FINDING OF NO SIGNIFICANT IMPACT
FOR
17™ STREET EXTENSION
[GDOT PROJECT NH-7141-00(900), P.I. NUMBER 714190]
AND
ATLANTIC STEEL REDEVELOPMENT PROJECT
FULTON COUNTY, GEORGIA
Lead Agency:
U.S. Environmental Protection Agency
Cooperating Federal Agencies:
U.S. Department of Transportation,
Federal Highway Administration
and
U.S. Department of Transportation,
Federal Transit Administration
An Environmental Assessment of the referenced project has been prepared by the
U.S. Environmental Protection Agency (EPA), in consultation with the U.S. Department
of Transportation, Federal Highway Administration (FHWA), and the U.S. Department
of Transportation, Federal Transit Administration (FTA), collectively referred to as the
"Federal Agencies". The document was made available for public inspection as
announced in public notices, and comments were invited from all interested parties.
Subsequent to the availability of the Environmental Assessment and the comment period,
an updated Environmental Assessment was prepared by EPA and has been furnished to
FHWA and FTA with the recommendation for a "Finding of No Significant Impact."
The Federal Agencies, after reviewing the revised Environmental Assessment, find
that the project will have no significant impact on the human or natural environment. No
significant impacts on air and water quality or on ambient noise levels are expected. The
project is consistent with local plans and will not divide or disrupt a community. The
project will have no effect on threatened and endangered species or any resources
regulated by Section 4(f) of the Department of Transportation Act of 1966.
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The Finding of No Significant Impact is based on the revised Environmental
Assessment, which has been evaluated by the Federal Agencies and determined to
adequately and accurately discuss the environmental issues and effects of the proposed
project. The Environmental Assessment was revised based upon comments from federal,
state, and local agencies, as well as private citizens and neighborhood groups. Most of
the changes to the Environmental Assessment document additional commitments that
have been developed in response to neighborhood concerns about traffic impacts. The
Environmental Assessment also provides sufficient evidence and analysis for determining
that an Environmental Impact Statement is not required. The Federal Agencies take full
responsibility for the accuracy, scope and content of the Environmental Assessment.
$-oo6
DATE
/tohn h. hankinson, jr'.
REGIONAL ADMINISTRATOR
ENVIRONMENTAL PROTECTION AGENCY
III 31100
DATE
LARRY R. DREIHAUP, P.E.
DIVISION ADMINISTRATOR
FEDERAL HIGHWAY ADMINISTRATION
(f-o-l-oo
DATE
JKLIN
^L ADMINISTRATOR
FEDERAL TRANSIT ADMINISTRATION
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FINDING OF NO SIGNIFICANT IMPACT
FOR
17th STREET EXTENSION
[GDOT PROJECT NH-7141-00(900), P.I. NUMBER 714190]
AND
ATLANTIC STEEL REDEVELOPMENT PROJECT
FULTON COUNTY, GEORGIA
SUMMARY OF ENVIRONMENTAL COMMITMENTS
The following is a summary of the environmental commitments of the public and
private entities involved with the 17th Street Extension and Atlantic Steel Redevelopment
Project.
Groundwater & Hazardous Materials
• The Georgia Department of Natural Resources (DNR) approved a remediation
plan for the Atlantic Steel site that requires a groundwater interception system to
collect and contain groundwater on-site. Jacoby Atlantic Redevelopment, L.L.C.
(JAR), or its successor, will monitor and treat intercepted groundwater, if required,
prior to discharge to the City of Atlanta sewer system. The remediation plan
requires that redevelopment and construction provide permanent engineered
barriers to exposure in the form of new structures, pavement, concrete and/or soil
cover.
• The City of Atlanta and Georgia DNR approved a conservation easement holding
JAR responsible for implementing the approved remediation plan. The easement
has been prepared in order to assure that the necessary engineering and
institutional controls are maintained in-perpetuity.
Water Quality & Wetlands
• The proposed project will comply with all federal, state, and local storm water
design standards. The proposed development will provide detention facilities to
reduce the peak runoff from the post-development condition to less than or equal
to the pre-development conditions. An additional stormwater detention capacity of
approximately 20% will be provided by JAR as part of its stormwater design to
assist the City in the management of flows to the Tanyard Creek Combined Sewer
Overflow Treatment Facility.
• Remediation of the Atlantic Steel site is expected to impact approximately 3.75
acres of wetlands. Mitigation for these impacts includes off-site stream restoration
by JAR, or its designee, in the City of Atlanta/Fulton County.
i
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Transportation Features
• Several communities in the project area expressed concerns about the cumulative
traffic increases resulting not only from this project, but from other new
development in the area that is already occurring, or that would occur in the future.
Through meetings with the Atlanta Neighborhood Planning Unit for this area,
along with individual meetings with the neighborhood civic associations, a number
of measures were developed to address these community concerns. The following
is a short summary of the measures.
~ Zoning Commitments: Specific zoning conditions for the Atlantic Steel
site were included to address the surrounding neighborhoods' concerns.
Condition 4 of the zoning for the site requires JAR to work with the City
of Atlanta, Home Park, and Loring Heights to limit cut-through traffic in
these neighborhoods. Condition 23 of the zoning for the site requires JAR
to develop a transportation management plan that will attempt to reduce
single occupancy vehicle trips to and from the site.
~ Transportation Control Measure (TCM1 Commitments: The Atlantic Steel
TCM requires monitoring by JAR of the site design and transportation
performance of the redevelopment project during build-out. The TCM
includes four site design criteria and four transportation performance
targets which collectively make certain that the site is built-out to
encourage alternatives to single occupancy vehicle trips and minimize
vehicle miles traveled.
~ Additional Neighborhood Commitments:
Home Park and Loring Heights - Atlantic Steel Brownfield Area and Tax
Allocation District Number Two (BATAD #2) promotes maximum use of
alternative transportation modes to minimize congestion and creates a
financing tool for transportation and other infrastructure to improve and
connect major activity centers. If cut-through traffic is determined to be
excessive in Home Park or Loring Heights attributed to the Atlantic Steel
redevelopment or surrounding areas, appropriate BATAD #2 funds would
be utilized to study and implement measures to limit cut-through traffic.
All monies and expenditures would be managed by the Atlanta
Development Authority and the City of Atlanta.
Ansley Park - In response to concerns from the Ansley Park Civic
Association (APCA) and many citizens of the neighborhood about
projected increases in traffic volumes, a specific agreement has been
entered into, by and between the APCA, Georgia Regional Transportation
Authority (GRTA), Georgia Department of Transportation (GDOT), the
City of Atlanta, and JAR. The purpose of this agreement is to establish a
mechanism for the continued study of traffic in Ansley Park as a result of
the Atlantic Steel Redevelopment project and other developments in the
Midtown Atlanta area. The agreement includes guaranteed financial
commitments for the implementation of traffic calming and control
measures that are identified as a result of separate studies, both internal
ii
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and external to the Ansley Park neighborhood. The agreement has been
duly executed and constitutes a valid and binding agreement, enforceable
in accordance with the laws of the State of Georgia and in any court of
competent jurisdiction.
Air Quality
• Redevelopment of the Atlantic Steel site will include a monitoring program,
consisting of site design criteria and transportation performance targets, to ensure
that the redevelopment is designed and built with elements that encourage
alternatives to single occupancy vehicle trips, and that the project will perform in
ways to lower vehicle miles traveled and associated emissions.
Noise
• Construction equipment will be required to have factory-installed mufflers or their
equivalents in good working order during the life of the construction contracts.
• Construction, where feasible, will take place primarily, during the less noise
sensitive daylight hours to avoid impacts during the hours associated with sleep.
Cultural Resources
• The roadbed of Hemphill Avenue may contain buried trolley tracks, and the area
beneath or alongside Hemphill Avenue may contain original water pipes
associated with the National Register-listed Atlanta Waterworks Hemphill Avenue
Station. During project construction, a qualified archaeological consultant would
monitor any construction and subsurface activities that are to occur along
Northside Drive in the vicinity of Hemphill Avenue.
• The Atlantic Steel site has been identified as eligible for listing in the National
Register of Historic Properties. Cleanup and redevelopment of the site would have
an adverse effect on this resource. Mitigation for impacts to this resource includes:
1) development of large-format black-and-white photographs of the site as it
existed prior to redevelopment; and 2) development and implementation of a
public education and outreach plan. Components of this education and outreach
plan will include compilation of an oral history of Atlantic Steel Industries, Inc.,
development of educational materials, and the potential creation of a permanent
exhibition space celebrating and incorporating the history of Atlantic Steel in the
redevelopment plan.
Land Use/Community Resources
• An additional City of Atlanta police precinct for the surrounding area is anticipated
to be added by JAR in conjunction with the project.
Aesthetics
• There are a number of specific zoning conditions for the Atlantic Steel site that
address aesthetic, architectural, and landscaping requirements. In general, design
111
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and placement of specific buildings will be completed in a manner so as to create
transitions from, and compatibility with, surrounding uses.
IV
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ENVIRONMENTAL ASSESSMENT
17™ STREET EXTENSION
[GDOT PROJECT NH-7141-00(900), P.L NUMBER 714190]
and
ATLANTIC STEEL REDEVELOPMENT PROJECT
FULTON COUNTY, GEORGIA
LEAD AGENCY:
U.S. Environmental Protection Agency
FEDERAL COOPERATING AGENCIES:
U.S. Department of Transportation
Federal Highway Administration
and
U.S. Department of Transportation
Federal Transit Administration
APPROVAL FOR ADVANC
1M
ILABILny/PUl IQJHEARING PHASE:
DATE
%-Z-°o
DATE
DATE
APPROVAL OF ENVIRONMENTAX^S^BSS
'IVloo
dXte "
'lUlco
DATE
u \x\
0^
)HN H. HANKINSON, JR.
REGIONAL ADMINISTRATOR
ENVIRONMENTAL PROTECTION AGENCY
fa
LARRY R. DREIHAUP, P.E.
DIVISION ADMINISTRATOR
FEDERAL HIGHWAY ADMINISTRATION
DATE
JERRT\FRA£
REGIONAL ADMINISTRATOR
FEDERAL TRANSIT ADMINISTRATION
-------
Certificate of Compliance
Project NH-7141-00(900), Fulton County
P.I. No. 714190
I hereby certify that the Georgia Department of Transportation has considered the social, economic
and environmental effects of the project and has fulfilled the requirements of 23 USC 128 relating
to public hearing requirements.
Georgia Department of Transportation
By:
Title: State Environmental/Location Engineer
Date: iVoeW-StfA. Sj
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TABLE OF CONTENTS
Section Title Page
I. TYPE OF ACTION 2
II. DESCRIPTION OF PROPOSED ACTION 2
III. COORDINATION AND COMMENTS 2
A. Circulation of Environmental Assessement 2
B. Public Hearing 2
C. Agency Responses to Public Comments Received on the
Environmental Assessment 3
IV. REVISIONS TO THE ENVIRONMENTAL ASSESSMENT 25
NEW APPENDICES
APPENDIX J - Public Hearing Transcript
APPENDIX K - Public Comments on Environmental Assessment
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I. TYPE OF ACTION
The U.S. Environmental Protection Agency (EPA), in cooperation with the Federal
Highway Administration, the Federal Transit Administration, Georgia Department of
Transportation (GDOT), Georgia Regional Transportation Authority (GRTA),
Metropolitan Atlanta Rapid Transit Authority (MARTA), Atlanta Regional Commission
(ARC) and the City of Atlanta, has prepared an Environmental Assessment (EA) for the
17 th Street Extension [GDOT Project NH-7141-00(900)] and Atlantic Steel
Redevelopment Project, Fulton County, Georgia. The EA is a summary of the
development of concept alternatives, design traffic studies, preliminary engineering
analyses, and environmental impact assessments, all of which have been completed with
opportunities for public comment and agency coordination. This document represents an
update of the EA that was distributed to the public in August 2000.
II. DESCRIPTION OF THE PROPOSED ACTION
Jacoby Atlantic Redevelopment, L.L.C. (JAR), a developer in the City of Atlanta,
has proposed the remediation and redevelopment of approximately 135 acres near
Atlanta's central business district. The property to be redeveloped is the site of the
former steel mill owned by Atlantic Steel Industries, Inc. The planned redevelopment is
expected to include two million square feet of general office space, one and a half million
square feet of retail and entertainment uses, two million square feet of high tech offices,
2,400 residential units, and 1,000 hotel rooms. In addition to the site redevelopment,
project plans include construction of a multi-modal (cars, pedestrians, bicycles, transit)
bridge and interchange at 17th Street that will cross Interstate 75/85 (1-75/85) and provide
access to the site as well as a connection to Midtown Atlanta and the nearby MARTA
Arts Center Station. Roadway improvements will include extension of the existing 17th
Street from West Peachtree Street (U.S. 19/S.R. 9) in Midtown Atlanta, heading west on
new alignment over 1-75/85, through the development, and connecting with Northside
Drive (U.S. 41/S.R. 3) at Bishop Street. The project also will include operation of a
transit shuttle system that will circulate between the MARTA Arts Center Station and the
Atlantic Steel site.
III. COORDINATION AND COMMENTS
A. Circulation of the Environmental Assessment
The EA for this project was approved for advancement to availability and public
hearing phase by the Federal Agencies on August 2, 2000. Copies of the approved EA
were circulated to a number of federal, state, and local agencies, and other organizations
and groups for review and comment. The EA was also made available to the public in
August 2000, with copies available at local public libraries, GDOT and EPA offices, and
on the internet at www.epa.gov/proiectxl/atlantic/index.htm.
