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Atlantic Steel

Atlantic Steel: Letter from Mr. S Meiburg, Region 4, to Mr. Replogle of the Environmental Defense Fund, March 25, 1999


March 25, 1999

Mr. Michael Replogle
Federal Transportation Director
Environmental Defense Fund
Capitol Office
1875 Connecticut Ave., NW
Washington, DC 20009

RE: Comments on the Atlantic Steel XL Project

Dear Mr. Replogle:

Thank you for your February 1, 1999 letter indicating both your support for and concerns with the proposed Atlantic Steel redevelopment project. I particularly appreciate the detailed suggestions you have provided as well as the time and thought which have gone into your review of this proposal. Many similar issues and concerns to those you raised have been identified by the project team assembled within EPA to work on this project. In this letter I am taking the opportunity to respond to your comments by first stating your concern/suggestion, then providing EPA's response or an update on our actions related to the particular comment. I should also note that EPA is working with all other government agencies ultimately involved in approving a TCM into the SIP. Many of the processes involved are within the purview of these other agencies. EPA is assisting them and encouraging inclusion of the elements necessary to make this the best project possible.

1. COMMENT: "We suggest the project agreement and TCM package might be backed with a private performance bond that insures resources will be available to implement transit and TMA management measures as needed to meet the adopted performance criteria in the event of a financial default by the developer or failure of the TMA or transit service agreements to comply with the agreements."

RESPONSE: EPA has developed a workgroup to work specifically on TMA development and implementation. The role of the workgroup is to both facilitate the development of the TMA and to assure that important parts of the overall project implementation are addressed. Alan Powell, an EPA regional expert on the formation and operation of TMAs, is the leader of this workgroup. He is working with the Midtown Alliance (a non-profit coalition of businesses and civic groups in midtown Atlanta), the Atlanta Regional Commission, the project sponsor, the City of Atlanta and interested stakeholders to develop a clear, inclusive approach to forming the TMA. EPA shares EDF's interest in assuring that the TMA will have the tools necessary to achieve the desired emissions and VMT outcomes. The issue of funding the TMA is one that will be addressed by both the EPA TMA workgroup and the broader group of parties with interests in this issue. Your participation in future discussions regarding the TMA would be welcome.

2. COMMENT: "The location alone is not an adequate basis for deeming this or other land-use related projects as TCMs or awarding air quality credit to them. There are several factors that will have a profound impact on the travel behavior and air quality impacts related to the redevelopment and the related Bridge/Interchange TCM package. These include:

- the quality, quantity, location, and design of transit services and connections of the proposed redevelopment site to MARTA stations and to other regional trip generators and attractors.
- The degree of pedestrian and bicycle friendliness of urban and street design in and around the Atlantic Steel site
- the supply, location, and price of parking, and other travel prices and incentives offered to travelers to and from the site."

RESPONSE: EPA agrees that location alone is not an adequate basis for deeming this project a TCM. EPA is considering this project a TCM for a variety of reasons in addition to its location, including most of those which you mention. On February 24, 1999, we published a Federal Register Notice (enclosed) announcing availability of the draft Phase 1 Project Agreement. That Federal Register Notice includes a summary of the numerous factors which influenced EPA's decision to move forward with this project. EPA agrees that the factors you highlighted need to be considered to evaluate whether the Atlantic Steel project achieves Superior Environmental Performance and qualifies as a TCM.

EPA felt that any future emissions reductions from the Atlantic Steel redevelopment would likely result from the site's regionally central location and design compared to the location and design the growth would have taken absent development of the Atlantic Steel site. Therefore, EPA analyzed the likely environmental performance of the Atlantic Steel site at two levels. First, EPA evaluated the performance of the Atlantic Steel site relative to three other likely regional growth locations. As part of this evaluation, carbon monoxide (CO) emissions associated with the Atlantic Steel site were evaluated for potential "hot spots." Second, EPA investigated the performance of the site design proposed by Jacoby relative to likely design of the greenfields and one other potential design for the Atlantic Steel site. The study results are summarized in the Phase 1 Project Agreement, currently available on the Project XL web site (www.epa.gov/projectxl).

We have requested that the project sponsor state his plans for shuttle operation in writing. He has done so and a copy of his letter is enclosed. This shuttle would provide service between the Arts Center MARTA station and the Atlantic Steel site.

The project sponsor has been working with Bill Wilkinson of the Bicycle Federation of America and the Atlanta Bicycle Campaign to further refine the site design and maximize "bicycle friendliness." Bike paths included in the project design will address a large missing link in Atlanta's overall bicycle pathway system. EPA will further evaluate the pedestrian friendliness of the final site design when it is received.

