15 Proposed Amendments to the Interlocal Agreement - Public Comment — original pdf

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ORGANIZATION OF BIOLOGICAL FIELD STATIONS Advancing field-based research, education, and stewardship across the globe www.OBFS.com November 9th, 2026 The Honorable Kirk Watson, Mayor, City of Austin Mr. T.C. Broadnax, City Manager, City of Austin Dr. Eric Johnson, Assistant City Manager, City of Austin Members of the Austin City Council 301 West 2nd Street, Austin, TX 78701 Re: Letter of Support for the Brackenridge Field Laboratory – Protecting a Cornerstone of the City of Austin’s Research, Teaching, and Public Engagement Dear Mayor Watson, City Manager Broadnax, and Members of the Austin City Council, I write in my capacity as President of the Organization of Biological Field Stations (OBFS), the professional association representing the 1,200+ field stations and marine laboratories across the globe. OBFS's mission is to support the field station and marine laboratory community and to advocate for the long-term protection of the places where field science and education happen. It is in this capacity that I write to express OBFS's strong support for The University of Texas at Austin's Brackenridge Field Laboratory (BFL), and to urge the City to ensure that BFL is permanently protected as the University and the City of Austin consider amendments to the 1989 Brackenridge Development Agreement. We applaud the effort to preserve the Lions Municipal Golf Course, and we urge the City not to approve amendments to the 1989 Brackenridge Development Agreement that would open BFL to development. Field stations and marine laboratories, like BFL, are critical and irreplaceable components of scientific research infrastructure. They protect land that provides the ecosystem services every community depends on, including clean air, water, and habitat, and they provide the long-term, undisturbed field conditions needed to understand how those systems respond to change. Field stations are also community assets: places where residents, schoolchildren, and volunteers engage directly with science. A field station within an expanding city is exceedingly rare, and once it is built over, it cannot be recreated elsewhere. Decades of research and a community’s access to a living laboratory are lost with it. BFL is a particularly strong example of what this stewardship offers a city. Established in 1966 on 82 acres of the Brackenridge Tract, BFL is the only active, formal research site within greater Austin that contributes to our understanding of the region’s urban ecology, with findings that matter to the State and the Nation. Its research on invasive species of importance to Austin and Texas, including fire ants, tawny crazy ants, cactus moth, buffelgrass, and pasture mealybug, has led to management through biological controls and non-chemical methods. Its student-led 15 Proposed amendments to the Interlocal Agreemnt between the City and the University of Texas related to the Brackenridge Tract.1 of 25restoration and monitoring of Schulle Creek, its studies of aquifer responses, and its research on drought and land management all speak directly to Austin’s environmental challenges. BFL supports hundreds of independent student studies and its habitats hold roughly 1,200 species of butterflies and moths, 200 species of native bees, 370 species of plants, and 180 species of birds, all within minutes of downtown. BFL is also deeply woven into Austin’s community life. Its Science Under the Stars program, in which graduate students give monthly public talks, has earned national acclaim. BFL hosts an annual BioBlitz with large community participation, tours for K-12 classes and neighborhood associations, volunteer days with Master Naturalists and community members, meetings of natural history associations, and regular public surveys through eBird and iNaturalist. For many Austinites, and for many UT students, BFL is a first serious encounter with the natural world, and it is a living observatory of Austin’s own natural systems. As the community has long valued greenspace and the knowledge that worthwhile research and teaching happen on its doorstep, BFL is an asset in preserving the quality of the City. Much of BFL’s value depends on qualities that are easy to overlook precisely because they are not built infrastructure: the continuity of the land and the long-term records that continuity makes possible. BFL hosts the longest-running urban ant community surveys in the world (45 years), a weekly phorid fly survey now in its 20th year, more than 4,000 individually tagged trees, the international DroughtNet experiment, and documentation of landscape change since the 1890s. As Paul Ehrlich and Peter Raven wrote in 2009, relocating BFL would destroy “the grand experiment that is BFL” because data collected over decades