B. Public Hearing
Following circulation of the EA, a public hearing was held on September 12, 2000,
from approximately 6:00 p.m. to 9:00 p.m. at the Georgia Center for Advanced
Telecommunications Technology Building in Atlanta, Georgia. Members of the public
attending the hearing were given an opportunity to comment on the project. All of the
2
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comments received have been made part of the official transcript. Public concerns
included the following:
• Traffic and air quality impact concerns;
• Roadway design concerns;
• Mass transit concerns;
• Other transportation concerns;
• Atlantic Steel Redevelopment site concerns; and
• Neighborhood concerns.
Representatives from EPA, GDOT, City of Atlanta, MARTA, and JAR addressed
questions and concerns at the hearing. The Public Hearing transcript is provided in
Appendix J.
C. Agency Responses to Public Comments received from the Environmental
Assessment
Written comments on the EA were received during the public comment period,
which ended October 6, 2000. During this period, 255 comments were received. A copy
of each comment is included in Appendix K. The majority of comments received were
from local citizens in and around the project study area. Agency representatives
developed responses that effectively address all the major issues from the comments
received. The following is a listing of the major concerns and responses:
General Comments
1. Comment: Why are taxpayer dollars being spent to support this private
development?
Response: The project is anticipated to provide substantial environmental
benefits to the general public, both by improving regional air quality and cleaning
up a brownfield site. The project also benefits the general public by reducing
congestion (i.e., along 14th Street, 10th Street and at the I-75/I-85 NB exit ramp at
10th Street), by providing another crossing of the interstate, by providing
transit/bike alternatives and corridors, and by providing pedestrian and streetscape
improvements.
The economic benefits of this project are significant. The project is anticipated to
generate approximately 18,000 new jobs with a predicted gain of $619,638,000
total salaries paid to the new jobs. Several million dollars in tax revenues would
be generated for the City of Atlanta and Fulton County. The retail portion of the
redevelopment would contribute a Special Purpose Local Option Sales Tax
revenue source that would be allocated to the City of Atlanta school system and a
one-cent sales tax revenue source dedicated to the Metropolitan Atlanta Rapid
Transit Authority (MARTA).
3
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The former Atlantic Steel Mill site and other properties along Northside Drive and
Bishop Street were part of an area that was dominated by heavy industry in the
early to mid 1900's. The surrounding communities were largely connected to this
industry through employment. However, this relationship no longer exists due to
a gradual transition from heavy industry to more compatible residential and
commercial land uses in downtown Atlanta. The proposed redevelopment of this
site into mixed-use residential and commercial land uses continues this transition
and provides opportunities for planned reconnection with the surrounding
communities. By removing the industrial land use that was Atlantic Steel and
replacing it with a more homogeneous type mixed-land use, the overall
community feeling between the established neighborhoods is no longer broken.
In addition, when the Downtown Connector was initially constructed in the
1960's, access and community dynamics in Midtown Atlanta completely changed.
Several existing roadways were severed by the initial freeway project.
Construction of the 17th Street Bridge and Extension provides another
opportunity to reconnect the east and west sides of Midtown Atlanta and restore
continuity for communities in this area. New commercial and retail opportunities
would be provided within walking and biking distances to many existing
residences on both sides of the Interstate.
With regard to the transportation infrastructure not being justified, traffic
conditions in the design year for this project (Year 2025) on the majority of
surface roadways and intersections in the study area are predicted to stay the same
or improve (i.e., traffic volumes are predicted to decrease and traffic is predicted
to move more efficiently) with the construction of the 17th Street Bridge and
Extension, as compared to not implementing the project. This is due in large part
to an improved distribution of traffic that is predicted to occur as a result of the
project.
2. Comment: The Environmental Justice section was only concerned with low-
income or minority populations. Why would environmental impacts figure
differently for different segments of the population? Is justice only available to
minorities?
Response: Executive Order 12898, entitled Federal Actions to Address
Environmental Justice in Minority and Low-Income Populations (1994), requires
all federal agencies to identify and address disproportionately high and adverse
human health or environmental effects of federal programs on minority and low-
income populations. The general purpose is to foster non-discrimination in
federal programs and to provide minority and low-income communities greater
opportunities for public participation in, and access to public information
regarding human health and environmental issues. Potential low-income and
minority communities were identified in the project area to ensure that these
communities have access to both concise and clear information sufficient to
effectively participate in the public involvement process; and to ensure that these
communities are not disproportionately impacted by this project.
4
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3. Comment: The Tax Allocation District (TAD) funding represents a financing
vehicle that has not produced any dollars to date, despite many promises,
anywhere in the City of Atlanta.
Response: The TADs in the City of Atlanta (Westside and Atlantic Steel) are
relatively newly established. The TADs are only recently formulating a bond
issuance strategy. The bond proceeds for Atlantic Steel will be used to build the
project's infrastructure and to improve its connective infrastructure to nearby City
of Atlanta streets and storm and sanitary sewer linkages.
4. Comment: The assumptions developed for the No Build Alternative are unsound.
Response: Using its best judgment, the EPA, City of Atlanta, and the developer
for the Atlantic Steel site (hereafter referred to as JAR) developed a reasonably
foreseeable No Build Alternative for what could occur on the Atlantic Steel site if
the 17th Street Bridge was not built. There is no way to predict with 100 percent
accuracy what the future will hold for cases such as this and market demands.
However, based on current trends in the City and region, the proposed No Build
Alternative is the best estimate.
5. Comment: Midtown neighborhoods, including Ansley Park, were not adequately
included in the planning of this project.
Response: An intensive public involvement campaign was conducted for this
project. Over 300 public and agency meetings and discussion groups have been
held, and individual contacts and public notices have occurred. This effort has
included activities related to the rezoning of the property, EPA's Project XL, site
remediation efforts, and the development of the EA. Neighborhood Planning Unit
E (NPU-E), which represents all Midtown neighborhoods affected by this project,
was involved as early as 1997 in reviewing the rezoning application for the site.
Most of the conditions placed on JAR in the final zoning conditions for the site
came as a result of negotiations between NPU-E, the neighborhoods, and JAR.
Several meetings have been conducted by EPA and the GDOT with individual
neighborhood associations to provide information about the proposed bridge and
associated roadway improvements. A number of significant changes to the
roadway improvements, including design of the bridge, have come from
neighborhood input and concerns. In addition, JAR has committed to continue to
meet with NPU-E to keep the neighborhoods up-to-date with the latest site design
information and provide any other information on the site build-out.
6. Comment: An independent Environmental Impact Statement (EIS) and additional
traffic studies should be completed that would consider alternative solutions and
identify the impacts of this project.
Response: EPA completed a thorough assessment of the environmental impacts of
this project in full compliance with the National Environmental Policy Act. A
number of nationally and internationally recognized architectural and engineering
contractors and environmental consultants were utilized to conduct independent
assessments of the various aspects of the project, including site design, traffic, air
and water quality impacts. A range of alternatives were considered for this
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project, including: 1) alternate site locations for the development in the Atlanta
metropolitan region; 2) alternate site designs for the Atlantic Steel redevelopment;
3) alternate locations for the 17th Street Bridge placement; 4) Interstate access
alternates; 5) alternate intersection improvement; 6) high occupancy vehicle
(HOV) access alternates; 7) alternate transit connections to the MARTA Arts
Center Station, and 8) no-action or no-build alternative. Based on the alternatives
that were considered and the results of the various analyses completed for this
project, EPA does not believe that an EIS is required.
Traffic and Air Quality Impact Comments
7. Comment: The analysis of traffic impacts included in the EA is flawed.
Response: The procedures used to develop future traffic projections followed
generally accepted engineering guidelines of the transportation industry and
included the use of state of the practice traffic modeling. Traffic projections were
based on a combination of criteria including the capacity of the existing
transportation network, future improvements to the transportation network,
historical data and trends, existing and future land-use plans, etc. While
predicting future traffic growth requires thorough consideration of a number of
quantifiable criteria, some assumptions must inevitably be made and these
assumptions must be based on sound engineering judgement and experience. The
traffic study was prepared by registered professional engineers and reviewed and
approved by state and federal agencies.
The traffic growth rates of 1.5% for the Interstate and 2.0% for surface streets
used in the traffic projections are compounded annual growth rates. Over the 25-
year period between existing (2000) and future (2025), the actual total growth
rates calculate to be approximately 45% for the Interstates and 64% for the
surface streets.
Currently, certain roadways in the metro Atlanta region have and are experiencing
growth rates far in excess of the growth rates predicted in this traffic study.
Roadways that experience double-digit traffic growth rates are generally in high
employment and/or population growth areas. In addition, these roads are, in most
cases, relatively new multi-lane facilities that have excess capacity to carry
additional vehicles. Growth rates near and above 10% are common in the Atlanta
region, but these rates represent short-term growth periods. Roadways that
experience multiple years of high traffic growth eventually become congested and
traffic growth slows as the traffic volumes approach the carrying capacity of that
roadway.
Traffic forecasting procedures on a roadway or a system of roadways are
approached differently when making short-term predictions verses long-term
predictions. When forecasting short-term future traffic conditions, recent growth
rates on roadways are used due to the tendency of traffic growth to follow recent
trends in the short term. Forecasting becomes far more difficult when predicting
20 and 25 years into the future. Forecasts become a function of several variables.
6
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First, the historical growth on roadways is considered. Second, the existing traffic
volumes on the roadways are considered. If a roadway or system of roadways
already experience high traffic volumes and congestion, these roads do not have
the physical capacity to grow at high percentage rates. Thirdly, the employment
and population growth in an area has to be studied since traffic growth is a
function of these factors. When studying population and employment growth,
historical as well as future predictions are utilized.
The metro Atlanta region has experienced a large population and employment
growth period over the past decade. The Atlanta region continues to grow at a
fast pace. While the growth experienced over the last decade has been large, this
increase is defined as large absolute population growth as opposed to percentage
growth. According to the ARC, the Atlanta region population grew from 2.5
million in 1990 to 3.2 million in 1999. While this represents a 700,000-person
increase over 9 years, this is a percentage increase of only 25%. Furthermore, this
growth represents an annually compounded growth rate of only 2.5%. The
employment in the Atlanta region from 1990 to 1998 went from 1.4 million to 1.8
million, a 29% total increase and 3.2% annual growth.
As the population and employment of the Atlanta region increases, the annually
compounded growth rates will reduce because of the high total numbers upon
which they are based. While the absolute number increases year to year may
remain high, these numbers represent a decreasing percentage of the growing
overall population. ARC's forecasts for 2000 to 2020 population and
employment are as follows. The Atlanta region is expected to experience a 1.5%
and 1.4% annual growth rate for population and employment, respectively.
Fulton County is expected to experience a 0.8% and 0.7% growth rate for
population and employment, respectively. While these growth rates appear small,
they are compounded annual rates based on already high population and
employment numbers.
What this information shows is that the long-term population and employment
growth rates for this region closely match the growth rates used for the traffic
predictions. Furthermore, in order to be conservative, the traffic forecasts
assumed constant modal split for the 25-year period. Modal split is the
percentage of commuters using automobiles, transit, bicycle and other modes of
transportation. With increased congestion predicted in the study area, it is likely
that the percentage of commuters using mass transit will increase over the next 25
years.
Traffic growth in Atlanta, like population and employment growth, will
experience decreasing annual growth rates due to the already high total volumes
on the surface streets and Interstates. Additionally, traffic growth of roadways is
further constrained by the physical ability of a roadway facility to handle
additional vehicles. The high percentage growth rates on the Interstate system
from 1986 to 1996 are, in large part, due to two factors, the first being the high
population and employment growth of the Atlanta region. The second factor is
that the Interstate system in the study area was widened in the mid-1980's. The I-
75/1-85 Downtown Connector was expanded from a 6-lane facility to a 12-lane
facility. This increased capacity on this section of Interstate enabled the high
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traffic growth during the next ten years. With no widening of the Interstate
planned or feasible in this area, additional traffic growth is constrained to the
existing roadways. With no planned long-term widening on the main arterials in
the study area, with the exception of Northside Drive, traffic growth on the
surface streets is likewise constrained by the capacity of these roadways.
Several factors were researched and considered in the traffic predictions for the
study area. The long-term population and employment trends were considered
and closely approximate the long-term traffic growth used in the study. The
existing roadway volumes and roadway capacities were closely studied when
making predictions on how these facilities would handle increased traffic growth.
Furthermore, if the percentage of commuters using transit to access this area of
Atlanta increases, as many predict it will due to the huge expenditures planned for
transit implementation, the growth rates predicted on these roadways should be
high, particularly when projected to the year 2025.
8. Comment: How can the EA conclude that there are no impacts to the Ansley Park
neighborhood? The traffic impacts to the Ansley Park neighborhood must be
identified and appropriate actions taken to remedy the impacts.
Response: The EA concludes that the proposed 17th Street Bridge and extension
would affect the Ansley Park neighborhood, primarily related to increased traffic
volumes in the neighborhood. However, based on information that has been
developed as part of the traffic impact analysis, the increases in traffic would
occur over an approximate twenty-year time frame and should not adversely
affect overall traffic patterns in the neighborhood. Three of the five entrances into
the Ansley Park neighborhood from the west (Beverly Road, Peachtree Circle,
and 16th Street) are anticipated to experience minimal increases in traffic volumes
at these specific locations. The remaining two entrances (15th Street and 17th
Street) into the neighborhood are anticipated to experience larger increases in
daily traffic. This analysis is based on the comparison between future conditions
in this area that are predicted to occur either with or without the 17th Street
Extension and Bridge.