EPA understands that the supply of parking which was originally proposed has been reduced based on comments provided to the project sponsor. The question of supply and location will be revisited upon receipt of the final design. The price of parking and other travel prices and incentives are all items we feel should be addressed by the TMA.

3. COMMENT: "... the project should include guaranteed funding mechanisms (such as a development district tax) for a Transportation Management Association (TMA) for the project and surrounding district. The TMA should be a public-private partnership with the power to influence key elements that shape travel behavior and emissions related to the Atlantic Steel site."

RESPONSE: As mentioned in #1 above, EPA is providing assistance to the project sponsor and the Midtown Alliance to form the TMA. Many ideas are under consideration as to how to form and fund the TMA. Your continued assistance and advice will be helpful as details are discussed.

4. COMMENT: "We are concerned that while the Bridge and Interchange have undergone significant preliminary engineering, there is still little specificity about the transit service connections to be provided to the Atlantic Steel site. Without a specific plan and financing arrangement, this missing key element seems enough to deem the project inadequately defined to make up an approvable TCM. And under current circumstances, unless the project is defined well enough to be an approvable TCM, we do not see how it can legally be approved as a part of the TIP, RTP, or SIP."

RESPONSE: EPA is aware of a number of "Preliminary Concept Reports" prepared by consultants for the sponsor analyzing potential configurations of the bridge and associated interchanges. Meetings to discuss the alternatives are still underway. No final concept or design has been approved. EPA agrees that specific information about the transit service connections and funding are necessary for this project to proceed as a TCM. The project sponsor has made an enforceable commitment in the Phase 1 Project Agreement to operation of a linkage from the Atlantic Steel site to mass transit at the Arts Center MARTA station. This commitment will be contained in the TCM in addition to the Project XL Agreements. As noted above, the enclosed letter from the project sponsor contains details regarding the frequency and nature of the transit service. The project sponsor will be submitting a diagram containing locations of transit stops in the near future. This diagram will be made available on the Project XL web site.
5. COMMENT: "We would hope to see a very high frequency transit connection between the Atlantic Steel site and MARTA, with service throughout the day and into the night that allows travelers to travel most of the time without worrying about scheduled connections."

RESPONSE: As noted above, please see the enclosed letter from the developer regarding transit frequency. MARTA has also committed to allow an interface between the private shuttle and the Arts Center Station. We anticipate that the connection may ultimately change to ensure consistency with the proposed west loop project. Results of a study on the west loop are expected in the Summer of 1999 and would likely impact the final design of the bridge.

6. COMMENT: "While light rail may be attractive, given the need for rapid deployment of a high quality transit link, flexible phasing of service, and currently limited financing, this context might be appropriate for application of a bus rapid transit system strategy, like that in Curitiba, Brazil, with high level boarding separate from fare collection, with designated stations, and potential to serve multiple trip origins."

RESPONSE: This is an interesting idea. EPA is not specifying the type of vehicle which should be used to link the site to the MARTA station. At the same time, we want to ensure that future transit options are not precluded. Therefore, we are working towards an agreement with Georgia DOT to ensure the bridge is designed and built to accommodate the widest possible variety of options.

The project sponsor has stated that the service is likely to be some type of rubber-tired vehicle. We will share your suggestion with the project sponsor, and believe they would welcome any additional information you have as they consider the most appropriate type of transit connection to provide.

7. COMMENT: "Employee Commuter Choice incentives and parking management should be a key instrument of the project agreement and TCM package, with administration by the TMA to assure timely traffic mitigation and emission benefits. Employers on the development site should, as a condition of lease or property covenant, take advantage of the new TEA-21 Commuter Choice tax incentives and offer these to all who are employed in the area. Specifically, employees should have the opportunity to purchase employer-discounted transit passes and vanpool benefits using pre-tax dollars. All employers might be also required to offer at least a 50% discount on transit passes to employees. In the event that travel behavior and emission targets for the development area are not met, the TMA should have the power to adjust the level of mandatory employer transit pass discounts, through leasing and property covenant agreements."

RESPONSE: The XL agreement is not designed to incorporate this degree of detail on the actual operation of the redevelopment. However, outside of the XL process, EPA is involved in promoting the Commuter Choice initiative. Commuter Connections, Inc., is being funded by Georgia DOT to start work on the Commuter Choice program for Atlanta. Michael Dziak, point of contact for the program, has pulled together a coalition that includes ARC, the City of Atlanta, Georgia DOT, the Federal DOT regional office, and others. Michael will be working directly with major employers, including prospective employers at the Atlantic Steel site. For more information, please contact Deanne Upson at the EPA Office of Mobile Sources, at (734) 214-4329.

