lubbock. The
Alliance suggests that Freese and Nichols follow the model set forth in that plan: first analyzing
in-depth the impediments faced by the East Lubbock community, then proposing specific and
measurable goals for addressing them. Many of the projects identified for development in the
2004 plan are still left undone. The 2040 Comprehensive Plan should pick up where the 2004
plan left off.

Additionally, East Lubbock developed a community revitalization plan of its own. The
Gateway Plan, spearheaded by the late Eric Strong, envisions a connectivity corridor between
Chatman Hill and the depot district along 19th Street.6 The Gateway Plan envisions a community
space, a performance venue, and a park anchored by the Caviel Museum of African-American
History and the Lubbock Roots Historical Arts Council on Avenue A. Although the Gateway
Plan is supported by the Chatman Hill Neighborhood Association and the Lubbock Roots
Historical Arts Council, it was not mentioned nor considered in the CPAC presentations. The
Alliance urges Freese and Nichols as well as members of CPAC to review the Gateway Plan and
include it in the 2040 Comprehensive Plan.

Second, Figure 2 below, which are slides pulled from Freese and Nichols’ own
presentation, show that the consultants have not fully fleshed out issues in East Lubbock, nor
have they developed viable strategies and solutions for the area. During the presentation on
Canyon Lakes and East Lubbock, some weaknesses and challenges were identified but not
backed up by solutions. These weaknesses included “I-27 as a barrier, perception of East
Lubbock, identity, . . . lack of amenities, market demand, . . . undefined responsible entities, un-
unified vision, how to connect to East Lubbock, [and] limitations of existing plans and

3
Core Ideas: Future Land Use Policy Direction, CPAC 5 (June 13, 2017),
https://clients.freese.com/Lubbock/files/7/Core%20Ideas%20Handout.pdf.
4
AM. PLANNING ASS’N, Healthy Communities Policy Guide 3 (Sept. 24, 2017),
https://clients.freese.com/Lubbock/files/21/HEALTHY%20COMMUNITIES%20POLICY%20GUIDE%20DA%20
final.pdf.
5
CITY OF LUBBOCK, North and East Lubbock Master Development Plan (2004),
https://issuu.com/soldonlubbock.com/docs/northeastlubbockmasterplan.
6
JSA ARCHITECTS, Gqteway to East Lubbock (2017),
https://drive.google.com/file/d/0BzlZDK7lRWMUMU0yZHYzOU9Ua01kM0xBY2duWHFuVmVTQV9j/view?usp
=sharing.

3
regulations.”7 Naming these problems is a start, but the Alliance urges Freese and Nichols to also
work with the East Lubbock community to devise solutions. Further, the description of East
Lubbock is incomplete. The list of specific neighborhoods in East Lubbock does not even include
Chatman Hill. When referring to “East Lubbock,” the presentation included a vast area of the
north side of Lubbock. While there may be issues that are important to both the North and East
sides, the two regions contain very different neighborhoods with very different needs.

Figure 2: Slides from Freeze and Nichols East Lubbock Presentation

Simply put, the comprehensive plan will not be “comprehensive” if it does not properly
identify and address the needs of East Lubbock. Moreover, it will fail to meet the goal of making
“East Lubbock Initiatives” one of its “core ideas” for the plan. As CPAC affirms in its Healthy
Communities Policy Guide, healthy communities are built by “addressing poverty at its roots”
and mitigating “historical injustices . . . through changes to policy, programs, and practices.” 8
This can only be accomplished if the City of Lubbock is willing to give a hard and honest look at
East Lubbock, where much of the City’s poverty is concentrated. For this plan to be
“comprehensive,” CPAC must develop creative and specific strategies for various tax issues,
development solutions, road building, water development, and land use, just as it has done for
downtown and South and West Lubbock. To fulfill the requirements set out by the City and to
achieve the important commitments affirmed in the Health Communities Policy Guide, further
research and community input from East Lubbock’s citizens is essential.

II. The Comprehensive Plan must confront and resolve the severe land use and
environmental inequities in East Lubbock.

The Alliance is deeply troubled by the 2018 Interim Land Use Plan, adopted by the
Lubbock City Council on February 1, 2018. As has been the case with past Lubbock land use
plans, African-American and Hispanic citizens are disproportionately impacted by the
environmental hazards associated with industrial uses (see Figure 3 below). Past city policies and
land use plans created during the Jim Crow era sought to confine African Americans and
Hispanics to Lubbock’s east and north sides while at the same time expanding industry in those
areas. The earliest plans and policies were blatantly racist and openly considered race as a factor

7
Id. at 30.
8
AM. PLANNING ASS’N, Healthy Communities Policy Guide 3 (Sept. 24, 2017),
https://clients.freese.com/Lubbock/files/21/HEALTHY%20COMMUNITIES%20POLICY%20GUIDE%20DA%20
final.pdf.