In response to concerns from the Ansley Park Civic Association (APCA) and
many citizens of the neighborhood about these projected increases in traffic
volumes, a specific agreement has been entered into, by and between the APCA,
GRTA, GDOT, the City of Atlanta, and JAR. The purpose of this agreement is to
establish a mechanism for the continued study of traffic in Ansley Park as a result
of the Atlantic Steel Redevelopment project and other developments in the
Midtown Atlanta area. The agreement includes guaranteed financial
commitments for the implementation of traffic calming and control measures that
are identified as a result of separate studies, both internal and external to the
Ansley Park neighborhood. The agreement has been duly executed and
constitutes a valid and binding agreement, enforceable in accordance with the
laws of the State of Georgia and in any court of competent jurisdiction.
9. Comment: The concerns of the Ansley Park neighborhood would be resolved if
Ansley Park was made a gated community.
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Response: The idea of gating the community of Ansley Park is problematic and
generally contrary to the City of Atlanta's Comprehensive Development Plan.
Public streets typically cannot be gated, especially those that provide access to
public parks. The City of Atlanta pledges to monitor traffic problems as they may
develop and to work with the neighborhood and appropriate agencies to address
such issues.
10. Comment: How will the traffic impacts to Home Park and Loring Heights be
addressed in the future?
Response: When the Atlantic Steel property was rezoned in 1998, specific zoning
conditions were included to address the surrounding neighborhoods' concerns
related to future traffic impacts. Condition 4 of the current zoning requires JAR
to work with the City of Atlanta and Home Park to limit cut-through traffic on
residential streets perpendicular to and south of 16th Street by means of cul-de-
sacs, speed humps, gates, control arms, and other traffic calming devices. JAR is
also required to work with the City of Atlanta and the Loring Heights
neighborhood to limit cut-through traffic on Bishop Street. In addition, Condition
#23 of the current zoning requires JAR to develop a transportation management
plan that will attempt to reduce single occupancy vehicle (SOV) trips to and from
the site. Both of these conditions represent enforceable measures on behalf of the
City of Atlanta and JAR to work with these adjacent neighborhoods to minimize
traffic impacts in the future.
Atlantic Steel Brownfield Area and Tax Allocation District Number Two
(BATAD #2) was created to make possible the redevelopment of the Atlantic
Steel site and encourage additional development on the perimeter of the
redevelopment area. More specifically, BATAD #2 promotes maximum use of
alternative transportation modes to minimize congestion and creates a financing
tool for transportation and other infrastructure to improve and connect major
activity centers. Since certain surface streets in the adjacent neighborhoods of
Home Park and Loring Heights are included in the boundary for BATAD #2, it
provides a specific process and dedicated funding source for the implementation
of future transportation projects, including potential traffic calming measures, in
these areas. Therefore, if cut-through traffic is determined to be excessive in
Home Park or Loring Heights attributed to the Atlantic Steel redevelopment or
surrounding areas, appropriate BATAD #2 funds would be utilized to study and
implement measures to limit cut-through traffic. All monies and expenditures
would be managed by the Atlanta Development Authority and the City of Atlanta.
For any traffic calming measures that would require changes in traffic ingress and
egress at certain intersections, the City of Atlanta would provide temporary
barricades for an agreed upon trial period to determine the effects of eliminating
(or improving) access.
Specific to Loring Heights, two proposed transportation improvement projects
have been identified as part of discussions with the Loring Heights Neighborhood
Association. These are: 1) construction of an elevated pedestrian/bicycle bridge
at Mecaslin Street; and 2) widening of Bishop Street between Northside Drive and
Howell Mill Road. The City of Atlanta and JAR will continue to work with the
Loring Heights neighborhood and the adjacent commercial district to further these
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projects, as appropriate. As stated above, it is anticipated that appropriate
BATAD #2 funds would be utilized to study and implement these projects.
The specific agreement with APCA in no way invalidates or supercedes existing
commitments of the City of Atlanta and the developer with the Home Park and
Loring Heights neighborhoods contained within the enforceable zoning conditions
for the site and the established BATAD #2 for the area.
11. Comment: The EA fails to analyze the cumulative environmental impacts of
other transportation proposals for this area.
Response: Specific, enforceable mechanisms have been established to monitor
the build-out of the Atlantic Steel site and commitments have been made to
continue to address traffic issues in the project study area. These commitments
were developed to address the cumulative effects of the Atlantic Steel
development and other developments and transportation proposals in the Midtown
area. Individual transportation proposals in the area will comply with
requirements for environmental impact assessment under the National
Environmental Policy Act, as appropriate.
12. Comment: Construction of the 17th Street Bridge relieves 14th Street and moves
Level of Service (LOS) on 14th Street from "F" to "C". However, 17th Street is
constructed at LOS "F". Please explain.
Response: Many factors contribute to the capacity of a specific section of road or
intersection. These factors include number of lanes, lane widths, shoulder widths,
speed, grades, percent trucks, directional distribution of traffic, and intersection
location. The extension of 17th Street and the construction of the 17th Street
Bridge is, in part, intended to alleviate traffic patterns that move east or west
across I-75/I-85 on 14th Street and 10th Street. The improved LOS on 14th Street
is directly related to providing new and improved access from the Interstate and a
new east-west minor arterial in the Midtown area at 17th Street across I-75/I-85.
In response to public concerns about the width of the originally proposed 17th
Street, several key intersections and roadways were redesigned, including the
removal of through lanes and turning lanes on 17th Street. In making these
changes, additional urban design criteria were considered such as pedestrian
safety and context sensitive design, creating a more acceptable urban corridor,
with less emphasis on accommodating future traffic volumes alone. It was agreed
that a certain amount of predicted additional congestion would be acceptable. A
decreased LOS on 17th Street was determined to be permissible in order to
accommodate the other design criteria. The primary design concern was that
traffic would not backup on the Interstate exit ramps and affect the operations and
safety of the Interstate system.
13. Comment: The analysis of air quality emissions included in the EA is incorrect.
Response: Regarding air quality impacts on surrounding neighborhoods
generated by the Atlantic Steel redevelopment, the Georgia Institute of
Technology performed a carbon monoxide (CO) hotspot analysis, on behalf of
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EPA. Results of the analysis concluded that traffic associated with the Atlantic
Steel redevelopment and associated roadway improvements would be extremely
unlikely to create a localized violation of the National Ambient Air Quality
Standards (NAAQS) for CO in the foreseeable future. Justification of the
appropriate traffic assumptions used in the CO hotspot in the analysis is described
in the Response to Comment #7. The CO hotspot analysis was conservative in
that it considered conditions most likely to produce CO hotspots in terms of
meteorology, traffic congestion, and receptor location. Furthermore, the CO
hotspot analysis was completed before EPA finalized its Tier 2 tailpipe emissions
and gasoline sulfur standards, which should reduce future motor vehicle CO
emission rates below those assumed in the CO hotspot analysis.
In addition, EPA performed a regional emissions analysis, which concluded that
the Atlantic Steel redevelopment would produce fewer transportation-related
emissions of volatile organic compounds and oxides of nitrogen, precursors to
ground-level ozone formation, than a comparable amount of development built at
other likely locations in the Atlanta region.
14. Comment: The EA fails to acknowledge the existence of air quality problems in
the Atlanta Metropolitan Region and active litigation challenging the recent
regional transportation plan.
Response: The EA clearly explains the current air quality status for the study
area, including the Atlanta Metropolitan Region. Regardless of the outcome of
any active litigation challenging the recent regional transportation plan for the
Atlanta region, the 17th Street Extension and Atlantic Steel Transportation
Control Measure (TCM) are required to be implemented by the State of Georgia
as this project has been included as part of the Georgia State Implementation Plan
(SIP).
15. Comment: The designation of the 17th Street Extension plus the Atlantic Steel
development as a TCM by EPA is in excess of its legal authority.
Response: EPA has approved the Atlantic Steel TCM into the Georgia SIP under
the authority of Sections 108(f) and 110 of the Clean Air Act (CAA). As
explained in the final TCM rulemaking, EPA approved the redevelopment as a
TCM because its location, transit linkage, site design, and other transportation
elements together comprise a measure for the purpose of reducing emissions or
concentrations of air pollutants from transportation sources by reducing vehicle
use or changing traffic flow or congestion conditions. In addition, the
redevelopment includes specific elements listed in Section 108(f). Under Section
110 of the CAA, EPA approves measures into the SIP that contribute to
attainment of the NAAQS.
16. Comment: The project lacks the necessary criteria to qualify as a TCM.
Response: In the final TCM rulemaking, EPA identified six criteria established
by EPA policy ("Transportation Control Measures: State Implementation Plan
Guidance," U.S. EPA Office of Air Quality Planning and Standards, September
1990) that a proposed TCM must satisfy before it may be considered for inclusion
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in the SIP. The rulemaking also contained detailed explanations of how the
proposed Atlantic Steel TCM satisfied EPA's criteria. It is the opinion of EPA
that the Atlantic Steel TCM has indeed been subject to intense scrutiny,
particularly in terms of satisfying EPA's six TCM criteria.
In addition, the Atlantic Steel TCM contains four site design criteria and four
transportation performance targets which will collectively help ensure both that
the redevelopment is designed and built with elements that encourage alternatives
to single-occupancy automobile trips, and also that the project will perform up to
its potential to lower vehicle-miles traveled and concomitant emissions. Zoning
conditions, other neighborhood commitments, and the site design criteria and
performance targets identify and establish appropriate measures to protect
surrounding neighborhoods from adverse traffic and air quality impacts generated
by the Atlantic Steel redevelopment and 17th Street Extension.
Roadway Design Comments
17. Comment: Rail transit, pedestrian walkways, and bus lanes should be the focus
for this project, rather than encourage vehicle use.
Response: The success of the Atlantic Steel redevelopment is contingent on a
mixture of access via different modes of transportation. Reliance on pedestrian,
transit, and bicycle modes of transport without the proposed number of single
occupancy vehicle (SOV) lanes would not address the proposed traffic demand
nor allow this environmentally beneficial project to be viable.
A specific alternative was considered in the EA that included transit-only for the
17th Street Bridge, including bike and pedestrian facilities, with no SOV lanes.
However, a number of significant traffic impacts of the transit-only alternative
were identified, specifically in the southern and western portions of the study
area. Without the provision of an east-west general traffic connection, including
SOV lanes, across I-75/I-85 and new Interstate access, traffic volumes would be
significantly greater on the existing Interstate exits at 10th and 14th Streets.
Certain sections of 10th Street, 14th Street, Techwood Drive, and Williams Street
would experience large increases in average daily traffic (ADT) volumes in the
project area. Several intersections would have a higher level of congestion in the
Year 2025. Furthermore, without the provision of direct access to the Atlantic
Steel site, traffic would utilize existing surface streets in the Home Park
neighborhood to access the redevelopment and have much greater impacts on this
community.
18. Comment: Instead of building the 17th Street Bridge, improve access to the site
from Northside Drive.
Response: Based on the future traffic projections for the planned residential,
retail, office and hotel development on the Atlantic Steel site, improvements to
Northside Drive alone, with no Interstate access improvements, could not
accommodate the projected traffic volumes. In addition, the "smart growth"
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aspects of the Atlantic Steel project and the substantial social, economic, and
environmental benefits, as outlined in the EA, would not be possible without
adequate access from all directions, particularly 1-85 from the north and I-75/I-85
from the south.
19. Comment; Cover the Interstate with a continuous bridge from 5th Street to 17th
Street, build a park on this structure, and reopen the cross streets.
Response: The overall implementation costs for such an alternative would likely
cost several hundred million dollars. A project of that magnitude may extend into
the billions, as has occurred on a similar project being constructed at this time in
Boston, Massachusetts. The "Big Dig", as it is referred, has an estimated cost of
ten billion dollars and is expected to increase over time. It is also estimated that
federal taxpayers will have to pay for eighty-five percent of the cost. This would
be beyond the scope and funding of this project. Due to fiscal constraints, this
alternative would not be feasible. The 17th Street Extension and Atlantic Steel
Redevelopment Project has an intended purpose of creating a mixed-use
community that is interconnected to the Midtown area.
20. Comment: The 17th Street Bridge design is not in compliance with the zoning
conditions attached to the Atlantic Steel property.
Response: The zoning conditions for the Atlantic Steel site included two
diagrams (a plan and cross-section) of 17th Street. These conditions are specific
to 17th Street on the Atlantic Steel property. However, the design for 17th Street,
including the bridge, included a divided four-lane roadway, with two general
purpose lanes in each direction and one bike lane in each direction. The main
addition to this design would be the transit-only lane from Northside Drive to
West Peachtree Street. The bicycle lane is now included within this wide transit
lane. Unfortunately, the rezoning of this property came well in advance of the
development of the concept for the 17th Street Extension, including a better
definition of the transit connection to the Arts Center Station. The bridge cross-
section in the zoning conditions is illustrative and not a binding diagram. The
proposed cross-section is consistent with and satisfies the performance criteria
stated in the zoning conditions.
21. Comment: The proposed bridge design is not supportive of the Blueprint
Midtown developed by the Midtown Alliance.