EPA will forward your suggestion to offer commuter choice to the project sponsor for consideration in the development of the project. In addition, we anticipate that ideas such as those you have expressed regarding transit passes for employees will be considered in plans for the TMA.

8. COMMENT: "All employers should be required to offer employees cash in lieu of a parking space if parking is provided to employees as a benefit, taking advantage of the new tax law. This might be the single most powerful means of influencing travel choice to the site, based on research by Donald Shoup and others. All property leases on the Atlantic Steel site should be required to be structured to provide parking as a lease item separate from office, retail, or residential unit rental, so that these costs are fully identified and separable and employers perceive an economic benefit in reducing employee parking space consumption. Management systems to influence parking supply, location, and price should be incorporated as part of the project plan, seeking to reduce parking supply to the minimum possible through appropriate incentives, multiple use parking management, and other transportation management measures. The TMA should be empowered from the outset to impose parking excise levies, by time-of-day, by facility, and by parking type, as needed to assure compliance with TCM travel performance goals over time, with revenues devoted to improving transit and alternative travel services for the area."

RESPONSE: Please see our response above regarding the Commuter Choice initiative. These comments are all helpful and instructive for the TMA workgroup. They will be considered and discussed for incorporation into the TMA outline.

9. COMMENT: "Innovative residential traffic management services should be incorporated into the project design at the outset and taken into account, like other measures, in the TCM and project agreements. These would include bundling free or highly discounted annual regional transit passes with each residential unit (to be purchased through a wholesale agreement with MARTA) and included in leases and property covenants, and provisions and support for neighborhood car rental, car sharing systems, and real-time ridesharing services available to residents and visitors. A guarded bicycle parking garage should be developed at the Art Center MARTA station with rental bicycles available to facilitate non-motorized access around the neighborhood for residents, workers, and visitors. Adequate secure short and long term bicycle parking and showers/changing rooms should be required for all major buildings on the Atlantic Steel site. The best traffic calming and pedestrian and bicycle friendly street space management strategies should be applied in site development and planning, and incorporated into the project agreements, with ambitious targets for bicycle and pedestrian travel in the area."
RESPONSE: EPA concurs. As part of the XL process, EPA hired the architecture and town planning firm Duany Plater-Zyberk & Company (DPZ) to evaluate the proposed site design and make recommendations which might improve it from an environmental performance standpoint with a particular emphasis on increasing pedestrian and bicycle friendliness. DPZ's recommendations for the site included traffic calming elements such as reduced street width, and on-street parking. They recommended increased connectivity of streets to improve walkablity. DPZ also identified how pedestrian trips could be increased through more direct routes and improved safety. EPA understands that many of the recommendations made by DPZ will be reflected in a revised site design to be submitted in March by the project sponsor.

We will take your suggestions into account as we continue discussions with the project sponsor on the final site design. The City of Atlanta's zoning requirements also emphasize pedestrian and bicycle facilities as well as traffic calming measures. They will also be considered in the development of site design performance measures for the project. These site design performance measures will be included in the Final Project Agreement.

We also agree that bicycle parking and changing rooms should be provided at the major buildings on the site and will forward this suggestion to the project sponsor.

10. COMMENT: "The choice of bridge design will have a major effect on the travel behavior in the area of Atlantic Steel and cannot be ignored in developing air quality project agreements. The 17th Street Interchange/Bridge Modification Concept Report, dated December 21, 1998, offers a preferred alternative that would extend the freeway into the city on both sides of the Interstate. This preferred alternative should be rejected as inappropriate for designation as a TCM."

RESPONSE: EPA agrees that the proposed bridge will impact traffic and air quality. The XL project is considering the redevelopment as a whole to be the TCM. As noted in response to an earlier question, our analyses have demonstrated that the site's design and location (centrally located as opposed to the three alternative locations) demonstrate an air quality benefit. The site level modeling including the bridge ramps and the transit linkage is not expected to alter that conclusion.

To be a TCM, the project needs to demonstrate an air quality benefit. While EPA is staying involved in the discussions of the actual bridge design to assure that the transit, pedestrian and bicycle friendly components are fully incorporated, ultimately the City of Atlanta, Georgia DOT, and the FHWA will determine, through the appropriate regulatory and analytical processes, the appropriate design features of the bridge. Further discussion on the bridge design is contained in the answer to comment 11. At a minimum, the bridge will include adequate lanes to accommodate pedestrian and bicycle traffic, as well as transit.