4
in Lubbock’s industrial development. Even after the passage of the Civil Rights Act in 1964,
subsequent comprehensive plans actually expanded industrial uses in and around Lubbock’s
communities of color. The ramifications of these openly discriminatory land use practices are
still felt today. The residents of predominantly African-American and Hispanic neighborhoods
in the east and north sides must coexist with polluting industries and, as a consequence, suffer
from the disproportionate health and economic impacts these industries bring with them. As the
historic center of black settlement and culture in Lubbock, East Lubbock has been profoundly
affected by this past discriminatory land use and environmental racism. The Alliance asks the
CPAC to reverse this legacy of discriminatory land use in the 2040 Comprehensive Plan by
implementing the following measures.
First, the Alliance asks the CPAC to stop the expansion of industrial land uses near
residential neighborhoods. Second, the CPAC should recommend that the City undertake
investigatory and remedial measures to address the issue of existing industrial concentration in
African-American and Hispanic communities. This begins with the City commissioning an
independent study to investigate the environmental and health effects of concentrated industry in
the east and north sides of Lubbock. Texas Tech University would be an excellent partner for
this project because of its hometown location and unparalleled research muscle. Third, the City
should form a blue-ribbon committee made up of residents of affected neighborhoods, scientists,
community advocates, industry owners, city officials, and other stakeholders to encourage
cooperation and information sharing between these groups. The ultimate goal of this committee
should be the implementation of solutions that prioritize the health, safety, and economic
prosperity of East Lubbock residents now and in the future.
Fourth, the plan must include concrete and measurable goals to foster economic
development in East Lubbock. This begins with increasing connectivity between the east side
and the rest of Lubbock. Jim Crow era planning efforts used zoning to separate the black
community in East Lubbock from the white majority. More recent city plans and actions
reinforced this division—perhaps the best example being the wall formed by Interstate 27, which
separates East Lubbock from the rest of the city. While members of the Alliance is pleased that
CPAC has discussed connectivity corridors between East Lubbock, Downtown, and Texas Tech,
they have seen similar proposals and promises go unfulfilled. CPAC should ensure that these
connectivity corridors remain a priority by including concrete and measurable goals in the final
plan.
Fifth, the Alliance urges CPAC, Freese and Nichols, and the City of Lubbock to
postpone the submission of the 2040 Comprehensive Plan until the citizens of the east and north
sides have sufficient time and opportunity to contribute to the plan. Many residents of East
Lubbock feel they have not had a meaningful opportunity to participate as there was only one
meeting in East Lubbock, which took place about a year ago. The Alliance urges Freese and
Nichols and the CPAC to schedule public meetings on the east and north sides during non-work
hours to summarize the plan for residents and solicit further public input as soon as possible. For
too long, land use decisions were made without comprehensive cooperation and input from
communities of color. This unfortunate practice has led to the clearly inequitable results for
African-American and Hispanic communities evident today. The City can and must do better.
The following section will first address the disproportionate impact Lubbock’s industries
have on Lubbock’s minority communities. Second, it will document the history of the City’s past

5
discriminatory actions which led to this result. Finally, it concludes with a restatement of the
Alliance’s demands. Maps comparing the past and present demographics of Lubbock and the
location of land designated for industry and locations of polluting industries are included
throughout this section.
Figure 3: Map of Proposed Land Use and Environmental Inequities in East Lubbock

A. Lubbock’s majority African-American and Hispanic neighborhoods are

disproportionately impacted by the negative environmental effects of
industrial uses.

The areas set aside for industrial uses in the 2018 Interim Land Use Plan
disproportionately impact predominantly African-American and Hispanic neighborhoods and the
citizens living there.9 The Interim Land Use Plan builds upon past planning efforts by the City of
Lubbock to concentrate industry in the north and east sides of the city in the areas surrounding
Lubbock’s neighborhoods of color. These discriminatory land use practices have caused all the

9
Figure 3.

6
toxic release inventory (TRI) sites in Lubbock to be within or border census tracts which are
majority Black or Hispanic.10 A 2014 study from the Department of Geosciences at Texas Tech
found that census blocks with high density African-American populations were located at an
average of 568.1 meters closer to toxic releasing facilities than the average block groups in
Lubbock County.11 Chemicals released from these types of facilities include those that cause
cancer, acute human health effects, and/or significant adverse environmental effects. Closer
proximity to toxic releasing industries is indisputably more dangerous to human health and the
environment.
Further, the presence of industry is often accompanied by other nuisances incompatible
with residential uses. These include noxious or smelly fumes, noise pollution, smoke and smog,
and unsightly facilities and storage yards. The nearby presence of industry negatively affects
homeowners’ property values and threatens the future viability and vitality of adjacent
neighborhoods. The presentations given by Freese and Nichols have not addressed these critical
equity issues. The Alliance urges the CPAC, Freese and Nichols, and the City of Lubbock to use
their planning expertise to further investigate and propose strategies for addressing these
environmental inequities in the 2040 Comprehensive Plan
B. Lubbock’s history of discriminatory zoning is a direct cause of the current
land use pattern.
Early in Lubbock’s history, the city confined African Americans in the east side and built
industry around their communities. In 1920, the Lubbock Avalanche published an editorial
calling on the city to regulate where black Lubbockites could live.12 Three years later, in 1923,
the Lubbock City Council created Ordinance 223, which prohibited African Americans from
owning or renting property anywhere outside of the area south of 16th Street and east of Avenue
C, excepting bona fide servant’s quarters.13 The ordinance justified itself with barefaced racism,
claiming that African-American residents were “dangerous to the health” and environmentally
hazardous to whites.14 Although the ordinance was never read into law, it was signed by the
mayor and achieved the desired result—by 1940, all African-American births in Lubbock