Response: Several key intersections and surface streets were redesigned.
Additional urban design criteria were considered such as pedestrian safety and
aesthetics, with less emphasis on accommodating future traffic volumes. The
focus of the changes was to reduce: driving speeds, lane widths, the number of
through and turning lanes, and turning radii of intersections. The ultimate
objective was to balance the needs of cars, buses, bicycles, and pedestrians to
better integrate 17th Street with the urban fabric of Midtown Atlanta and
coordinate more closely with the vision for Midtown provided by the Midtown
Alliance and "Blueprint Midtown."
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22. Comment: The 17th Street Bridge is too wide. The dedicated bus lanes should
not be a part of the bridge.
Response: The dedicated transit link to the MARTA Arts Center Station is
required in order for this project to be considered a TCM. The multi-modal
bridge is proposed to be approximately 130 feet wide to accommodate
automobile, transit, pedestrian, and bicycle elements. Without the transit, bicycle,
and pedestrian elements incorporated into the design of the 17th Street Bridge, the
project would not be approved.
23. Comment: The 17th Street Bridge must be designed by someone sensitive to
aesthetic issues, not just experienced in building roadways.
Response: Pedestrian design and aesthetic detail will be important considerations.
The 17 Street Bridge will be multi-modal, meaning that vehicles, pedestrians,
bicycles, and transit buses will all utilize it. At this time, potential designs for the
bridge are unknown; however, there is a general agreement that the 17th Street
Bridge should be designed as a "gateway" structure into the heart of Downtown
Atlanta, if possible. Regardless, qualified landscape architects will work to
ensure that aesthetic values and overall compatibility with existing and future
Midtown streetscapes are achieved in the course of final bridge and roadway
design.
24. Comment: The project should provide return access to I-75/I-85 from the 17th
Street Bridge.
Response: This was considered during the early stages of concept development.
However, it was determined that such connections were not feasible due to
physical and geometric constraints and due to unacceptable impacts on freeway
mobility. Therefore, the existing local access to the Interstates will be utilized.
25. Comment: Why do you need the 17th Street Bridge, when there is an existing
state roadway corridor (14th Street) that runs parallel to the proposed corridor and
provides adequate access to the area?
Response: An alternative was considered that included upgrades to 14th Street
and no 17th Street Bridge. Results of the Year 2025 traffic modeling for this
alternative did not show appreciable improvements in traffic and ramp operations
even with significant widening of 14th Street. In addition, this alternative did not
provide direct access to the Atlantic Steel site. Therefore, this alternative was not
considered further, and it was determined that a new bridge would be required to
provide direct access to the Atlantic Steel site and another east-west connection
into Midtown.
26. Comment: As part of this project, Piedmont Road, Juniper Street, Spring Street,
and West Peachtree Street should be returned to two-way traffic.
Response: The return of these roadways to two-way traffic is considered outside
the scope of the 17th Street Extension project. Piedmont Road and Juniper Street
are City of Atlanta streets. A specific project could be initiated to effect this
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change; however, the City of Atlanta would be responsible for sponsoring and
implementing these changes. West Peachtree Street and Spring Street are both on
the State Route system. Previous studies conducted by traffic engineering
consultants for GDOT indicated that this is the best utilization of these two
facilities and that returning these roads to two-way traffic would reduce the
existing level of service to further unacceptable levels.
27. Comment: Instead of extending 17th Street to Peachtree Street, stop 17th at
Spring Street or West Peachtree Street.
Response: The termination of any GDOT project requires a connection to a State
Route (SR). The 17th Street Extension as currently designed, terminates at U.S.
41/S.R. 3 (Northside Drive) on the west and U.S.19/S.R.9 on the east. S.R.9 in
this location consists of Spring Street and West Peachtree Street, which are one-
way, southbound and northbound arterials, respectively. Because these are one-
way streets, 17th Street must connect to both streets in order to effectively
distribute the traffic in both directions. 17th Street between West Peachtree Street
and Peachtree Street is an existing two-lane City street. 17th Street in this
location would not be changed, with the possible exception of the removal of on-
street parking at the intersection of 17th Street and Peachtree Street. Utilization
of 17th Street in this location is necessary to provide continued access to the
commercial district along Peachtree Street, maintaining the City Street grid
system, and allowing for better distribution of traffic.
28. Comment: The combined bus/bicycle lane design poses a hazard to bikers.
Response: Dedicated bus/bicycle lanes will continue from West Peachtree Street
to Northside Drive. In the design of the 17th Street Extension, these lanes would
include 12 feet for buses and four feet for bicycle travel. Adequate space has been
provided within these lanes for the safe operation of buses and bicycles based on
American Association of State Highway and Transportation Officials guidelines.
Operation of shuttles is not anticipated to hamper bicycle travel. Shuttles would
operate on four and eight minute intervals. The same concept has been used in
other cities and has been found to be effective. Based on comments made during
the Public Hearing for this project, the Executive Director of the Atlanta Bicycle
Campaign expressed support for this concept.
29. Comment: The 17th Street Extension does not seem to be pedestrian-friendly.
Response: The multi-modal bridge is proposed to be approximately 130 feet wide
and would include automobile, transit, pedestrian, and bicycle elements. The
bridge would contain two general-purpose travel lanes and one dedicated
transit/bike lane in each direction with sidewalks on both sides. Sidewalks would
be provided on all new surface streets in the Atlantic Steel redevelopment and as
part of most off-site roadway improvements. It is anticipated that sidewalk
widths would be approximately 15 feet on all street improvements except for the
17th Street Bridge where they would be 22 feet on the south side and 30 feet on
the north side. The redevelopment would include utilization of the existing at-
grade crossing over the railroad at Mecaslin Street to provide a signalized
bike/pedestrian crossing into the Loring Heights community. JAR would provide
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a grade separated (elevated) bike/pedestrian crossing at the location, depending on
negotiations with Norfolk Southern Railroad.
There are a number of design-specific measures that will be considered in the next
phase of bridge and intersection design to ensure that bicycle and pedestrian needs
are met. These include: 1) construction of narrower lanes to shorten the length of
the intersection crossing; 2) develop wider medians to provide islands; 3)
consideration of prioritized signal timing for pedestrians; and 4) use of special
surface treatments for cross walks. The City of Atlanta and GDOT commit to
working with affected stakeholders of the project to ensure that pedestrian needs
are considered and a continuous flow of pedestrian movement is maintained in the
design of roadways and intersections connecting the 17th Street Bridge into
Midtown.
30. Comment: Lower the design speed on 17th Street to 25 mph.
Response: The speed design is applicable to the functional classification of the
proposed roadway. While the design speed is set at 35 mph, once completed the
posted speed can be changed to facilitate operations. The City of Atlanta is
anticipating to post a 25 mph speed limit on 17th Street.
31. Comment: Provide an eight to ten foot planting buffer between the travel lanes
and the sidewalk on 17th Street.
Response: The design team for the project will consider this and similar options
for the 17th Street corridor during the plan development phase. Additional input
will be sought from the community and the City of Atlanta concerning the
landscaping desires and commitments for maintenance as the project moves
forward.
32. Comment: Provide a grade separation to allow motorists traveling southbound on
Techwood Drive that are destined to 10th Street to pass under 14th Street.
Response: According to the traffic analysis conducted for the Atlantic Steel/17th
Street Extension project, acceptable operations will occur with the 14th
Street/Techwood Drive intersection remaining at-grade. In order to grade
separate the 14th Street movements from the 10th Street movements, there would
be substantial impacts to all properties surrounding this intersection and,
therefore, this option is not viable for this project.
33. Comment: Shift the alignment for the southbound ramps from 1-75 and 1-85 to
Techwood Drive to the east in order to reduce property impacts south of 16th
Street.
Response: The conceptual alignments have been adjusted to achieve a "smoother
transition" as suggested. However, there will be unavoidable impacts to the
properties that abut this section of Techwood Drive. The final design will attempt
to minimize property impacts without jeopardizing vehicular safety or operations.
Once the design is completed in this area and the actual property impacts are
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defined, specific affected property owners will be contacted to discuss the
property impacts of the final design.
34. Comment: Extend 17th Street west from Northside Drive to Howell Mill Road
Response: Currently, there are no plans to extend 17th Street improvements
beyond Northside Drive. The Loring Heights Neighborhood Association
expressed a desire to widen Bishop Street between Northside Drive and Howell
Mill Road. This will not be included in the 17th Street project; however, the City
of Atlanta and JAR will continue to work with the Loring Heights neighborhood
and the adjacent commercial district to further this project, as appropriate. As
stated previously, it is anticipated that appropriate BATAD #2 funds would be
utilized to study and implement this project.
35. Comment: Provide a traffic light at the intersection of Bishop Street and 17th
Street.
Response: GDOT will evaluate need for a traffic signal at this location as design
proceeds. Specific design standards will be reviewed to determine if adequate
distance from Northside Drive is available to place a traffic light at this location.
Any traffic light at this location will include signalization for both pedestrians and
cars.
36. Comment: Close Bishop Street at Mecaslin Street.
Response: At the request of the Loring Heights Neighborhood Association and
several of the businesses in the adjacent commercial district, Bishop Street will
remain open at Mecaslin Street.
37. Comment: Do not destroy large oak trees on the east of Northside Drive, south of
Bishop Street.
Response: No trees will be removed at this location.
Transit Comments
38. Comment: Rail transit, not a shuttle service, should be a component of this
project.
Response: The developer will provide a rubber-tired shuttle service for ten years
from the date that the 17th Street Bridge opens to traffic or until December 31,
2015, whichever is longer. The developer's obligation will cease if, during the
period of obligation, an appropriate entity operates a fixed mass transit link
providing a similar level of service.
Although currently there is no commitment of funds for rail transit service to the
Atlantic Steel site beyond the developer's commitment, EPA believes it is
reasonable to expect that some form of future fixed transit (potentially rail) will
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be developed to serve the Atlantic Steel redevelopment. The 2025 Regional
Transportation Plan (RTP) for the Atlanta region adopted by ARC anticipates
assigning $1,677,000,000 for the construction of a light rail line from the
MARTA Arts Center station through the Atlantic Steel redevelopment and
extending northwest to the Town Center area in Cobb County (RTP projects AR-
251 A, AR-251B, and AR-251C). The first phase of the project, which would
connect the MARTA Arts Center station to the Cumberland area through the
Atlantic Steel redevelopment, is anticipated to be operational by 2010. The
developer has committed in the TCM to provide without cost right of way in the
development to MARTA or other acceptable entity for the construction of a
transit linkage connecting the Atlantic Steel site to the MARTA Arts Center
station.
39. Comment: Provide an explanation on the status of the transit loop to the OMNI
MARTA Station, commonly called the "West Side Loop".
Response: The 2025 Regional Transportation Plan (RTP) for the Atlanta region
adopted by ARC includes SI,000,000 for a downtown westside transit study (AR-
325). One of the objectives of the Central Atlanta Transportation Study (CATS),
currently underway, is to develop alternatives for mobility on the west side of
Downtown Atlanta between the Atlantic Steel redevelopment and the Georgia
World Congress Center and destinations between, including transit.
40. Comment: There are insufficient guarantees to preclude expanded automobile
lanes on the bridge in place of the transit lanes.
Response: Approval of the project as a Transportation Control Measure (TCM)
requires dedicated transit lanes. Any conversion of these lanes to general purpose
vehicular traffic is prohibited under the federally enforceable TCM.
41. Comment: How can the developers or the City of Atlanta believe that bus service
to the site will do any good?
Response: Provision of a shuttle bus service is the short-term solution of linking
the Atlantic Steel site to the MARTA Arts Center Station. This short-term transit
option should be successful because of: 1) the connectivity it will provide with
MARTA; 2) convenience; 3) accessibility; and 4) specific performance
requirements in the TCM. Buses would circulate throughout the development and
across the 17th Street Bridge on dedicated transit-only lanes, which will have a
signal priority at certain signalized intersections. During peak hours (6:00 to 9:00
AM and 3:30 to 6:00 PM) the buses would operate on a four-minute frequency
and an eight-minute frequency at off-peak hours, thereby matching the existing
MARTA train schedule. The developer will provide the buses, which are
anticipated to be comfortable, clean-burning natural gas vehicles, and will operate
the shuttle system. The shuttle service will be free of charge. Finally, there are
specific performance requirements in the TCM and zoning conditions for the site
that if the development is not meeting expected ridership targets for non-SOV
modes (including transit), the developer must initiate practices to increase
ridership in these alternative modes.
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It is also anticipated that MART A will expand or alter its existing bus routes to
include service to the Atlantic Steel site once the redevelopment attains a transit-
supportable level of residents, employees, and other trip generators.
42. Comment: What are the opportunities for linking this project with AMTRAK or
creation of a new multi-modal terminal on the Atlantic Steel site?
Response: The current proposed Multi-Modal Passenger Terminal (MMPT) is
proposed to consolidate a number of transportation providers (Greyhound Buses,
Metro Commuter Rail/Buses, Georgia Rail Passenger Network and AMTRAK) at
one location adjoining the Five Points MARTA Station. It has been in the
planning stages for nearly a decade. A feasibility report was completed by ARC
in 1991 which looked at a number of sites for AMTRAK. GDOT prepared an EA
in 1994 for the MMPT at the Five Points site. Brookwood Station was
considered, but was not large enough, nor could it be expanded to accommodate a
new AMTRAK network. GDOT is now in the process of reviewing this project
and it is probable that AMTRAK, with a larger network or the current New
York/New Orleans service, will be relocated to the Five Points facility to provide
a comprehensive transportation facility for the traveling public. Relocation of the
MMPT to the Atlantic Steel site is not part of the site development plan as created
by JAR.