cannot be reproduced. Development of the land and its buffers would not simply shrink the acreage available for study; it would erase the unaffected setting and the continuity on which this body of research depends. As we understand the proposal, the amended agreement would define the parameters for future private development in the Brackenridge Tract, including land on which BFL sits. Saving Muny preserves one precious greenspace; it should not come at the cost of another. Protecting Muny’s fairways and BFL’s habitats are complementary goals, and the City has the opportunity to secure both. In short, allowing development on BFL would permanently degrade its unique habitats, forfeit Austin’s only formal urban ecology research site, and end a public science and education resource that thousands of Austinites rely on. OBFS encourages the City of Austin to: (1) Understand the scale of what will be lost, not just now, but for generations, if BFL’s land, natural areas, or buffers are opened to development. (2) Ensure that any amended Brackenridge Development Agreement expressly excludes BFL’s existing footprint, natural areas, ecological buffers, and supporting infrastructure from development, and designates them for continued research, education, and conservation, with enforceable protections. (3) Engage the BFL scientists, UT faculty and students, and the community members, schools, and volunteer groups who use BFL before Council acts, and, if more time is 15 Proposed amendments to the Interlocal Agreemnt between the City and the University of Texas related to the Brackenridge Tract.2 of 18 needed to do so, separate the provisions affecting BFL from the Muny conveyance so that the two can be resolved on their own merits. Field stations like BFL take decades to build and cannot be relocated or recreated once their ecological integrity is broken. OBFS would welcome the opportunity to speak further with the City about the role BFL plays in Austin and in the broader field station community, and to support a process that preserves the Brackenridge Field Laboratory for the benefit of all Austinites. Thank you for your consideration. Sincerely, Conner Philson, PhD President, Organization of Biological Field Stations 15 Proposed amendments to the Interlocal Agreemnt between the City and the University of Texas related to the Brackenridge Tract.3 of 18 Statement for the Meeting of the Austin City Council Planning Commission, November 10, 2026 Chase Rakowski, Ph.D. I received my Ph.D. from UT Austin in Ecology, Evolution and Behavior in 2023, and I am now a Research Scientist at the University of Colorado. My development into a scientist and educator, including the research, training, mentoring, and teaching I performed as a graduate student, was possible in large part due to the Brackenridge Field Laboratory (BFL). BFL is a world-class research, education, student training, and public outreach facility. It is crucial that BFL be preserved in its present state because its status as a critical asset for UT, the Austin community, and the world is dependent on its location. As a graduate student I was able to perform intensive field research, despite having to take and teach classes on UT’s main campus, thanks to BFL’s location a short drive from campus. Similarly, I was able to mentor undergraduates as they participated in field research, and serve as a teaching assistant for field courses, because BFL’s proximity to campus allows undergraduates to commute to and from the lab in between other classes. Not only is it invaluable to have a field laboratory near UT’s main campus, but BFL’s specific location now carries a priceless legacy of long-term datasets which provide a rare resource for environmental research. Decades of research by UT professors, as well as decades of data collection by undergraduate students in UT’s Field Ecology Laboratory course, have produced historical ecological records that provide baselines for studying the effects of global change. Losing the ability to continue tracking the ecosystems of BFL as environmental change progresses would represent a tragic loss of scientific potential. BFL is also a hub for community outreach. For example, the monthly Science Under the Stars series invites families from the community to tour the laboratory grounds and learn from graduate students about a diverse array of scientific topics. The great success and popularity of this program hinges on BFL’s proximity to so many of Austin’s communities. Lastly, the entirety of BFL lies within a flood zone. The land is characterized by a thick layer of sediment deposited in a previous flood. Climate change is drastically increasing flood risks in Texas as recent tragedies from Camp Mystic to Hurricane Harvey have shown, so it is more important than ever to preserve floodplains with minimal impervious cover. BFL is an invaluable asset to the Austin community and to the world through the research, training, education, outreach, and flood protection it provides. However, the ability of BFL to provide all these benefits is inherently contingent on its current location. Therefore, it is critical that the Brackenridge Field Laboratory be preserved as-is in perpetuity. 