10
Id.
11
Jason Michael Post, Spatial Environmental Inequality in Lubbock, Texas 43 (May 2014) (unpublished M.S.
thesis, Texas Tech University) https://ttu-ir.tdl.org/ttu-ir/handle/2346/58599 (“The average block group centroid in
Lubbock County was calculated to be 3.037.7m from a toxic waste releasing facility. The regression showed that
block groups containing a higher percentage of African American residents were located much closer to these
facilities. This closer distance was found to be statistically significant. African American residents are located an
average of 2469.6m away from toxic waste releasing facilities, a 568.1m closer proximity than the overall average
for all block groups in Lubbock County.”).
12
Robert Foster, Black Lubbock: A History of Negroes in Lubbock, Texas, to 1940 47 (Dec. 1974) (unpublished
M.A. thesis, Texas Tech University) (quoting Lubbock Avalanche (Feb. 5, 1920)) (“In all probability the time has
come when our city must designate a certain portion of the city for these people [African Americans] to build their
home and live separate and apart from the balance of us. People are not going to stand for negro neighbors, and if
there is not regulation made by the proper authorities there is liable to be regulations of a private nature, which
should be avoided if possible . . . .”).
13
Id. at 109.
14
Id. at 110 (quoting from Ordinance 223 Section 4) (“The fact that negroes and persons of African descent and
persons containing as much as one-eighth negro blood are residing in various portions of this city and their
residents is dangerous to the health and pollutes the earth and atmosphere, creates an emergency and
necessity that the removal of the charter requiring an ordinance to be read at two several meetings be suspended and
this ordinance been acted at the meeting of its introduction and effective upon publication.”).

7
occurred within the boundaries prescribed by the ordinance.15 Even as late as 1960, 93.8% of
Lubbock’s black population lived within the confines (see Figure 4 below).
Figure 4: Percentage of Lubbock’s Total Black Population Residing in Census Tracts
(1960)

Segregation was also enforced through private action.16 White developers and citizens
carried out the spirit of the ordinance by incorporating deed restrictions that prohibited property
owners from selling to people of color. And even though the Supreme Court ruled racial zoning
laws unconstitutional in 1917,17 the City of Lubbock found new ways to use its zoning power to
further segregation. In Lubbock’s first comprehensive plan, published in 1943, city planners
created industrial buffer zones separating communities of color from the rest of the city. The
1943 comprehensive plan was openly discriminatory,18 reserving the east and north sides for
Black and Hispanic neighborhoods and industrial uses:

15
James R. Henley Jr. & Charles K. Edgley, Population Change by Ecological Areas in East Lubbock (1960–1965)
(on file with Texas Tech University, Southwest Collections).
16
Jason Michael Post, Spatial Environmental Inequality in Lubbock, Texas 5 (May 2014) (unpublished M.S. thesis,
Texas Tech University) https://ttu-ir.tdl.org/ttu-ir/handle/2346/58599.
17
The Lubbock ordinance was assuredly unconstitutional when it was written. The Supreme Court struck down a
similar ordinance in Louisville, Kentucky in Buchanan v. Warley. 245 U.S. 60 (1917).
18
Cynthia L. Sorrensen, Perry L. Carter & Jack Phelps, Urban landscape as mirror of ethnicity: trees of the South
Plains, URBAN GEOGRAPHY 36:7, 1042–63 (July 2, 2015), https://doi.org/10.1080/02723638.2015.1039397
(“Discriminatory thinking behind annexation was blatantly demonstrated in the 1943 city plan of Lubbock. Eastside
property that extended from industrial areas was deemed ‘not appropriate’ for White residences. Black and Latino
residential landscapes were not seen in a similar vein, and instead were deemed ‘appropriate’ for the eastside and its
exposures to industry. This became even more clear in 1953 when the Southeast Lubbock Development Board

8
 The area to the East and to the North of the present business district has been
preempted by the Santa Fe Railroad right-of-way tracks and yards. Immediately
beyond this industrial area the attendant development is principally for Negro and
Mexican families. This [cannot] be considered as desirable potential property for
white residential development excepting probably the area on the heights to the
East of the Mackenzie State Park. The prospective developments to the East and
North, then, under such circumstances could not be expected to encourage the
extension of the central business district in those directions.19
In 1943, most of the Lubbock’s black population lived in the “Flats,” the “Wheelock
Addition” (present-day Chatman Hill), the Seiber Second Additions, and unincorporated areas
outside of the city limits. Wheelock was surrounded by industry and the railroad (see Figure 5
below).20 Its western border was the Santa Fe railroad, zoned “M” for manufacturing. To the
south, a strip of land was zoned L for manufacturing. To the east, separating the black
community from downtown, lay six blocks of railroad tracks and land zoned F, J, and L for
industry and manufacturing.21 The Seiber Second Additions were immediately south of
Wheelock and the city limits line. This land would be annexed by the city during urban
renewal—a portion was zoned residential and incorporated into Chatman Hill and Manhattan
Heights. The area south of present day Coronado Drive would become industrial.

(SLDB) was established for the sole purpose of developing eastside residential zones for Black residences. The
mission of the board aligned with the urban blight/annexation discourse and worked to alleviate hazardous
conditions within already-existing slum areas, which had supposedly resulted from overcrowding. It also encouraged
the relocation of historic Black communities to newer developments on the eastside. In essence, Black and Latino
residential landscapes were not really residential in the minds of city planners; these landscapes were instead
understood as extensions of industrial landscapes where labor lived and worked.” (Emphasis added.)).
19
CITY OF LUBBOCK, TEXAS PLANNING, The City Plan of Lubbock Texas (1943),
https://www.ci.lubbock.tx.us/departmental-websites/departments/planning/lubbock-s-past-and-
future/comprehensive-plans.
20
Id.
21
Id. at 46; see also Post, supra note 11, at 8.