A possible rail line to Cobb County from the Arts Center Station thru the Atlantic
Station site will be studied by GRTA and, if feasible, would be subjected to an
environmental document, as described previously. It would be a number of years
in planning and development stages. It is not likely that any of these studies
would conclude that AMTRAK should be located at the current site or a new site
based on the earlier studies for the MMPT in 1991. MARTA has no studies
underway or pending for a Northwest Line that would link to an AMTRAK
facility at the current location or at the Atlantic Steel site.
Other Transportation Comments
43. Comment: What is the status of providing High Occupancy Vehicle (HOV)
access to Midtown as part of this project?
Response: Based on public concerns, the concept of providing HOV access to the
Midtown area is no longer a part of the 17th Street Extension project. The
concept of providing HOV access into the Midtown area is still being considered
by GDOT, GRTA, and the City of Atlanta; however, there is currently not a
specific project that has been defined for inclusion in the ARC FY 2001 to FY
2003 Transportation Improvement Program (TIP) or 2025 RTP. It is anticipated
that a Midtown HOV project could be developed for inclusion in later
updates/amendments to the TIP or RTP. Several alternatives would likely be
considered to satisfy the overall purpose and need for that project. The HOV
project would have a separate planning process, including preparation of an
environmental impact document and several opportunities for public involvement
and comment on the scope of any HOV plans. Construction of the 17th Street
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Extension will not preclude the possibility of a direct HOV freeway access
component in the future.
44. Comment: What is the status of the proposed redesign of the I-75/I-85
interchange?
Response: A separate project to improve the existing exit from 1-75 southbound
to 1-85 northbound at Brookwood is listed in the ARC FY 2001 to 2003 TIP, as
Project AT-AR 211. This project is not included within the 17th Street project;
however, design of the 17th Street Extension will not preclude the possibility of a
future interchange. Monies are included in the TIP to initiate preliminary
engineering this fiscal year. The I-75/I-85 Interchange project will have a
separate planning process, including preparation of environmental impact
documents and several opportunities for public involvement and comment on the
scope of the proposed improvements.
45. Comment: Roadway construction staging areas should be located on the Atlantic
Steel site and not on the east side of the Interstate. Any nonessential land
acquired by GDOT for construction purposes should be put back into use within a
year after construction is finished.
Response: Construction staging areas have not been identified at this point. This
decision will be made during the Right-of-Way acquisition phase.
Atlantic Steel Redevelopment Comments
46. Comment: Redevelopment of this site should not include a retail component that
is larger than Lenox Mall.
Response: The retail component of the Atlantic Steel Redevelopment is small in
comparison to Lenox Square Mall in Buckhead. Lenox Square has over 230
specialty stores and three department stores. The retail component planned for
the Atlantic Steel redevelopment consists of approximately 80 stores, or about
one-third the size of Lenox Square.
47. Comment: Mixed use buildings only promote transit if they have their front doors
at the sidewalk or oriented to transit stops.
Response: The mixed-use buildings within the Atlantic Steel redevelopment will
be oriented to the sidewalk and transit stops. This is not only part of the
redevelopment plan for the site but is outlined in the zoning conditions as well.
48. Comment: The Atlantic Steel redevelopment is a suburban, not urban,
development.
Response: JAR consulted and produced its redevelopment plans with local,
national and international experts who have been identified as the leaders in
mixed-use, smart-growth urban communities. Based on these experts'
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recommendations and extensive input from the neighboring communities of
Home Park and Loring Heights, the current plan has been developed. Architects
and planners who understand how great urban spaces are created, have
commented that the mix-of-uses, street-connectivity, small block-size, pedestrian-
orientation and urban design elements in this plan have made the Atlantic Steel
Redevelopment a national model for exceptional urban development.
49. Comment: The Atlantic Steel Redevelopment is three times the size of the Mall
of Georgia.
Response: The Atlantic Steel Redevelopment is actually over three times smaller
than the Mall of Georgia. Construction of the Mall of Georgia required the
clearing of approximately 500-acres of undeveloped land 30 miles northeast of
downtown Atlanta in Gwinnett County. The Mall of Georgia contains only retail
components. The Atlantic Steel redevelopment cleans up a contaminated
industrial site and will include a mix of uses on approximately 135 acres. The
Mall of Georgia has over 175 specialty stores and 5 anchor department stores
compared to the approximately 80 stores planned for the Atlantic Steel
Redevelopment.
50. Comment: Make the former Atlantic Steel site into a park.
Response: The redevelopment of the Atlantic Steel property is ultimately a
private venture, which is providing the financial resources for cleanup of this site.
The City of Atlanta has not identified this area as part of their master park plan.
In addition, a specific zoning condition placed on the property by the City of
Atlanta stipulates that there will be no less than 7 acres of green space or park
space within the redevelopment. Currently there are plans for over 11 acres of
public park space for the residents, employees and visitors to use. This 60%
increase in park space will provide opportunities for recreation, afternoon
concerts, and evening strolls.
51. Comment: EPA must ensure that adequate measures are taken to control dust
from on-site construction operations.
Response: JAR has implemented a stringent dust control program that provides
for visual inspections of construction activities on a continuing basis, and requires
the construction contractor to maintain and utilize dust control equipment (water
trucks) on a full time basis during earthwork and grading activities. Two such
water trucks are currently utilized at the project site maintaining the excavation
areas and haul roads in a watered down condition. Ongoing inspections by the
City of Atlanta staff, the Fulton County Soil and Water Conservation
Commission, and the on-site engineering staff maintain consistent oversight of the
contractor's compliance with these requirements. Citizen complaints to EPA will
be forwarded to the Georgia Environmental Protection Division for enforcement
of regulatory requirements.
52. Comment: Water and sewer lines in the Home Park neighborhood should be
updated and expanded, based on current inadequacies of the water system in the
area.
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Response: JAR has conducted a detailed evaluation of the current potable water,
storm sewer and sanitary sewer service system within the area of 16th Street
between Mecaslin Street and Techwood Drive. This evaluation was conducted to
determine if any infrastructure improvements would be required to fully support
the additional service needs of the redevelopment. The utility improvements
identified include installation of a new potable water service main paralleling 16th
Street and connecting to the existing service mains that provide potable water
service along the connecting north-south streets in the Home Park community. In
addition, JAR has conducted television inspections of the combined sewer mains
along 16th Street to assess the current condition of these lines. As a result of this
evaluation, JAR has recommended that the City of Atlanta remove sediment and
debris that currently reduces the capacity of these lines. The City of Atlanta
recently completed this action. As part of the redevelopment, JAR will be
providing a separate storm sewer line along the reconstructed 16th Street that will
handle storm drainage from Home Park streets, providing additional sanitary
sewer capacity in the existing line. These improvements should address current
infrastructure concerns with respect to potable water service, sanitary service, and
storm drainage/flooding issues along 16th Street and in Home Park.
53. Comment: Storm water and wastewater should be separated in the 5 03-acre Shoal
Creek catchment area. Stormwater detention should be provided on the Atlantic
Steel site for the entire Shoal Creek watershed.
Response: For purposes of this project, the sanitary sewer and stormwater
impacts are limited to the redevelopment site within the 503-acre catchment area.
The combined sewer issues and storm water runoff within the entire Shoal Creek
watershed were considered to be beyond the scope of this project. However, a
number of mitigative measures and corrective actions will be implemented to
address storm water runoff and combined sewer overflow issues for the entire
Shoal Creek catchment area.
The developer is required to provide an increased on-site stormwater detention
capacity of approximately 20% to assist the City of Atlanta in the management of
stormwater flows to the Tanyard Creek Combined Sewer Overflow (CSO)
Facility. Furthermore, the Hemphill Water Treatment Plant historically
contributed to surface water flows on the Atlantic Steel site, primarily from water
that was discharged as part of cleaning its on-site filters. Recently, the City of
Atlanta instituted a number of measures to recycle these flows. JAR is required to
provide separate stormwater and sanitary sewer facilities, with sanitary
connections directly to the Tanyard Creek Interceptor Sewer downstream of the
Tanyard Creek CSO Treatment Facility. The combined effect of the reduction of
other sources of surface water (Hemphill Water Treatment Plant), the requirement
for additional on-site detention, and separation of sanitary flows is anticipated to
improve operations at the Tanyard Creek CSO Treatment Facility.
Although the issues of control are being addressed for only the portion of the
Shoal Creek catchment area pertaining to the Atlantic Steel site, all of the
measures listed above represent a step in the positive direction for the entire Shoal
Creek catchment area.
22
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54. Comment: The EA fails to acknowledge the existence of water quality problems
in the City of Atlanta, and the impacts of this project on the City's ability to
address those problems.
Response: Permits and certifications for the project were based upon the best
available information. The issuance of the capacity certification letters by the
City of Atlanta are based upon projected site build out figures and sequence of
construction. The stormwater and wastewater flow volumes estimated by JAR in
the EA were based on the current redevelopment plan. Submittal of projected
flow volumes is a common permit practice for new developments.
The certification letters limit JAR to development that is consistent with the
parameters established in the certification letters. In addition, infrastructure
improvements on-site and in the Home Park and Loring Heights communities
funded by and constructed by JAR are an integral component in the City's
determination that the sanitary and storm sewer capacities will be available to
service the planned development. Discussions between JAR and the City are
ongoing and continuous. As the design activities continue to move forward, the
scope of detention pond design and required retention capacities will be
maintained and enforced by the City of Atlanta.
Stormwater runoff and combined sewer overflow issues are regulated under the
Georgia Municipal stormwater permit for the City of Atlanta, and the long term
control plans in the combined sewer overflow permits issued by the State. The
City of Atlanta is responsible for assuring: (1) that the project will comply with
the Federal Clean Water Act litigation; and (2) that the project will be constructed
in such a way as to guarantee the existence of sufficient water and sewage
capacity. By addressing the potential to generate significant pollutant loadings as
a result of redevelopment of the site, future impairments to the watershed should
be minimized.
55. Comment: Stormwater runoff laden with lead and other contaminants from the
National Smelting and Refining site should not be permitted to flow via any
piping system into Tanyard Creek.
Response: The EPA currently is conducting a removal action that will abate the
immediate threats posed by the National Smelting and Refinery site. Although
the final remedial solution for the site has not been determined, EPA will
implement the necessary stormwater runoff management and controls to limit off-
site migration of surface soil contaminants.
56. Comment: Provisions should be made to inform future commercial or residential
tenants of the redevelopment that both the Atlantic Steel site and the National
Smelting and Refining property were once Superfund sites.
Response: The Atlantic Steel site has never been listed as a Superfund site. The
conservation easement, which is the legal mechanism for ensuring future actions
comply with the approved remediation plan, is filed with the City of Atlanta and
Georgia EPD. This information is available from Georgia EPD, Hazardous Waste
Management Branch, or the City of Atlanta, Planning Department. Future
23
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purchasers of property in the redevelopment would be subject to this conservation
easement, under law. However, there is no legal obligation of future purchasers
to inform individual tenants of any information contained in the remediation plan
or conservation easement. This disclosure would be up to the discretion of each
purchaser.
The long-term remedial solution for the National Smelting and Refining site will
likely be conducted in accordance with the Superfund remedial program or the
State of Georgia Hazardous Site Response Act. Future public disclosures and
announcements related to site cleanup activities will follow all requirements of
these statutes and likely include press releases and periodic updates to the
surrounding community, including owners at the Atlantic Steel site.
57. Comment: The compensatory mitigation needs to be recomputed to account
realistically for the value of these wetlands to the community.
Response: A Nationwide Permit (NWP) 38 for fill of the on-site Waters of the
United States was applied for and authorized by the Savannah District, U.S. Army
Corps of Engineers (USACE). The NWP 38 allows activities to be completed in
wetlands that are required to effect the containment, stabilization, or removal of
hazardous or toxic wastes that are performed, ordered, or sponsored by a
government agency with established legal or regulatory authority. The
authorization of NWP 38 was due to the approval of the Remediation Plan by the
Georgia EPD. Mitigation for wetland impacts was calculated using the USACE's
Standard Operating Procedures for Compensatory Mitigation. The appropriate
mitigation credits were applied to an "in-lieu of fee" stream restoration mitigation
plan. Approval of the mitigation plan was coordinated with the EPA, U.S. Fish
and Wildlife Service, and Georgia EPD. Identification of appropriate stream
restoration sites included an evaluation of all surface waters in the Chattahoochee
watershed, including Tanyard Creek and Peachtree Creek. Candidate sites were
assessed based on their current condition, position and function in the watershed,
and potential for further degradation. In addition, extensive coordination with the
USACE, the City of Atlanta, and DeKalb County, specific to their needs related to
current restoration efforts and pending greenway acquisition projects, was
conducted as part of mitigation efforts.
58. Comment: What happens if the ultimate uses of the Atlantic Steel site change or if
transportation aspects of the project change? Is there a consequence imposed on
the developer?