15 Proposed amendments to the Interlocal Agreemnt between the City and the University of Texas related to the Brackenridge Tract.4 of 1815 Proposed amendments to the Interlocal Agreemnt between the City and the University of Texas related to the Brackenridge Tract.5 of 1815 Proposed amendments to the Interlocal Agreemnt between the City and the University of Texas related to the Brackenridge Tract.6 of 181Dear Planning Commission, I would like to make a case for why Brackenridge Field Laboratory (BFL) needs to be preserved in its entirety instead of being moved to a new location or making the decision to only keep a portion of the property intact and safe from development. The views and opinions expressed here are my own, and I do not represent UT or BFL. I am submitting this recommendation in my personal capacity as a scientist and ecologist who is familiar with BFL. BFL is a diverse and integrated research landscape whose scientific, ecological, and educational value depends on its size, continuity, diversity, and long-term integrity. Preserving only a portion of BFL does not preserve its true value. Its value would be lost disproportionately as the property is reduced. Scientific research and long-term data 1. Biodiversity is distributed throughout the property. Different areas support distinct habitats, species, ecological communities, and environmental conditions. No single portion represents the full biological diversity of BFL. 2. Long-term baseline studies depend on the entire property. Foundational studies of ants, trees, plants, and other organisms are distributed across BFL and studies must be continued on a site-specific basis. Losing substantial portions would undermine existing datasets and decades of accumulated scientific knowledge. 3. Thousands of student research projects have used the property. Student studies span the entire landscape, creating a substantial body of historical research that cannot simply be relocated or replicated elsewhere. 4. Experimental replication requires sufficient space. Independent replicates must be sufficiently separated to minimize spatial autocorrelation and avoid confounding effects. Reducing available land limits the scope, impact, and scientific rigor of future experimental studies. 5. Landscape-scale ecological processes require a substantial footprint. Processes such as oak wilt progression, invasive species dispersal, succession, population dynamics, and wildlife movement cannot be adequately studied within small, fragmented areas. 1 15 Proposed amendments to the Interlocal Agreemnt between the City and the University of Texas related to the Brackenridge Tract.7 of 18 6. Environmental gradients provide essential research opportunities. Differences in topography, soils, moisture, vegetation, and disturbance history allow researchers to investigate ecological responses across natural environmental variation. 7. Undisturbed reference areas are essential. Researchers need intact areas for controls and comparisons when studying development, disturbance, invasive species, climate change, and restoration. There are no other spaces within Austin that could be used for these comparative research purposes. 8. Future research opportunities depend on available space. Field stations must accommodate new experiments, long-term plots, controls, manipulations, and emerging research questions. Land developed today is permanently unavailable for future studies. Ecological integrity and conservation 9. Development creates disproportionate edge effects. Even relatively small development footprints can alter surrounding habitat through changes in light, temperature, noise, invasive species, human activity, and wildlife behavior. 10. Fragmentation compromises habitat connectivity. BFL functions as part of a larger network of greenspaces along the Colorado River. Retaining isolated remnants is not equivalent to maintaining continuous habitat. 11. Ecological processes extend beyond field station boundaries and development footprints. Changes in noise, lighting, drainage, runoff, sedimentation, vegetation, and can affect ecological processes such as wildlife movement over much larger areas than those directly developed. 12. BFL provides an increasingly important urban wildlife refuge. As surrounding areas become more developed, the value of maintaining a large, continuous area of relatively undisturbed habitat increases. 13. Large, intact landscapes provide climate resilience. Environmental variation and microclimates provide refugia for organisms responding to extreme temperatures, drought, and other environmental changes. 