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Atlantic Steel

Atlantic Steel: Letter from Environmental Defense Fund regarding Atlantic Steel XL Project

Subject: EDF Comments on Atlanta Atlantic Steel Project XL

1875 Connecticut Ave NW
Washington, DC 20009

February 1, 1999

Mr. James Kutzman
Deputy Director, Clean Air Division
US Environmental Protection Agency, Region 9
Atlanta, GA

Mr. Michael Dobbins
Planning Commissioner, City of Atlanta
Department of Planning, Development, and Neighborhood Conservation
Atlanta, GA

RE: 17th Street Bridge / Interchange

Dear Mr. Kutzman and Mr. Dobbins:

We are writing to express the concerns of the Environmental Defense Fund (EDF) about the proposed 17th Street Interchange for the proposed brownfields redevelopment project on the mid-town Atlanta site of Atlantic Steel. It appears the preferred alternative advanced in late December 1998 by Georgia Department of Transportation would not provide for the
implementation of all reasonably available control measures to assure the timely attainment of air quality in the region. We hope you will insist on a more transit and pedestrian friendly bridge and interchange design and a better specification of transit and travel demand management incentive strategies that can assure enforceability of performance criteria that must be a part of this project if it is to be approved as part of a Transportation Control Measure under the Clean Air Act.

EDF, a leading, national, NY-based nonprofit organization, represents 300,000 members, including many thousands in Georgia, and links science, economics, and law to create innovative, economically viable solutions to today's environmental problems.

Because the Atlanta region has not since 1994 been able to demonstrate the conformity of its regional transportation plan (RTP) and transportation improvement program (TIP) with the emission budget set by the State Implementation Plan (SIP) that Georgia has adopted for the region, it is generally not now possible to add new road projects like the proposed 17th Street Bridge / Interchange to the region's RTP and TIP. However, it may be possible to advance this project during the current conformity lapse if it is bundled as part of a Transportation Control Measure (TCM) and incorporated as a real, permanent, and enforceable element of the SIP.

EPA has been working with the City of Atlanta, Atlanta Regional Commission (ARC), Georgia Department of Transportation (GDOT), and others to explore such regulatory flexibility under its Project XL. EDF has been following this process with interest. We support EPA's goal of promoting infill, brownfields redevelopment and exploring how this can lead to a reduction in total vehicle miles of travel in a metropolitan area, yielding related benefits for the environment.

We want to be assured that, as a TCM, the package that includes the 17th Street Bridge / Interchange will demonstrate a contribution to better air quality, rely on rigorous evaluation and follow-up measures, be a real, permanent, and legally enforceable part of the SIP, and be subject to EPA approval, with opportunities for meaningful and substantive public involvement. Once the bridge, interchange, and related real estate development is built, it will not be possible to shut these down if they fail to meet their planned performance objectives.

Thus, great care must be exercised in developing the project agreements, detailing realistic, but ambitious and enforceable quantitative criteria for transportation and environmental performance. These should include vehicle miles of travel, vehicle trip starts and trip ends, and mode share targets, as well as specific emission reduction objectives. These should be grounded in detailed analytic studies, with explication of supportive management and service strategies, and should be backed up by institutional and financial structures strong enough to guarantee compliance over time, with backstop arrangements. 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.

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 project agreement, and the package that is submitted to become a part of the TIP, RTP, and SIP must clearly define these elements. We hope you will work to make it a model package, worthy of awards and worth replicating nationally. Given the serious air quality and transportation planning failures in the Atlanta metropolitan area, these elements must include every reasonable effort to contribute to the timely attainment of air quality and to reduce traffic and emissions related to the proposed project and development, including innovative strategies that have not heretofore been pursued in metropolitan Atlanta but which are reasonably available emission control strategies.

To meet these objectives, 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.

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. 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. 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. 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

on 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.

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.

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 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.

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 shou
ld be applied in site development and planning, and incorporated into the project agreements, with ambitious targets for bicycle and pedestrian travel in the area.

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 city into the city on both sides of the Interstate. This preferred alternative should be rejected as inappropriate for designation as a TCM.

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 / Art Center MARTA station and the Atlantic Steel site. A better alternative would be 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.

We are also concerned that the traffic analysis of the Interchange / Bridge prepared for GDOT 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.

It has come to our attention that there may be stormwater 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 stormwater management, which is a costly problem for the City of Atlanta.

We would very much like to see the Atlantic Steel project XL process succeed as a national model for how Clean Air Act conformity and brownfield problems can be turned into opportunities for urban revitalization, livable communities, improved access of low income communities to jobs, and economic growth with environmental progress. To get there, we hope you will address the concerns we here raise.

We would be pleased to discuss these issues further with you and your staff at your convenience.


Michael Replogle
Federal Transportation Director, EDF

cc: Harry West, Atlanta Regional Commission
Harold Reheis, Georgia DNR
Brian Leary, CRB Realty Associates
Geoffrey Anderson, EPA UEDD
Laura Voss, EPA OMS
Tim Torma, EPA Office of Reinvention
Stanley Meiburg, EPA Region 4
Keith Laughlin, CEQ
Rep. John Lewis, US Congress

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