Response: Four site design criteria and four transportation performance targets
are included in the final TCM rulemaking that would collectively ensure that the
redevelopment is designed and built with elements that encourage alternatives to
single occupancy vehicle trips, and that the project would perform in ways to
lower vehicle miles traveled and associated emissions. An enforceable, detailed
site design is not included in the TCM due to the complexity and duration of
build-out. Instead, the TCM contains site design criteria and target values that are
enforceable. As part of the TCM monitoring, JAR is required to submit copies of
the site plan, with revisions, to the City of Atlanta, ARC, Georgia EPD and EPA
annually after the bridge opens to traffic until the project is built-out. If the site
24
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design does not meet or exceed the target site design criteria, JAR must submit
and receive approval from the City of Atlanta, ARC, EPD, and EPA for a revised
final site plan that does.
The TCM also contains contingency measures that encourage more travelers to
use alternatives to single occupancy vehicles, should the monitoring program
conclude that the project is not meeting the transportation performance targets. If
the site is not meeting or exceeding the applicable performance targets, JAR
would identify funding or fund the creation of a Transportation Management
Association (TMA), if employers and property managers are not participating in a
TMA already. The TMA would consult with the City of Atlanta concerning
implementation of additional alternative transportation programs that achieve the
performance standards stipulated. The City of Atlanta and JAR would ensure that
these programs would be developed and implemented, as appropriate.
The City of Atlanta has established zoning conditions on the Atlantic Steel
property that require JAR to complete certain activities that are also related to
implementation of the TCM. Relevant conditions include: development and
appropriate phasing of residential and non-residential components of the project;
development of 17th Street as a mixed use street; construction of bicycle lanes;
creation of and maintenance of open space; incorporation of a transit connection
to the MARTA Arts Center station from the site; development of a transportation
management plan, including support for and participation in a TMA; and the
necessity of having the 17th Street Bridge under contract for construction before
building permits are issued for the site. These zoning conditions apply to JAR
and/or its successors. These conditions ensure that the site design maximizes
pedestrian and bicycle connectivity, transit connections, and activity diversity.
Before construction occurs, JAR is required to submit a site plan to the Bureau of
Buildings of the City of Atlanta for approval. Compliance with zoning conditions
is enforceable by law.
IV. REVISIONS TO THE ENVIRONMENTAL ASSESSMENT
After reviewing all the comments received by EPA on the Environmental
Assessment, only a few changes to the document were found to be needed. Therefore,
the Environmental Assessment is revised as follows:
1) Pg EX-3,2nd bullet - Replace text to read...
• Several communities in the project area expressed concerns about the traffic
increases resulting not only from this project, but from other new developments in
the area that are already occurring, or that would occur in the future. Based on
these concerns, a number of measures were developed. These measures include
design modifications, specific zoning and traffic monitoring commitments for the
Atlantic Steel site, and specific conditions or agreements between various public
and private entities and individual neighborhoods.
2) Pg vii, List of Appendices - Delete Appendix I and rename Appendix J as Appendix I.
3) Pg vii, List of Appendices - Add new Appendix J - Public Hearing Transcript.
25
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4) Pg vii, List of Appendices - Add new Appendix K - Public Comments on
Environmental Assessment.
5) Pg 4-27, Section 4.3.3.7, Measures for Addressing Community Traffic Concerns -
Replace entire text of section to read...
As part of the rezoning process for the Atlantic Steel site and public involvement for
this project, a number of citizens from the neighborhoods in the study area (Ansley Park,
Home Park, and Loring Heights) raised concerns about potential traffic impacts to their
communities resulting from the 17th Street Extension and Atlantic Steel redevelopment.
Through subsequent meetings with the City of Atlanta Neighborhood Planning Unit
(NPU-E) for this area, as well as individual meetings with the neighborhood civic
associations, a number of measures were developed to address these community
concerns. These measures are summarized below.
Design Modifications. Several design modifications were developed for the original
17th Street Concept based on direct input from the neighborhoods. The major design
modifications to the 17th Street Bridge and its transition into Midtown Atlanta, both east
and west of 1-75/1-85, were discussed in Section 4.3.3.1. In addition, three alternatives
were presented to the Loring Heights Neighborhood Association related to the design of
the intersection of Bishop Street and the proposed 17th Street. The neighborhood
discussed these alternatives with the adjacent commercial district along Bishop Street
and identified a preferred alternative. This design alternative was incorporated into the
latest design of this intersection.
Zoning Commitments. When the Atlantic Steel property was rezoned in 1998,
specific zoning conditions were included to address the surrounding neighborhoods'
concerns related to future traffic impacts. Condition 4 of the current zoning requires
JAR to work with the City of Atlanta and Home Park to limit cut-through traffic on
residential streets perpendicular to and south of 16th Street by means of cul-de-sacs,
speed humps, gates, control arms, and other traffic calming devices. JAR is also
required to work with the City of Atlanta and the Loring Heights neighborhood to limit
cut-through traffic on Bishop Street. In addition, Condition #23 of the current zoning
requires JAR to develop a transportation management plan that will attempt to reduce
single occupancy vehicle (SOV) trips to and from the site. Both of these conditions
represent enforceable measures on behalf of the City of Atlanta and JAR to work with
these adjacent neighborhoods to minimize traffic impacts in the future.
TCM Commitments. The Atlantic Steel TCM requires annual monitoring of the
build-out and performance of the Atlantic Steel site relative to certain site design and
transportation performance measures. The TCM contains four site design criteria and
four performance targets which will collectively ensure that the redevelopment is
designed and built with elements that encourage alternatives to SOV trips, and also that
the project will perform in ways to lower VMT and associated emissions (see Section
4.3.4.4).
Additional Neighborhood Commitments.
Home Park and Lorins Heishts. Atlantic Steel Brownfield Area and Tax Allocation
District Number Two (BATAD #2) was created to make possible the redevelopment of the
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Atlantic Steel site and encourage additional development on the perimeter of the
redevelopment area. More specifically, BATAD #2 promotes maximum use of alternative
transportation modes to minimize congestion and creates a financing tool for
transportation and other infrastructure to improve and connect major activity centers.
Since certain surface streets in the adjacent neighborhoods of Home Park and Loring
Heights are included in the boundary for BATAD #2, it provides a specific process and
dedicated funding source for the implementation of future transportation projects,
including potential traffic calming measures, in these areas. Therefore, if cut-through
traffic is determined to be excessive in Home Park or Loring Heights attributed to the
Atlantic Steel redevelopment or surrounding areas, appropriate BATAD #2 funds would
be utilized to study and implement measures to limit cut-through traffic. All monies and
expenditures would be managed by the Atlanta Development Authority and the City of
Atlanta. For any traffic calming measures that would require changes in traffic ingress
and egress at certain intersections, the City of Atlanta would provide temporary
barricades for an agreed upon trial period to determine the effects of eliminating (or
improving) access.
Specific to Loring Heights, two proposed transportation improvement projects have
been identified as part of discussions with the Loring Heights Neighborhood Association.
These are: 1) construction of an elevated pedestrian/bicycle bridge at Mecaslin Street,
and 2) widening of Bishop Street between Northside Drive and Howell Mill Road. The
City of Atlanta and JAR will continue to work with the Loring Heights neighborhood and
the adjacent commercial district to further these projects, as appropriate. As stated
above, it is anticipated that appropriate BATAD #2 funds would be utilized to study and
implement these projects.
Anslev Park. In response to concerns from the Ansley Park Civic Association
(APCA) and many citizens of the neighborhood about projected increases in traffic
volumes, a specific agreement has been entered into, by and between the APCA, GRTA,
GDOT, the City of Atlanta, and JAR. The purpose of this agreement is to establish a
mechanism for the continued study of traffic in Ansley Park as a result of the Atlantic
Steel Redevelopment project and other developments in the Midtown Atlanta area. The
agreement includes guaranteed financial commitments for the implementation of traffic
calming and control measures that are identified as a result of separate studies, both
internal and external to the Ansley Park neighborhood. The agreement has been duly
executed and constitutes a valid and binding agreement, enforceable in accordance with
the laws of the State of Georgia and in any court of competent jurisdiction. The specific
agreement with APCA in no way invalidates or supercedes existing commitments of the
City of Atlanta and the developer with the Home Park and Loring Heights neighborhoods
contained within the enforceable zoning conditions for the site and the established
BATAD #2 for the area, as described previously.
6) Pg 4-37, Section 4.3.6, Cultural Resources - Change title of section to
"Archaeological/Historic Resources".
7) Pg 4-38, Section 4.3.6, Archaeological/Historic Resources - Add a new paragraph
following the bulleted text to read...
In accordance with Section 106 of the National Historic Preservation Act, the
Georgia State Historic Preservation Office (SHPO) reviewed the EA, as well as
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supplementary documentation and correspondence, to determine the effect of this project
on historic properties. Based on this review, the Georgia SHPO concurred that the
project will have no adverse effect on the 15 historic architectural properties identified.
In addition, the SHPO concurred that there will be no adverse effect on historic
archaeological resources in the project's area of potential effects, conditioned upon
monitoring of construction activities along Hemphill Avenue and further consultation
with the SHPO should historic trolley tracks or water mains be discovered (see Appendix
D). The basis for these determinations is included in Sections 4.3.6.1 through 4.3.6.3.
8) Pg 4-59, Section 4.3.6.3, Measures Proposed to Address Cultural Resource Concerns -
Replace entire text of section to read...
During project construction, it is recommended that a qualified archaeological
consultant monitor any construction and subsurface activities that are to occur along
Northside Drive in the vicinity of Hemphill Avenue. Should the remains of either trolley
tracks or water pipes be located, the archaeological consultant should notify the SHPO
about the nature of the findings. Consultation with the SHPO and/or other interested
parties would occur to discuss further treatment measures. Documentation of these
resources would follow Georgia Historic Preservation Division and GDOT guidelines.
Impacts to historic properties in the study area associated with future transportation
improvements that could be proposed outside the scope of this project, but as part of the
agreement with APCA, as discussed in Section 4.3.3.7, are impossible to predict at this
time. However, several agency and public citizens, including the SHPO, the Georgia
Trust for Historic Preservation, the Atlanta Preservation Center, and citizens of Ansley
Park raised concerns related to potential impacts of future transportation improvements
to historic properties in Midtown. In recognition of these concerns, the City of Atlanta,
through the Atlanta Urban Design Commission, will take appropriate steps to insure that
historic properties that might be affected by any proposed transportation improvements
are taken into account at the earliest possible opportunity. This will include coordination
with the SHPO, the Georgia Trust for Historic Preservation, the Atlanta Preservation
Center, and APCA.
9) Pg 4-70, Traffic Impacts, 2nd paragraph - Replace text to read...
However, because of concerns raised by the surrounding neighborhoods related to
traffic impacts, a number of measures were developed to address these concerns. These
measures include design modifications, specific zoning and traffic monitoring
commitments for the Atlantic Steel Site, and specific conditions or agreements between
various public and private entities and individual neighborhoods. Based on these
commitments, no disproportionate adverse impacts associated with additional traffic are
anticipated to low-income or minority populations.
10) Pg 5-6, List of Acronyms - Delete MOU, Memorandum of Understanding.
11) Appendix D, Agency Correspondence - Add letter from W. Ray Luce, Historic
Preservation Division, Division Director and Deputy State Historic Preservation Officer
to Heinz J. Mueller, Chief, Office of Environmental Assessment, U.S. Environmental
Protection Agency.
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REVISED APPENDIX D
AGENCY CORRESPONDENCE
-------
C. Barrett, Commissioner
Georgia Department of Natural Resources
Historic Preservation Division
W. Ray Luce, Division Director and Deputy State Historic Preservation Officer
156 Trinity Avenue, S.W., Suite 101, Atlanta, Georgia 30303-3600
Telephone (404) 656-2840 Fax (404) 657-1040
www.gashpo.org
November 17, 2000
Heinz J. Mueller, Chief
Office of Environmental Assessment
U. S. Environmental Protection Agency, Region 4
Atlanta Federal Center
61 Forsyth Street
Atlanta, Georgia 303030-8960
re: 17th Street Extension (GDOT Project NH-7141-00(900), P. I. Number 714190) and
Atlantic Steel Redevelopment Project
Atlanta, Fulton County, Georgia
HP990810-010
Dear Mr. Mueller:
The Historic Preservation Division (HPD) has reviewed the following information
submitted by the Environmental Protection Agency regarding proposed 17th Street improvements
including a bridge over 1-75/85 and the Atlantic Steel site redevelopment in Atlanta, Fulton
County, Georgia:
"Environmental Assessment, 17th Street Extension [GDOT Project NH-7141-00(900),
P. I. Number 714190] and Atlantic Steel Redevelopment Project, Fulton County,
Georgia," prepared by the Environmental Protection Agency, August 2000;
"Historic Architectural Properties Identification and Evaluation for the Proposed 17th
Street Extension ... and the Atlantic Steel Redevelopment Project, Atlanta, Georgia/'
prepared for the Environmental Protection Agency by Parsons Engineering Science, May
2000;
"Archaeological Assessment of the Proposed I7lh Street Extension ... and the Atlantic
Steel Redevelopment Project, Atlanta, Georgia," prepared for the Environmental
Protection Agency by Parsons Engineering Science, May 2000;
Supplementary documentation regarding the National Register eligibility and boundaries
for the Siemens Westinghouse building at 1299 Northside Drive, Atlanta, Georgia,
prepared for the Environmental Protection Agency by Moreland Altobelli Associates,
Inc., July 25, 2000; and
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Letter to Heinz J. Mueller
November 17, 2000
Page 2
E-mail correspondence from Ben West, Environmental Protection Agency, to W. Ray
Luce and Richard Cloues of HPD, dated November 15, 2000, outlining additional
commitments for future traffic studies in the Ansley Park-Midtown area of Atlanta as part
of the Atlantic Steel redevelopment project which will be incorporated into Section
4.3.6.3 of the final Environmental Assessment.