15 Proposed amendments to the Interlocal Agreemnt between the City and the University of Texas related to the Brackenridge Tract.8 of 18 14. Type localities make BFL scientifically irreplaceable. More than ten species have type localities at BFL, with different species occurring in different portions of the property. These locations have lasting scientific and historical significance. 15. Cumulative impacts can fundamentally alter ecological integrity. Light pollution, noise, altered drainage, invasive species, and increased human activity interact over time, potentially compromising habitat well beyond the immediate development footprint. Education and institutional value 16. BFL is an irreplaceable outdoor classroom. Students need access to a functioning, diverse ecosystem where they can conduct independent investigations, collect data, and observe ecological processes firsthand. 17. BFL’s location a short ride from campus allows students to incorporate field-based studies and research experiences into their class schedules. These opportunities open career avenues for students, particularly those who must work and cannot otherwise acquire these skills outside their school schedules. 18. BFL's urban location is itself a unique research resource. Its proximity to UT Austin allows convenient field-based teaching and research while providing opportunities to investigate urbanization, fragmentation, invasive species, and ecological change. 19. Multiple classes and research programs require simultaneous access. BFL supports independent courses, student projects, faculty research, and visiting researchers. Its current capacity is already challenging to manage, and reducing the available footprint would intensify competition for space. 20. BFL supports education and research training across numerous disciplines. Its value extends beyond ecology to evolution, botany, entomology, mycology, zoology, geology, hydrology, and environmental science. Different disciplines require different habitats, locations, and levels of disturbance. 21. The property represents decades of institutional investment. Research infrastructure, established plots, collections, historical datasets, institutional knowledge, and relationships with researchers and students have accumulated over nearly 60 years. Long-term planning and preservation 15 Proposed amendments to the Interlocal Agreemnt between the City and the University of Texas related to the Brackenridge Tract.9 of 18 22. The entire property is greater than the sum of its individual parts. Its scientific and ecological value depends on the interaction of habitats, species, environmental gradients, and research areas across the landscape. 23. There is no scientifically defensible basis for identifying expendable portions. Areas that appear less diverse or are not currently used for research may provide essential habitat, connectivity, controls, or opportunities for future studies. 24. Relocation cannot replace what would be lost. Another greenspace or field station cannot reproduce BFL's particular combination of student accessibility, ecological communities, environmental conditions, historical datasets, and established research infrastructure. 25. Future institutional expansion should not come at the expense of habitat. Previous plans have increased the building footprint through consolidation of Collections and Outreach and expansion of Research and Teaching. Further building expansion will reduce habitat and compromise the resource that makes BFL valuable in the first place. Habitat is the currency of the field station. Buildings and infrastructure exist to support the use and study of the land, not to replace it. Established habitats, ecological communities, research sites, and the opportunities they provide cannot be recreated once developed. The long-term success and expansion of BFL’s research, teaching, and outreach mission depend on preserving the entire property. Thank you for your time and consideration. Elizabeth Bowman, PhD 15 Proposed amendments to the Interlocal Agreemnt between the City and the University of Texas related to the Brackenridge Tract.10 of 18 15 Proposed amendments to the Interlocal Agreemnt between the City and the University of Texas related to the Brackenridge Tract.11 of 1815 Proposed amendments to the Interlocal Agreemnt between the City and the University of Texas related to the Brackenridge Tract.12 of 18Good afternoon, I'd like to speak out regarding the proposed plans for the Brackenridge Field Lab. We live in a time when it too often feels like we are losing things we can't ever fully get back. Preserving this land is important. Protecting diversity, speaking for those who cannot speak for themselves, and fostering an environment for curiosity are integral to what makes Austin and UT great. What