9
 Figure 5: 1943 Plan Zoning Districts22

Lubbock’s 1959 comprehensive plan perpetuated the discriminatory practices of the

city’s 1943 comprehensive plan. Almost 40 years had gone by since the creation of Ordinance
223, but nearly 94% of Lubbock’s black population still lived within the confines it set (see
Figure 4 above). The 1959 comprehensive plan continued to concentrate industrial zoning
around the African-American community, cementing the environmental racism of surrounding
Chatman Hill with pollution and expanding industrial zoning in newly annexed land in the
southeast.23 Ironically, the 1959 comprehensive plan stated that the ideal neighborhood should be
“free from the noxious odors, sounds and sights of industry.”24 Heavy industries, it stated, “are
known to emit smoke, dust, odor, or noise, or are hazardous by nature.”25 The plan made much
of a southwestern prevailing breeze as a reason to locate industry in the northern and
southeastern parts of the city because the wind would carry noxious fumes away from residential
areas.26 But no thought was devoted to the existing and proposed black neighborhoods on the
east side, which were already surrounded by industry.27

22
CITY OF LUBBOCK, TEXAS PLANNING, Lubbock Comprehensive Land Use Plan (1943).
23
CITY OF LUBBOCK, Lubbock Comprehensive Plan Land Use Report (1959),
https://www.ci.lubbock.tx.us/docs/default-source/planning-file-library/1959-plan.pdf?sfvrsn=f7809bc8_4.
24
Id. at x.
25
Id. at 6.
26
Id. at 16.
27
Cynthia L. Sorrensen, Perry L. Carter & Jack Phelps, Urban landscape as mirror of ethnicity: trees of the South
Plains, URBAN GEOGRAPHY 36:7, 1048 (July 2, 2015), https://doi.org/10.1080/02723638.2015.1039397.

10
 Figure 6: Proposed Zoning from 1959 City of Lubbock Plan28

Concurrent with the 1959 planning effort, Lubbock also began the process of urban
renewal. The Housing Act of 1949 provided federal funds to cities to combat blight in urban
areas. Cities could use the funds to tear down and relocate “blighted” communities under the
auspice of health and safety.29 Urban renewal left no part of Lubbock’s black community
untouched. During the “Coronado Project,” The Lubbock Urban Renewal Agency acquired and
demolished almost all the homes in present day Chatman Hill and attempted to relocate the
inhabitants to new subdivisions designed specifically for African Americans.30 These
subdivisions included Manhattan Heights, which was developed for “Negro occupancy since the
initial planning for the Coronado Project came into being.”31 In an interview in 1969, J.D.
Hassell, a member of Lubbock’s first planning and zoning board acknowledged urban renewal
was meant to keep blacks separated from whites. Segregation, he said, “was perfectly natural and

28
Lubbock Comprehensive Plan Land Use Report (1959).
29
Id.
30
John Overton Burford, The Development of the Coronado Urban Renewal Project 48–49 (1966) (unpublished
MBA thesis, Texas Tech University) https://ttu-ir.tdl.org/ttu-ir/handle/2346/13637?locale-attribute=es.
31
Letter from H.O. Alderson, Executive Director of Urban Renewal Agency of City of Lubbock (Jan. 15, 1960) (on
file with Texas Tech University, Southwest Collections).

11
logical at that time.”32 While Urban Renewal Agency policies continued to confine African
Americans to the east side, city planners continued the expansion of industrial zoning in the same
area.
In 1986, Lubbock published a new comprehensive plan. In the years since 1959, the
racial makeup of the east and north sides changed substantially. The Arnett Benson and Jackson
Mahon neighborhoods became majority Hispanic. The Parkway and Cherry Point
neighborhoods, in the northwest quadrant of the city, changed from majority white in 1960 to
majority African American and Hispanic by 1980 (see Figure 7 and Figure 8 below). After the
demographics had changed, the 1986 comprehensive plan proposed major expansions of
industrial zoning in these areas. The change essentially blocked the expansion for these now
majority minority neighborhoods outside of their existing boundaries and limited the possibility
of future residential development.33 Shortly following this publication of the 1986
comprehensive plan, the final portion of Interstate 27 was constructed along the old Avenue C
corridor. Although nearly 70 years had passed since Ordinance 223, the highway served as a
physical reminder of the racist ordinance, having been built along the same barrier the old
ordinance had prescribed. The land use patterns finalized in the 1986 comprehensive plan,
coupled with the construction of I-27, have influenced the growth of Lubbock for the last 30
years. The expansion of industrial land use in East and North Lubbock near communities of
color, and the construction of I-27, which effectively severed East Lubbock from the rest of the
city, perpetuated the discriminatory impact of past City plans.

32
Interview with J.D. Hassell by Alice Johnson (Jan. 11, 1972) (On file with Texas Tech University, Southwest
Collections).
Interviewer: “Now you had the Manhattan Project [sic] come up during the time you were on. Now this
was particularly for the blacks.
Hassell: “That’s right.”
Interviewer: “Now as this a city plan to keep them over there?”
Hassel: I can only offer my opinion on that and I think it was. It was perfectly natural and logical at that
time.”
33
CITY OF LUBBOCK, 1986 Comprehensive Land Use Plan (1986), https://mylubbock.us/docs/default-
source/planning-file-library/land-use-plan-1975-1986.pdf?sfvrsn=1f5f98c8_.