Our comments, below, are offered to assist the Environmental Protection Agency in
complying with Section 106 of the National Historic Preservation Act.
1. We concur that the 15 historic architectural properties identified in Table 3-5, page 3-26,
of the August 2000 Environmental Assessment are eligible for or listed in the National
Register of Historic Places.
2. We concur that there are no archaeological resources other than possible trolley tracks
and water lines under Hemphill Avenue within the proposed project's area of potential
3. We concur that the proposed project will have no adverse effect to the 15 historic
architectural properties identified in the August 2000 Environmental Assessment.
4. We concur that there will be no adverse effect to historic archaeological resources in the
project's area of potential effects conditioned upon monitoring of construction activities
along Hemphill Avenue and further consultation with HPD should historic trolley tracks
or water mains be discovered, as proposed on pages 4-58, Sections 4.3.6.2. and 4.3.6.3, of
the August 2000 Environmental Assessment.
We look forward to continuing to work with the Environmental Protection Agency in the
planning and implementation of the proposed project to insure compliance with Section 106 of
the National Historic Preservation Act. If you have questions, please contact me directly at 404-
651-5983.
effects.
W. Ray Luce
Division Director,
Deputy State Historic Preservation Officer
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APPENDIX J
PUBLIC HEARING TRANSCRIPT
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DEPARTMENT O*" TRANSPORTATION
STATE OF GEORGIA
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
In re:
IT™ STREET EXTENSION
GDOT FROJECT NH-7141-00-(900)
P.I. No. 714190
and
ATLANTIC STEEL REDEVELOPMENT
FROJECT
l?CC
lo/njoo
Public hearing for the proposed 17' Street
Extension and Atlantic Steel Redevelopment
Project, Fulton County, Georgia same being hosted
by U.S. Environmental Protection Agency and
Georgia Department of Transportation, commencing
at 6:00 o'clock, p.m., September 12, 2000, 250
14th Street, N.W., Atlanta, Georgia, same being
reported by Howard E. Worley, Eleanor McShaw,
Certified Court Reporters.
WORLEY S ASSOCIATES
COURT REPORTERS
P.O. BOX 475 DECATUR, GEORGIA 30030
(404) 370—6239
. noi.ni'ivi :> iiy i , r. ::.i 1.¦, i
my company is Cily Realty advisors, 137!=> Spiuin
Street, 30300. I have three specific comments.
One. It seems to me we have not focused on
access to mid-town from Northside Drive and 1-75.
While the DOT plans to do extensive improvements at
Northside and Bishop, these improvements become
useless because Northside Drive has to be widened at
the 1—75 interchange. Currently an average of a
hundred cars are waiting at the stop sign, as thev
exit 1-75 south on to Northside Drive between 7:30 and
9:30 a.m., each business work day. This problem is
exacerbated by traffic trying to exit off of Howell
Hill on to 1—75 south.
It is very important that the DOT deal with
the Northside/I-75 interchange first.
Number 2. Any staging area used bv the DOT
that is not directly in the right of way should be
pulled back to the public within two years.
3. Please explain why there is a ten foot
t-lAKTA easement outside the proposed sidewalk between
Spring Street and West Peachtree.
Thank you very much.
MR BECK: .1 Beck, 95 Montgomery Ferry
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tly sii'iyost ion would I" the consider i rcvjl.i-'
oft of Peachtree Street that took cars from Peachtree
near the Jewish Synagogue back behind the PD Station
to Buford Highway in the same way there is a current
street that lets cars off of Buford Highway on to
Peachtree. They made that two-way or added another --
I don't know if it is north or a eastbound lane.
It seems to me it would alleviate a lot of
traffic problems on Peachtree Street of people
desiring to get to Buford Highway - 85 North -
Piedmont or Monroe. Currently there is an intersection
at Monroe and Armour near the area where I would
suggest this road come in -- where the road cuts and
where the traffic is to come up on to Peachtree. It
would seem if that is a two-way that could be created,
it could alleviate a lot of problems.
The other thing I wanted to say, this is my
concern of the neighborhood. I live in Ansley Park. Is
the traffic under this new proposed system and bridge
and all of the traffic being treated by this
development going to develop the traffic on the
streets in our neighborhood" And right now it is way
toe much traffic. It is dangerous fcr kids, animals,
anvthina. It is alreadv saturated. And this traffic
..ouWI put, £m.n-j I ') I iu< i l '(111 . .hi ' ') i'. i' ..
double the ttaffic. Thai 15 .> tcriible t'nuvj to me.
* 4
MS. LEVY: Valarie Hartman Levy, 120 The
Prado, N.W., Atlanta, 30309.
I am a resident of Ansley Park. I am
committed to ln-town living since I arrived in Atlanta
nine years ago, I have lived m-town. And I believe in
the importance and vibrant midtown community, which
includes development of the Atlantic Steel site.
I believe that has to be counter-balanced
with the ends and safety of the neighborhood in
midtown. And this is not an issue about the nth
Street product, it is about development _of multiple
projects in midtown and the concept of urban
development of multiple projects in midtown and the
concept of urban development. Now we are going to
address through street traffic and pollution. What is
bad now is only going to get worse, if we do address
i t now.
We need to have some reasonable solution so
you don't ruin the neighborhoods.
• *
MR. CARR: Steve Carr, 850 Mercer Street,
Atlanta.
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Tins brown f i c 1 is only partiall/ ..i
cleaned up and Hien covered with almost impet v i <>'t -
surfaces. Our ground water will simply never be
cleaned up from this site.
The City of Atlanta has mostly north—south
major transportation vehicle routes. We need more east
- west routes. The city of Atlanta and Metro Atlanta
needs more alternative transportation alternatives.
The City of Atlanta has had only one bicycle
transportation, one street route. We need your help
with this and other environmental matters.
Where are the other leadership and/or
programs. If Carol Browner and the EFA is in favor of
the bridge, then why are we having a public hearing?
Will the City of Atlanta be able to separate
the Orme sewer line before construction is started?
Will all storm water runoff from this site
either be reused, gray water for chillers,
landscaping or drained into the Howell Hill/Hemphill
Water reservoir or dedicated bac1: to the
Chattachoochee River7
What is the projected impervious surface at
project completion? Can most or all traffic signals be
times at the speed limit, both for this project and
for At 1 ant a
J
Can ' o Lie into Ami: i ai. - 'i't ¦ 1
Station and ArLs Center - MARTV (.".in wo Lie U'lo I.ho
Chattachooee Industrial area7
* 4
MR. ROGERS: Harrison L. Rogers, Jr., 2672
Battle overlook N.W., Atlanta 3032?.
I think that they need to be innovative as
we look at this project. A project that is so large,
has the potential for being so important for the City
and the region. Important not only to the potential
residents in this area of Atlantic Steel, but also for
the people in midtown who are here tonight to show
vocal opposition to the project.
. A suggestion that I saw described in the
Atlanta newspaper six months ago was so innovative and
so fresh with the idea and so seemingly practical that
I felt attention should be given to it before we get
this in concrete with the design of the bridge.
I would like to discuss the need to
transport people and vehicles from the east side of
the west side and vice versa by some means other than
a single bridge. Even a couple of bridges.
The project that was described in the
newspaper six months ago envisioned covering over the
expressway with a continuous bridge from nth Street
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I o • oL:*p?L nt t.iie HiLLnvji^, u >* 'jiiiw •• t-.v: •; > i
biid«je, planting grass, trees, a [ 11 «icl i \-e site Cor
everyone that passed by. In addition, it would provide
access* both major access and minor access, across the
expressway for transportation of all sorts, rails bus,
pedestrian.
We have in the midtown of Atlanta a very
large number of people today who have moved in the
last ten years, and we only have Piedmont Park which
is burdened today and will be more burdened tomorrow.
This would give the opportunity of having a larger
area for people to enjoy walking, to ride bicycles or
roller-blade or whatever they want to do. So we would
have the opportunity to provide better access, and in
addition a wonderful thing for the people of Atlanta.
And 1 would encourage, before we settle on a
firm design for a bridge or pair of bridges, that we
look seriously at this.
Thank you very much.
* *
MR. ALLEN: My name is Christian Allen. I
live at 1125 State Street, Northwest, Atlanta, 30318.
I am in favor of the proposed 17,h Street
bridge. I think it is a wonderful opportunity for
midtown Atlanta. I believe that it should run from
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i.'orlhc'ldo r;ti"P to rpjrhtrpp n'.ic-.'L in ot'lI"
alleviate Lraflin Muit nlre.idy exists on si u'oi .
I'm In favor of all of the Atlantic Stool
Redevelopment project. Thank yovi.
* *
MR. HUBERT: My name is Richard N. Hubert.
I am a lawyer and concerned citizen of the
City of Atlanta and live in the unincorporated area of
DeKalb County. I have reviewed the environmental
assessment and find it woefully inadequate in terms of
meeting the fundamental conditions of NEPA, Section
1(f) of the Department of Transportation Account.
Specifically, I am aware that we are in violation of
the Clean Air Act and under a court order that was
entered into by consent by the Georgia Department of
Transportation concerning air quality and non-
attainment of the ozone level in and around 13 county
areas where the City of Atlanta is located. We are
about to construct a bridge that will increase the
number of single vehicle automobiles and other
transportation vehicles by some seventy-three thousand
to a hundred thousand cars per day in this area. It
can not help but have a significant and profoundly
adverse impact on the air quality of this city and
particularly the neighborhood surrounding the J 7"'
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i <• ;i, p.-1 r !¦c"i1 11 1 ' "•
neii:M-M l»or>d -rind Pni(;}itr':'3 Slro^t.
I am also aware that there is presently
extant a federal court order that deals with the
noncompliance with the Clean Water Act in the Northern
District of Georgia that was signed by Judge Thomas
Thrasher sometime last year. I do net find anything in
the environmental assessment that indicates that the
court orders are complied with or there is pending any
motion or petition before the Court that would
authorize a project of this magnitude. It is therefor
my conclusion that the environmental assessment and
NEPA process is going forward without federal court
approval .
1 am also aware of the three s'tate compact
involving Alabama, Florida ahd Georgia dealing with
water allocation that has not been able to
successfully conclude any resolution of problems of
polluted water and the distribution of what they are
that might be used for growth and development within
the three states.
In spite of that fact, Mr. Norman Copeland
of tne City of Atlanta has approved this project for
the allocation of sewer capacity and water capacity
presently presumable with the full knowledge that
suriac? iHtoi run off from l.his djiii
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Cipoiii.i Tef.h Undent. I .ini oboul 1 - i : 1 >
lucent 1 / did a study on the redcvcK'.. tut -.1 idy on
this down zoning and redevelopment. of midtown, and in
ray study I included Atlantic Steel and midtown. In my
findings I was able to sell myself and also the
readers of the paper that Atlantic Steel is going to
be the catalyst that is going to cause Atlanta to
become the 24 hour city realize its potential. Also
that the density is essential for Atlanta to
revitalize its urban core and that density mind set
within the development will carry on, change the way
the people will think about living in the long term,
cause Atlanta to become a 24 hours city like its
American counterparts as Boston, D.C., San Francisco,
and it will bring more interest into Atlanta
internationally and nationally and change how people
see Atlanta as a city.
* •
MS. GOLDMAN: My name is Paula Goldman. I
live at BO park Lane in Ansley Park.
I have come to the hearing tonight to voice
my concern about the amount of traffic that is going
to be sent through our historic neighborhood by this
monumental project. I would like to ask that the
residents be considered in the planning and we be
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bridge so that I he tmffic i-. not funnclol into oui
neighborhood.
* A
MS. McFARLANE: Teresa K. McFarlane, 242 The
Prado Ado, Atlanta 30309, Ansley Park.
My comment is about the traffic coming over
the bridge eastbound that is dumping onto would
Peachtree Street which at the present moment is pretty
much blocked up from 1:30 in the morning to "7:30 at
night. And how is it going to accommodate any
additional traffic? On the street?
Also, point 2, the pedestrian lanes on the
n'1' Street bridge, they are walking over the downtown
connector which is a dirty, filthy, polluted smog
road. They have nothing to look at. Why would people
bother to use it as pedestrian lanes, obviously,
pedestrian lanes which will become car lanes down the
road?
» t
MR. MERLINO: John Merlino, 180 17th Street,
Atlanta 30309.
I guess what 1 would like to say is that
everyone, even Atlanta, is excited about this project,
but I guess we don't want to ruin an 80 year old
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will e; ply j pro]ccl lh.it is supposed to soe /O.COu
trips a day right in through a beautiful 80 year old
neighborhood and for anybody to believe that it won't
have an adverse effect on the neighborhood, I think
they are kidding themselves or they are trying to kid
us. I think there are things that can be done the make
the project more palatable, modifications to the
bridge, reducing its size and where it empties to. I
don't think it should get beyond Spring Street and
that somehow some exit or entrance to the nighway
should be considered. Otherwise it will simply become
the east west connector for Atlanta, Northside to
Morninaside. So I plead with the DOT and the powers
that be to reconsider the design of this bridge. And
that is all I have to say.