we can gain from preserving this place is priceless and what could be lost is devastating. I attended talks here during my time at UT. While I can't remember every fact I learned, I will never forget how it made me feel. It brought a spark to my love for nature and reminded me how vast and wonderful our world is. I felt inspired to do my part and to feel the embrace of nature, not just in looking at it but also in learning about it and protecting it. I can only imagine the wealth of knowledge and joy that others have gained from the BFL. Preserving this piece of land does not just benefit the students who will get to learn there, but also the community as a whole and all the lives they will touch as they bring their passion and knowledge into the world. I feel lucky to have been a part of it in any small way. Thank you, Julia Daniel 15 Proposed amendments to the Interlocal Agreemnt between the City and the University of Texas related to the Brackenridge Tract.13 of 18 15 Proposed amendments to the Interlocal Agreemnt between the City and the University of Texas related to the Brackenridge Tract.14 of 1815 Proposed amendments to the Interlocal Agreemnt between the City and the University of Texas related to the Brackenridge Tract.15 of 1815 Proposed amendments to the Interlocal Agreemnt between the City and the University of Texas related to the Brackenridge Tract.16 of 1815 Proposed amendments to the Interlocal Agreemnt between the City and the University of Texas related to the Brackenridge Tract.18 of 18Jen Schlauch Written Statement for the Austin Planning Commissioner Meeting November 10, 2026 My name is Jen Schlauch, all opinions are my own. I am an ecologist who received my undergraduate degree from UT in 2019. Among thousands of alumni with personal stories, I speak today on the critical importance of BFL for UT’s science and education mission, and to its individual importance to researchers. Over the last week, we have gathered over 2,000 signatures on our petition in support of the preservation of BFL. My arguments tonight are twofold: First, BFL’s land is worth more to the University as a platform of scientific discovery, hands-on instruction, and positive community engagement than it would be as a developed property. Second, BFL’s location is critical for biodiversity and researcher accessibility. The field station cannot simply be relocated. In 2018 I discovered a rare new species of ant in BFL’s trails, one of two new-to-science ant species found here and nowhere else on the planet. As an ecologist currently working in restored sites, I can tell you that paving over this property would cause damage irreversible in our lifetimes. BFL serves as a critical biodiversity island in urban Austin for many of the butterflies, birds, and other wildlife that make the city a special place to live. Exploring BFL’s grounds as a young researcher introduced me to a life in ecology more beautiful than I could have imagined. BFL is a source of wonder and curiosity for UT students and the broader public alike. The individually studied trees, rocks, and populations, the decades of scientific knowledge based here, are critical to the mission of impact that the College of Natural Sciences claims. If BFL is so valuable to the mission of research, education, and public outreach, why are we rushing a deal that would open it up for destruction? I am arguing for the preservation of BFL in perpetuity, for education and biodiversity. At the least, I am asking the City to pause, and give this huge decision the time it deserves, and follow the amendments made on October 21 by the Environmental Commission. The university needs to consider the uniquely valuable asset it has with Brackenridge Field Lab. By working together on a reasonable timeline, we can come to a solution that will be better for both UT and the City of Austin. FORMAL PUBLIC COMMENT / AGENDA ITEM 15 Preserve Brackenridge Field Laboratory November 10, 2026 To: Chair Alice Woods and Members of the Austin Planning Commission Re: Proposed amendments to the Brackenridge Development Agreement Dear Chair Woods and Commissioners: I am a UT Austin alumnus and Austin resident writing to urge the Commission to recommend permanent, enforceable protection of the entire 82-acre Brackenridge Field Laboratory (BFL) as part of any amended Brackenridge Development Agreement. The City can secure the future of Lions Municipal Golf Course without placing another irreplaceable public resource at risk. BFL is an exceptionally rare urban ecological field station only three miles from the UT campus. Since 1967, its prairies, woodlands, river habitats, laboratories, and decades-long studies have enabled hands-on field courses, undergraduate and graduate research, and discoveries about biodiversity and ecological change. Students can work in functioning ecosystems without the travel barriers