12
Figure 7: Percentage of African American Population in Census Tract (1980)

Figure 8: Percentage of Hispanic Population in Census Tract (1980)

13
 C. The 2040 Comprehensive Plan must remediate the harm done to minority
communities by past discriminatory land use practices.
The land use pattern set forth in the 2018 Interim Land Use Plan is built on a foundation
of discrimination. The new plan must make a clean break from the past. CPAC must take steps to
end the disparate impact Lubbock’s industries have on communities of color. The Alliance asks
CPAC, Freese and Nichols, and the City of Lubbock for the following: first, halt the expansion
of industry near predominantly African-American and Hispanic neighborhoods. Second, the City
should fund an independent study of the environmental harms of industry in East and North
Lubbock. Third, the City should form a blue-ribbon committee of community stakeholders to
create innovative solutions to remediate existing harms to health and ensure a healthy and
prosperous future for East and North Lubbock residents. Fourth, the plan must include goals and
measurable milestones to foster economic development in East Lubbock and increase
connectivity between it and the rest of the city. Fifth, the submission of the plan must be
postponed so that communities on the east and north side can meaningfully participate in the
planning process. Meetings on the north and east side should be scheduled for evening or
weekend hours as soon as possible.
The leaders of modern day Lubbock work hard to keep the American dream alive for
every Lubbock resident. With cooperation, straight-talk, hard work, and a commitment to equity
there is no limit as to what will be accomplished.

III. The Comprehensive Plan must address East Lubbock’s substandard infrastructure.

Improved and well-maintained infrastructure in East Lubbock is key for its communities
to thrive. Roads on the east side must be given the same care as roads in other parts of the city.
East Lubbock’s access to municipal services should not come second to the rest of town, nor be
sacrificed in order to subsidize new growth in other regions of Lubbock.
The newly finished Marsha Sharp Freeway ends where East Lubbock begins, and with it
so does road quality, ease of entrance and exit, quality lighting, and connectivity with the rest of
the city. Infrastructure improvements are needed to improve the community, make the area more
attractive to developers, and ensure that residents on the east side are treated with dignity by their
city. East Lubbock, especially along Avenue A, is subject to much heavier industrial traffic than
other areas of town, and the streets show the wear. Similar conditions exist along Martin Luther
King Boulevard, Broadway Street, and Parkway Drive. East Lubbock is in desperate need of
projects designed to improve traffic flow, grant easier access to businesses along Parkway, and
connect East Lubbock to the rest of the city. All of East Lubbock’s main thoroughfares would
benefit greatly from improved aesthetics, whether it be landscaping, public art, or better curbs
and sidewalks. Alongside major thoroughfares such as MLK and I-27, the city should analyze
and update safe crossings for pedestrians, especially near MLK and railroad crossings. East
Lubbock would also benefit from incentives to install fiber optic and other communication line
updates. Compared to other parts of the city, roadway lighting is lacking on many stretches of
East Lubbock’s main thoroughfares and throughout its neighborhoods. MLK in particular needs
updates to improve street lighting. Better lighting would make the area more inviting and help
change the perception that the east side is unsafe. While other areas of town thrive, there are still

14
residential streets that are unpaved in East Lubbock. Neighborhoods in Yellow House Canyon
and Southeast Lubbock, for example, remain largely unpaved. Similarly, sidewalks and overhead
electrical wiring are in disrepair throughout the east side. While it is the property owner’s
responsibility to maintain the sidewalks and electrical wiring, these amenities are used by the
public, and the City should step in to ensure they are properly maintained. This will increase the
appeal, walkability, and electrical use throughout the community.
Unlike in other parts of the city, many East Lubbock properties are abandoned, vacant
lots are unmaintained, and dilapidated structures persist without the city taking any action. While
there are programs in place to rehabilitate homes, there must also be a process to demolish
abandoned structures and make them an asset to the community again. The city must encourage
infill of existing neighborhoods to help stabilize the community. Past city plans encouraged the
creation of programs to hold neighborhoods accountable for blighted properties, but the Alliance
fears that strategy would be ineffective in East Lubbock, where more and more homes that were
once owner occupied have been turned into rental properties. Many of these properties have been
neglected by absentee landlords who do not themselves live in East Lubbock. The city must
ensure that these properties are up to code and sufficiently maintained, and that landlords are
held accountable for the condition of their properties.
The Alliance hopes that efforts continue to be made to change the designated flood zones
in its community. Much of Chatman Hill has been deemed a flood zone by the Federal
Emergency Management Agency, despite its high elevation and sufficient drainage. This
discourages new construction and burdens buyers with unnecessary extra costs. The city
deserves praise for working to change the designation of flood zones in north and east Lubbock.
The Alliance asks that the city continue to prioritize amending these flood zone designations
when incorrect.
Freese and Nichols’ presentations on the draft comprehensive plan stress the importance
of perception and call for investments in areas that serve as gateways for travelers driving into
the city from Dallas, Austin, and Houston.34 East Lubbock is one of those gateway areas.
Providing improved and equitable municipal services to East Lubbock will not only benefit
historically neglected neighborhoods; it will also improve the perception of Lubbock as a whole.
While this type of project was called for in both the 1986 land use plan and the 2004 North and
East Master Development Plan, it has yet to be realized. The city must follow through on today’s
calls for better linkage to the rest of town.35
In developing the 2040 Comprehensive Plan, the Alliance asks that the 2004 North and
East Lubbock Master Development Plan be revisited, analyzed, and expanded. Some of the ideas
asserted in that plan have succeeded, some remain ongoing, but too many were never
implemented or fully realized. There must be accountability in achieving these goals and input
from the community. Further, the Alliance urges the CPAC to follow the tenets and adopt the