11. COMMENT: The facility should be redesigned to extend the city's arterial street grid over the freeway, using the bridge as a buffer to the freeway that now slashes the city in half. A lower level facility that would allow 17th Street to intersect with Spring Street east of I-75 and that would connect to the street grid as close as possible to the west side of I-75, without the added collector-distributor connections between 14th Street and the freeways north of 17th Street, would be less oriented towards high speed motor vehicle movement but would enhance pedestrian connectivity. The preferred alternative with a high signature bridge, would create a dehumanized environment oriented mostly to cars. With that design few would choose to walk between the West Peachtree Street/Arts Center MARTA station and the Atlantic Steel site. A better alternative would be a more horizontal engineering structure, like that in Seattle's Freeway Park, reconnecting the east and west side neighborhoods with a decked structure over the freeway for a good portion of the distance between 14th and 17th Streets. This could include landscaping, space for market stalls or kiosks, sculptural elements, and elements that would humanize and energize this as a safe and inviting pedestrian environment, with insulation from freeway noise and pollution."

RESPONSE: EPA believes that the actual design of the bridge must meet Georgia DOT and FHWA requirements. Through the XL project agreements and the TCM, required components of the bridge will include right-of-way for and capacity to accommodate transit, pedestrian walkways, and bicycle lanes. While these components will be required, EPA does not intend to prescribe a specific design for the bridge as part of the project. We anticipate the design of the bridge will be the subject of extensive discussion by stakeholders, including but not limited to the project sponsor, community groups, the City of Atlanta, Georgia DOT, FHWA, and FTA. Your suggestions echo some that we have heard from other stakeholders in the process. We will forward your letter to the appropriate governmental bodies and encourage you to reiterate those comments directly to the decision-makers at those governmental bodies for consideration in their review, comment and approval process. We will continue to pursue design options and features that further our shared interest in pedestrian, bicycle and transit-friendly features in the overall redevelopment, including the bridge.

12. COMMENT: "We are also concerned that the traffic analysis of the Interchange/Bridge prepared for Georgia DOT is based simply on ITE trip generation rates, reduced by a 10% internal capture and a 15% transit share. We are unsure what is the basis for these assumptions. The traffic analysis should not drive the bridge and interchange design, but alternative designs should be considered with appropriate sensitivity to stated assumptions about travel incentives, transit service levels, pedestrian friendliness, and other factors."

RESPONSE: EPA agrees. The assumption needs to be adequately explained in the next version of the report. We agree that assumptions are important for determining the air quality impacts of the project.

13. COMMENT: "It has come to our attention that there may be storm water management issues on the Atlantic Steel site that might be remediated as part of this project agreement. While we lack details on this aspect of the project, we hope that the design of the Interchange and Bridge might be seen as an opportunity to explore the possible flexing of available TEA-21 transportation funds for mitigation of past harms related to highway system development, including not just air quality and the cutting off of neighborhoods from each other, but also storm water management, which is a costly problem for the City of Atlanta."
RESPONSE: EPA will require that the infrastructure for the redevelopment incorporate separate collection systems for storm water and sanitary wastewater to allow for implementation of whatever is required by the City of Atlanta as a result of the Consent Decree for mitigating current problems with the combined sewer overflow system for storm water management. We will explore the possibility of using TEA-21 transportation funds in the manner you suggest.

Thank you again for taking the time to provide us with detailed comments and suggestions. We share your interest in promoting a model XL project (and process) for assisting communities in addressing air quality and transportation problems. This is an innovative project; we are interested in promoting as much involvement and understanding as possible and your insights are both helpful and useful. I look forward to working with you and your organization as we move toward a Project XL Final Project Agreement in May 1999. Additionally, I invite you to participate on the workgroup for developing a structure and guidelines for development and implementation of the Transportation Management Association. Please feel free to call Ms. Michelle Glenn, of my staff, at 404-562-8674 if you are interested in participating in the TMA workgroup or have additional questions.


//original signed//

A. Stanley Meiburg
Deputy Regional Administrator


cc: Michael Dobbins, City of Atlanta, DPDNC
Harry West, Atlanta Regional Commission
Harold Reheis, GA EPD
Charles Brown, CRB Realty Associates
Brian Leary, CRB Realty Associates
Keith Laughlin, CEQ
Honorable Rep. John Lewis, US Congress
Larry Dreihaup, FHWA
Susan Schruth, FTA
Frank Danchetz, Georgia DOT

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