associated with remote field stations. Once continuous research sites and established habitats are destroyed, they cannot simply be recreated elsewhere. The 1989 agreement expressly restricted non-university development of BFL, and the UT System Board of Regents unanimously voted in 2009 to retain the laboratory. Yet the proposed framework for roughly 190 acres of UT land does not clearly carry permanent BFL protection forward. The Commission should resolve that uncertainty before key development terms are approved, not leave the question solely to a later regulating plan. I ask the Planning Commission to recommend that City Council: 1. Protect all of BFL permanently. Identify its full boundaries on binding maps; prohibit non-university development; and pursue a conservation easement or equivalent protection compatible with continued UT research and teaching. 2. Exclude BFL from transferable development rights. Do not count the protected acreage toward floor-area or impervious-cover allowances that would facilitate construction elsewhere. 3. Require environmental review and buffers. Assess baseline habitats, trees, waterways, drainage, and impacts from neighboring construction before establishing final development parameters. 4. Make protections explicit before approval. Require written, legally enforceable commitments in the amended agreement and meaningful consultation with BFL researchers, students, and conservation experts. A fifty-year retention provision would be helpful, but it is not permanent preservation. Please make protection of Brackenridge Field Laboratory a clear condition of the Commission’s recommendation to Council. Thank you for considering this request. Sincerely, Stuart Robertson UT Austin alumnus | Austin resident References: UT Field Station Network (research site); UT System Regents, Dec. 22, 2009 (retention decision); City of Austin Planning Commission agenda, Nov. 10, 2026; UT Brackenridge Tract Task Force report, 2007 (1989 agreement history). Public comment • Austin Planning Commission • November 10, 2026 Agenda Item 15 FORMAL PUBLIC COMMENT | AGENDA ITEM 15 Preserve Brackenridge Field Laboratory Austin Planning Commission (cid:127) November 10, 2026 To: Chair Alice Woods and Members of the Austin Planning Commission Re: Agenda Item 15 — Opposition to rezoning Brackenridge Field Laboratory for sale and development Dear Chair Woods and Commissioners, I am writing as the founder of Central Texas Plant Rescuers, a volunteer native plant conservation program that uses a greenhouse at Brackenridge Field Laboratory (BFL). I strongly oppose rezoning BFL for sale and development and urge the Commission to recommend its permanent protection. BFL is a rare urban ecological field station, located just three miles from the UT Austin campus. Since 1967, it has provided an exceptional setting for student education, university research, and the study of biodiversity in functioning natural habitats. This resource cannot simply be recreated if it is developed. BFL is also essential to our community conservation work. We are currently nurturing four species of greatest conservation need (SGCN) in its greenhouse before donating them to preserves and pollinator gardens. We also plan to propagate Texas orchids listed as SGCNs. This year, Central Texas Plant Rescuers donated over $5,000 worth of native pollinator plants to the Austin chapter of the Native Plant Society of Texas, making dozens of pollinator host plants and endemic species available to the community and its pollinators. Losing BFL and its greenhouse would seriously diminish our ability to care for and distribute these important plants and to conduct research on locally vulnerable species of conservation need. It would also mean losing a unique resource for UT students, researchers, and the broader Austin community. 1 2 3 4 I ask the Planning Commission to: Oppose rezoning BFL for sale and development. Recommend permanent, legally enforceable protection of the entire 82-acre laboratory. Ensure BFL is excluded from transferable development rights and development allowances. Protect continued access to its research, teaching, and greenhouse facilities. The 1989 agreement restricted non-university development of BFL, and the UT System Board of Regents voted unanimously in 2009 to retain the laboratory. These commitments should be carried forward in clear, binding protections. Preserving Lions Municipal Golf Course should not require sacrificing Brackenridge Field Laboratory. Both are valuable community resources, and BFL’s scientific, educational, and conservation functions deserve lasting protection. Thank you for considering my comments and for recommending against rezoning BFL for sale and development. Sincerely, Ali Baucom Founder, Central Texas Plant Rescuers Public Comment (cid:127) Austin Planning Commission (cid:127) November 10, 2026 Agenda Item 15