34
Core Ideas: Future Land Use Policy Direction, CPAC (June 13, 2017),
https://clients.freese.com/Lubbock/files/7/Core%20Ideas%20Handout.pdf.
35
Core Ideas: Future Land Use Policy Direction, CPAC (June 13, 2017),
https://clients.freese.com/Lubbock/files/7/Core%20Ideas%20Handout.pdf.

15
goals of the Healthy Communities Policy Guide - a healthy, well-served community is key to
East Lubbock thriving into 2040 and beyond.36

IV. The Comprehensive Plan must include strategies to make public transit more
accessible to East Lubbock neighborhoods.

East Lubbock needs a comprehensive plan that makes public transportation more
accessible to its residents and fosters positive development for the community. Without a proper
plan for public transit, the pattern of low-density, single-family zoning, and low-density retail
sprawl will continue to make transit a hardship rather than a lifeline.37

The City of Lubbock has tasked several organizations with improving public transit.
These include CPAC, the Lubbock Metropolitan Planning Organization (MPO), the Public
Transportation Strategic Planning Task Force, and the South Plains Regional Coordination
Transportation Advisory Committee. They all have identified weaknesses in the Lubbock transit
system, but to date these problems have gone unaddressed. For example, in 2004 Lubbock City
Council appointed the Public Transportation Strategic Planning Task Force, which identified
problems and opportunities with Lubbock public transit. Problems included that the “[f]unding
doesn’t match [the] mission,” a lack of “[u]nderstanding/perception of what Citibus does,” a lack
of “[a]ccess to all parts of the city,” and deficient facilities.38 The task force identified
“[building] partnerships and auxiliary enterprises” as an opportunity. To the Alliance’s
knowledge, none of these weaknesses have been sufficiently addressed, nor have enough
opportunities been seized.

In 2007, Freese and Nichols and the Lubbock MPO were both tasked to improve public
transit in Lubbock by conducting research and creating a plan which would extend from 2012 to
2040.39 Many of the organizations listed above requested that Lubbock incorporate extensive
public transit plans into its land use plan.40 However, the interim plan fails to address public
transit issues, and Freese and Nichols’ presentations throughout the CPAC process have been
insufficient in regard to public transit. In a recent presentation regarding public transit, Freese
and Nichols posed a series of questions about public transit to a panel that had no familiarity or
expertise in the area. Questions regarding whether transit demand is being met, what new
connections or services are needed, and how transit could be further integrated within the
“complete streets” model went unanswered.41 Freese and Nichols has also presented inaccurate

36
AM. PLANNING ASS’N, Healthy Communities Policy Guide (Sept. 24, 2017),
https://clients.freese.com/Lubbock/files/21/HEALTHY%20COMMUNITIES%20POLICY%20GUIDE%20DA%20
final.pdf.
37
Song et al., Techniques for Mitigating Urban Sprawl: Goals, Characteristics and Suitability Factors (Aug. 2002),
http://ctr.utexas.edu/wp-content/uploads/pubs/0_4420_1.pdf. Report prepared by UT’s Center for Transportation
Research for TX DOT’s research office includes chapters on home rule cities in TX controlling land use and the
legal authority in Texas for policy actions related to transportation-efficient land use strategies.
38
LUBBOCK METRO. PLANNING ORG., 2012-2040 Metropolitan Transportation Plan 38 (2007),
https://www.mylubbock.us/docs/default-source/lubbock-metropolitan-planning-organization-file-library/2040-
metropolitan-transportation-plan-(mtp-2040).pdf?sfvrsn=0.
39
Id. at 23.
40
Id.
41
CITY OF LUBBOCK, Comprehensive Plan for the Future, CPAC 100 (Feb. 21, 2018),
https://clients.freese.com/Lubbock/files/47/Final%20-%20CPAC%20Meeting%209%20(2018_02_21).pdf.

16
or misleading information about public transportation in Lubbock. For example, the consultants
stated that there are “[nine] bus routes serving the City as a whole,”42 when in fact these routes
do not serve the city as a whole. The routes serve the East and North sides and inside the Loop,
but do not extend into areas of new development or economic prosperity in the south and west
parts of Lubbock. These routes were designed for the needs of Lubbock in 1993, not 2018 nor
2040. Lastly, during the Capital Development Activities presentation, Freese and Nichols did not
address either East Lubbock infrastructure or public transit.43 This is unacceptable, as
transportation is one of CPAC’s major pillars and is a significant part of Lubbock’s Capital
Improvement Projects.44 The City must prioritize public transit plans that address the current and
future needs of the city’s residents and will give citizens of East Lubbock access to all parts of
the city.

Although the Lubbock MPO worked to create a plan which seeks to address public-
transit issues, this plan has proved to be ineffective and inadequate. The 2012-2040 Lubbock
Metropolitan Transportation Plan identifies itself as “a tool to continue to ensure convenient,
efficient, and reliable transportation alternatives for all sectors of the metropolitan area.”45 The
plan identifies various goals to accomplish regarding public transit within the plan. The Texas
Department of Transportation stated goals for “better integration of transportation and land use
planning, multimodal transportation systems, methods to monitor and evaluate performance of
the multimodal transportation system, congestion, air improvement, quality of life, and improved
neighborhood opportunities for economic development.”46 The local Lubbock Transportation
groups’ goals within the plan were “[t]o meet the objectives for both human service and public
transportation programs, [t]o do more with limited resources, [t]o enhance mobility within and
between communities, [t]o preserve individual independence, [t]o enhance quality of life, [t]o
generate new revenues, [t]o reduce the cost of providing individual trips, [t]o increase efficiency
and productivity of transportation services, [and] [t]o build a consensus on how to use available
resources.”47 The MPO also identified unmet needs: “operating assistance shortfall, lack of
options to employment locations not on route systems, fixed route service expansion” as well as
a litany of other unmet needs.48 Throughout the planning, all neighborhood associations were to
receive notification of the plan.49 To accomplish many of these goals, the city was advised to
conduct fixed route study which would “attempt to undertake a comprehensive route evaluation,
which will include boarding and alighting surveys, service assessments, and other processes
designed to gain insight into consumer opinions of the service and ways to improve efficiency
and effectiveness.”50

42
Id. at 67.
43
CITY OF LUBBOCK, City Development Activities (Jan. 22, 2018),
https://clients.freese.com/Lubbock/files/40/City%20Development%20Activities%20(2018_01_22).pdf.
44
Id. at 16.
45
LUBBOCK METRO. PLANNING ORG., 2012–2040 Metropolitan Transportation Plan 37 (2007),
https://www.mylubbock.us/docs/default-source/lubbock-metropolitan-planning-organization-file-library/2040-
metropolitan-transportation-plan-(mtp-2040).pdf?sfvrsn=0.
46
Id. at 23.
47
Id. at 70.
48
Id.
49
Id. at 24.
50
Id. at 73.

17
 Since 2004, public transit in Lubbock has not improved, and these goals have not been
met. Public transit was not incorporated into the future land use plan sufficiently as evidenced by
Freese and Nichols’ lack of research and effective plans. Neighborhood associations in the
Alliance were not given sufficient notification of the plan. The strengths and weaknesses of
public transit were not further researched nor were they improved upon. A fixed route study was
never done, with the most recent review having last been made in 1993. This has rendered nearly
all of the goals set out by the MPO incomplete.

Public transit does not give residents access to all parts of the city. In fact, access has
decreased since 2007. Below is a Citibus fixed route map in 2007 followed by the fixed route
map in 2017. Not only has the route access worsened, but the growth of Lubbock has expanded
further away from public transit access. The efficiency of the transit for those in East Lubbock
has worsened as well. The routes surrounding East Lubbock that provide access across the city
have extremely long commute times.51 The route running to Lubbock Estacado High School and
Kings Dominion runs less frequently.52 There is little to no access to the Southeast part of
Lubbock, including Yellowhouse Canyon, as well as to the South Plains Food Bank.53 The bus
does not run on Sundays and has limited options after 7 p.m. on Mondays through Saturdays.
This makes relying on transportation extremely difficult for those working outside of a normal
business schedule. Texas Tech’s comprehensive transit study of Lubbock in 2015 found that
Citibus was “not viable to other parts of the city.”54 Of those polled in the study, 78% stated that
public transit did not provide accessibility to areas outside of Texas Tech.55 These transit
problems are proof of a flawed system. The City of Lubbock identified problems and researched
some solutions, but it has failed to prioritize funding and research for over a decade. The
Alliance urges the CPAC to address these problems head on by doing further research and
incorporating public transit planning into the 2040 Comprehensive Plan.

51
Fixed Route Map, CITIBUS (Jan. 2017), http://www.citibus.com/cms-assets/documents/266016-
318014.2017fixedroutefinalcompressed.pdf.
52
Id.
53
Id.
54
TEXAS TECH UNIV., Transit Master Plan, SRF (June 2015),
https://www.depts.ttu.edu/parking/PDFsandDocuments/TransportationMasterPlanExecutiveSummary.pdf.
55
Id.

18
 Figure 9: 2015 Texas Tech Transit Study56

56
TEXAS TECH UNIV., supra note 52, at 14.

19
 Figure 10: 2007 Lubbock Fixed Routes57

Figure 11: Current Lubbock Fixed Routes58

57
LUBBOCK METRO. PLANNING ORG., Lubbock Metropolitan Transportation Plan: 2032 16 (Sept. 18, 2007),
http://webcache.googleusercontent.com/search?q=cache:mUCdOaT9j9AJ:oaktrust.library.tamu.edu/bitstream/handl
e/1969.1/90602/Lubbock%2520MTP%25202007-2032.pdf+&cd=1&hl=en&ct=clnk&gl=us.
58
Fixed Route Map, CITIBUS (Jan. 2017), http://www.citibus.com/cms-assets/documents/266016-
318014.2017fixedroutefinalcompressed.pdf.

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 Funding public transit to an extended part of the city is economically viable. According
to CPAC, Citibus comprises merely 0.1% of the City of Lubbock’s total debt.59 Also, Citibus in
Lubbock is already considered one of the top cost-recovery bus systems in Texas and the United
States in 2016–2017.60 Thus, Citibus can extend fixed-routes and increase frequency of service
while remaining economically viable. The CPAC should use its influence to encourage
expansion of public transit and create the 2040 Comprehensive Plan with expansion in mind.
Finally, the CPAC should urge the City of Lubbock to fund a fixed route study of the transit
system. Lubbock has not conducted such a study since 1993. Twenty-five years of massive
growth has rendered the 1993 study virtually useless. Funding a fixed route study will help the
City of Lubbock understand how to improve access to more parts of the city, improve ridership,
and maintain financial viability.

Figure 12: Lubbock Municipal Debt61

CPAC and Freese and Nichols must urge the City of Lubbock to prioritize public transit
by actually funding goals instead of simply writing them down. From the City’s 2004 Public
Transit Study, 2004 NE Lubbock Master Development Plan, 2007-2032 MPO Plan, and 2017
South Plains Five Year Regionally Coordinated Plan, it is clear that Lubbock can develop broad
goals and ideas. However, the fruit of these plans are often underfunded and unrealized when it
comes to the interests of East Lubbock. While the City of Lubbock funds costly research and
construction for major highway projects like Route 88 and major boulevards on the south and

59
Blu Kostelich, City Finance & Debt Capacity, CITY OF LUBBOCK 7 (Jan. 22, 2018),
https://clients.freese.com/Lubbock/files/39/Lubbock%20Finance%20(2018_01_22).pdf.
60
CITY OF LUBBOCK, Approved Operating Budget & Capital Program 92 (Oct. 1, 2017),
https://www.ci.lubbock.tx.us/docs/default-source/finance-files/fy-2017-18-approved-operating-budget-and-capital-
program---volume-ii.pdf?sfvrsn=44e12fc9_2.
61
Kostelich, supra note 57, at 7.

21
west parts of Lubbock, it fails to incorporate sufficient funding for research or building on public
transit. Many of these coordinated plans suggest that the 2040 Comprehensive Plan incorporate
public transit as a major component of the plan. CPAC should honor this suggestion and include
a more detailed, comprehensive, and measurable plan for public transit so that people have
access to all parts of the city.

V. Conclusion

The decisions CPAC makes in including fair and equitable land use, infrastructure, and
public transit in the 2040 Comprehensive Plan will impact the health of the East Lubbock
neighborhoods for decades to come. Therefore, the Alliance asks that more work, research, and
funding be dedicated to issues outlined above. To accomplish this, the Alliance urges Freeze and
Nichols, the CPAC, and the City of Lubbock to take the following measures:

1. Hold more public meetings on the east and north sides of Lubbock after 5 p.m. on
weekdays or on weekends to address the various needs of the community, including but
not limited to the issues raised in this public comment.
2. Develop a better understanding of East Lubbock’s geography and make-up, including an
understanding of how past City plans hurt citizens of East Lubbock and how the 2040
Comprehensive Plan could help redress these harms. Adhering to the tenets of Healthy
Community Guide will help Freeze and Nichols and the CPAC accomplish this goal.
3. Conduct further research into the specific needs of East Lubbock to move from
“identifying issues” to “recommending strategies,” and finally to “implementation.”
4. Recommend the cessation of the expansion of industrial land uses in areas bordering
residential areas. The CPAC should include remediation strategies to eliminate the
harmful effects of industrial land use in East Lubbock. The City should commission an
independent research study, perhaps conducted by Texas Tech, to determine the health,
environmental, and economic effects of industrial concentration in North and East
Lubbock. In addition, the CPAC should recommend the formation of a blue-ribbon
committee made up of East and North Lubbock residents, community advocates,
scientists, planning experts, industry owners, city officials, and other stakeholders to
devise solutions that will ensure the good health and economic prosperity for East and
North Lubbock residents for decades to come.
5. Include concrete and measurable goals to foster economic development in East Lubbock.
These should include strong coordination between CPAC and the Lubbock MPO to foster
development of infrastructure and public transit in East Lubbock. This should include a
revisiting of past City plans such as the 2004 North and East Master Development Plan
and any prior MPO plans to determine whether the goals were accomplished, and if not,
to incorporate them into the new land use plan.
6. Conduct a fixed route study of the Citibus system and allocate funds to extend efficient
routes to south and west Lubbock.
7. Delay any implementation of a land use plan until CPAC, Freese and Nichols, and the
City of Lubbock researches these topics in more detail, and CPAC affirms adequate
changes.

22
 Thank you for your attention to this letter. The Alliance offers this comment in the spirit
of cooperation and looks forward to working with you to create an equitable and truly
comprehensive plan that will ensure prosperity for all of Lubbock’s citizens for years to come.

Sincerely,
The Alliance of East Lubbock Neighborhood Associations

Tina Betts, President of Parkway-Cherry Point Neighborhood Association

Billie Russell, President of Dunbar-Manhattan Heights Neighborhood Association
Dianna Thomas, President of Chatman Hill Neighborhood Association
David Washington, President of Yellowhouse Canyon Neighborhood Association
Rose Wilson

Michael Bates, Attorney at Law batesm@lanwt.org

Mark Oualline, Attorney at Law ouallinem@lanwt.org

Legal Aid of NorthWest Texas

Community Revitalization Project
1001 Main Street, Suite 502
Lubbock, Texas 79401
806-763-4557

cc: Lubbock City Council

23