MS. HANSEN: Sarah Hansen, 176 Peachtree
Circle Northwest, Atlanta, Georgia, 30309.
I have lived in Ansley Park for almost 29
years. The traffic is as bad -- the volume of traffic
is as bad or worse now than it has ever been. The
pollution from the cars is so heavy that I have to
clean the windows on the front of my house around my
front door at least every month. Our sewers are
'.r 1 J -ips i ii'J uikIo l~ I hn o f 'ho I i".i I I •. .
Additional car.; i-puuivj into our iiO i'ihl:r i hood
will make all of these problems worse. Hp linve chosen
to live in the city because we love the city, but if
our old neighborhoods are destroyed by increased
traffic, no one will want to live in the city any
more.
« t
MS. BROKAW: Katherine Brokaw, 227 Peachtree
Circle, Atlanta, Georgia 30309.
I am a resident of Ansley Park which is one
of the Atlanta's national registered in town
neighborhoods. It has been listed on the National
Register of historic places for 25 years. It is a
wonderful, vibrant, diverse community filled with
pedestrians, children on bikes, grown-ups on roller
blades, people walking their dogs and people enjoying
a true community.
I believe that the nth Street bridge and
extension east as currently planned pose a severe
threat to the community life of my precious
neighborhood.
Ansley Park asks that there be no l"?th
Street extension east of Spring Street. We ask that
the public agencies do a full blown environmental
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* ;¦ r i.L .iUiLoim.m.L with specific icioreM-^ lo pi-*-. i i i
impact of tLaffic and air pollution on Ansle/ r.n1:. •>
want smart growth, not smog growth for ovjl* in— town
neighborhoods.
The Ansley neighborhood has bepn ignored in
the planning of this project. The EPA has overlooked
key features of our communities from parJ:s to the
neighborhood preschool. We all walked those places and
we need to be able to cross our streets an safety. The
EPA and the Georgia DOT should not be using our
taxpayer funds to destroy what has become a wonderful,
viable# urban community. Thank you.
*«
MS. WEDDELL: Sallie Weddell, 4J South Prado,
Atlanta.
I live in Ansley Park which will be affected
by the proposed 1 "71h Street bridge and want to state
my opposition to having the 17th Street bridge dump
traffic onto -- into Ansley Park. Ansley Park is a
historic neighborhood which has enjoyed 30 years of
urban renewal. My family and others moved in and
repaired and renovated old homes and cleaned up the
neighborhood, and not offer a very beautiful and
diverse neighborhood with public housing. We have
apartments. We have condominiums. We have historic
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; " • • r.u'. hy tins is fr.ir-l\ 1 ¦ • i. 1
. t-, • . -;ur -aiLipicion that H.are n<»v'r .vas »iny
in oiving it a reasonable and independent assessinr-rl
of the environmental impact of this, and this reeks of
what we have come to be used to, a partnership between
private developers and government in pushing through
projects that may not be in the public interest. I
personally will do everything possible to try to stop
this project, and I hope that our elected officials
within the State of Georgia and the federal government
will stop and listen to us and try to reevaluate how
this project will be developed.
*«
MR. LAMAR: Thomas Lamar, 176 Peachtree
Circle, Atlanta, Georgia 30309.
My statement is to put on record that
several of the officials at the EPA and the Department
of Transportation have stated that they have not taken
into account the excess weight load of cars when the
bridge from 17th Street connection across 75/85 is
implemented.
The weight impact over time will destroy the
trees of middle age and older age. These trees are
crucial to the protection of the air quality based on
the southern oxidant study performed at Georgia Tech,
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the connection between ',-h.idc on p an-1 In i')
the atmosphere combined with moio CF emissions ,mrl I he
natural burning of coal for electrical power plants in
the state of Georgia will continue to increase
negative impacts on the quality of life throughout the
state and surrounding regions if the green space,
trees, parks are not considered in the engineering of
traffic flow.
Ansley Park is on the National Historic
Register and has not been recognized as such in this
design process.
Old streets, old sewer lines, old trees will
all be damaged severely by the increased traffic if
the bridge is completed in its current design.
Last week a man was killed by a tree that
fell and hit him on the head He was an arborist. This
was in Ansley Park. The tree probably died due to
excessive weight load from greater traffic flow
through the park, Ansley Park. This should be on the
consciousness and on the' record before any further
design is contemplated.
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MR. HOHENSTEIN: Louis Hohenstein, 228 15 ''
Street, Ansley Park.
Member of the Ansley Park Civic Association,
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Iji-irr piPMilent rf the ns^ocii1ion, 1 viijjiv
3|-po.;o L11• bi id'j'.' lis lL is presenile .i:r.co 1 vcd. ap.l '
helieve the daLa are that EPA and DOT have core tip
with have been rigged to come to the conclusions they
want. If any bridge has been built, I think it should
stop at Spring Street and not go further east at
Spring Street.
MR. MAHON: William Mahon, 210 Little John
Trail, Atlanta 30309.
I just think that the bridge that dumps onto
Peachtree Street is very poorly thought out. I think
that it will ruin a number of our neighborhoods,
Sherwood Forest for one, and Ansley Park_.
I think DOT should consider the quality of
life in Atlanta, rather than just merely building
roads for the sake of building roads.
I'm going to keep this statement rather
short because I know other people want to speak If
the citizens in the area adversely against this bridge
revealed this mandate and put it through for the
benefit cf the real estate developers.
* *
MR. KIMBROUGH: Erich Kimbrough.
The first comment, the increase in the
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.iinoiu.t •:( traffic. Tim project ••¦ill -n.iJ-¦ ¦ [ .¦..¦rlil i ¦ ¦
undo irable. If you drive Poach! lee during ru.-h lion,
now, it is extremely backed up. The project to
increase traffic forty percent without changing the
street, that is the height of absurdity.
I am also upset that the 11th Street bridge
is changed in concept from what they originally got
approved in the zoning. What they plan to construct
today is much wider, encourages much more traffic than
what was originally approved, and should seek zoning
approval again.
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MS. KATHY YANTZ: I am State Representative
Kathy Yantz.
And tonight I --
(Applause)
MS. YANTZ: Let me first say thank you for
having this hearing. And thank you for DEFAX for
finding a way for me to have my say.
Tonight I asked EPA and all of the other
folks listening to hear from some of the folks 1 am
privileged to represent in the Georgia House.
By way of introduction of these folks who
are going to be speaking, let me be clear that the
the people who live in Ansley Park are urban voyeurs.
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MS. YANTZ: ..'o n.v«? • a decision 1 i
and to stay in the City. They recognized the
importance of development. But they also recognize the
significance of preserving our need.
And so I ask you to find ways that traffic
count, development and motorists can fully live and
can live together without making the quality of life
for these folks intolerable.
Thank you for hearing from us. Thank you.
for responding to this instance. We have a ways to go.
But I suggest we are going to get there.
Thank you.
(Applause)
«*
MS. WILLARD: I am Kathy Willard. I am
Atlanta City Council member. Transportation Committee.
I just wanted to say to everyone here that I
did hear the presentations made to the Atlanta City
Council, there will be portions of this project that
will come before my Committee.
I have two things to say. One is the tract
that two people remind me, the Atlanta City Council
web site. If you go there, we have a process where our
agenda is available before the Committee meetings or
Al-.i*, siw.nni!.-? won M (I'.nlnrl. :ny offl. i* '.'n.'n
the: e are changes roLntiv<_» M this siLl*, Jt i.onio3 to
my Committee.
I really like the citizens to come to my
Committee as often as possible, whenever there are
changes. But I would appreciate, as often as you feel
-- that as an opfn invitation to come so that the
people will have an opportunity to see that as often
as possible. This is a very sensitive issue and all of
the people to know what is going on with that. We have
very critical decisions to make.
So thank you very much.
* *
MS. HOLLAND: My name is Kris Holland and I
am the President of Atlanta Scientific Association
and I live on The Prado.
This is a historic neighborhood established
in 1901. A neighborhood that was reclaimed in the
1950s and '70s by some urban pioneers who staked out
more subdivisions. Many long time residents are here
tonight to support our neighborhood. Would you please
stand up?
It is a beautiful place, old trees and
sidewalks and we love to think in the City, and we
welcome new development But this project is
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. 11 I i • i . ..!»i i ' I i,<» An31 e / i\-»: '• Ar > i . ' • -
nppr<~vccl i n principal tho dove Icp^n! of tho 1. n
field into a lively work/play environment. Our issue
is the proposed 17th Street bridge and the inevitable
impact it will have on our historic neighborhood and
on the air we breathe. This is an 82 million dollar
project/ funded by public taxpayer money, and
specially designed to benefit this development.
There is no other development in midtown
that has this deal. This bridge is nothing but a huge
highway interchange. And even the most conservative
estimates show that 73,000 cars per day will be
generated by this project. And the environmental
assessment states that there will be no impact on the
people in Ansley Park. This document masquerades an
environmental assessment. It is riddled with paper.
EPA, where is the assessment analysis that is required
by law. This is unacceptable.
The retail portion alone at Atlantic Steel
is larger than Lenox Mall. And EPA states no impact.
We said we are staring down the barrel of a loaded
cannon, where that cannon is 134 feet wide and it is
filled with cars and smog. And no impact on Ansley
Park? A 134 foot wide bridge of 70 -- excuse me -- 83
million dollars of public money We have been
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l.ooiK'in-'-"I. isn't ;nui; It. a- » :
growth.
We nay no to more cars and no to more smog.
We say yes to protect a vibrant m-town historic
Ansley Park.
* *
MR. FARNHAM: Ladies and gentlemen, I am
Clint Farnham.
My wife Kitty ana I raised our family on
Drive and Inman Circle. We are among the newer
in the neighborhood. We didn't qet there until
Why we came here. We saw the times of the
James Palsey, Phillip Alston, Deveareux
McClatchy, James Sibley, Julia Martin, people who
suffer and mate. And there was always somebody --
somebody had a building, somebody had a gas tank,
somebody had an apartment house. They had to deal. We
were supposed to eat it.
Well, with those giants ir. their time, we
didn't eat it. And that is why we have it today. When
we arrived, the new giants were on the scene. Tom Beck
and Tom McGuire, people iike that. Gladys down at the
City Council, wanted to get these people that we are
dealing with each time, that we were supposed to eat.
Sewell
people
1968 .
t imes,
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, .1 COt. n nr ' c I, J. M- 1 - .'I •' :-l . 1
is I. ho i.Ji' il.e POT in li.e .i •jio'.l'.'i1 :J. iro ro'i' -
- and they are pointed slr.nghl out -- over theie with
the traffic flow of massive proportions that Chris
just told you about.
Ladies and gentlemen, it is our turn. It is
our turn. It is our turn to face this massive project
that has come at us without one single soul of
consideration of any professional traffic evaluatcr,
urban planner demeanor, that has not been beholden to
one of the parties, what is the deal?
And that the dear old neighborhood, the
giants that they are trying to put forth, to decide
for us. Ladies and gentlemen, you are ao_ing to near
the petitioners. This is a weak project. It has normal
abilities. It can be had. If you stay together, zoning
and planning people, we can be the people of our
times. It is ours to keep for our solution.
« *
MR. HUBERT: Thank you, Mr. Chairman. I'm
Richard Hubert. I represent the Ansley Park Civic
Association. And I live in Atlanta, DeKaib County,
and I practice law for a living.
I would say, Mr. Chairman# on this occasion
to be charitable, that the key aid that has been
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ic.ilirj r»up'?r f ic i .i 5 I i ^ '
~ \ i . n \ oflects ate, *. •¦» .il? I ! I ii ' '• c-
Court Orders as to our failure to comply in the past,
but we also have a totally experimental project here
to try out for the first time on the City of Atlanta
mid-town area, and specifically the Anslt-y Park Civic
Association. And I suggest, Mr. Chairman, that that
might be subject to challenge. It certainly indicates
that we ought not to be the guinea pig in terms of how
we live and how we exist in this community.
We are also led that there is water problems
in this area. I read with interest Mr. Copeland's
incredible statement as to how we could provide water
quality and meet the compliance requirements in the
EA. I suggest to you that there has been a compact of
three states, and we attempt to avoid a Supreme Court
decision on those areas, and they talk in grave terms
about the effect of water quality on this State and
its existence as well as our surrounding states.
And yet, with some sort of back of the hand
motion of compliance, Mr. Copeland says, oh, we can
supply us with water, in an area that has been
contaminated for lo these many years by grounds of
contamination, that is the founder of that -- of the
surface water and the containment policy of the EPA's
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supi.to'-'Uly i o f.lorin up tliM j i1 o .
Mr. ChaiLmnn, it i •> mil contention thnt th?
analysis that has been done under the Clean Air Act
has been the subject matter of our comments. And when
we commented on it, we showed in graphic detail I
think, the fact there has been a neglect of
determining what the hot spots of oh, no, will be. We
have shown that you have not considered what the
retail traffic counts will be in terms of, that you
have used as your mode}, the traffic count on 1-75/95.
And the process is flawed beyond repair.
Therefore, if I am asked by my clients, in
terms of this proceeding, I would say to them that I
think that we are being set up for what I call the
push dance steps of the EPA once again. They will
issue the EA. They will approve it. And we will be the
subject of a finding, a finding of no significant
impact.
I believe that you should be aware of the
fact that if that happens, we shall entertain the
prospect of a Federal lawsuit. And in terms of that,
we will not hang back from suggesting that what this
tract needs is a full blown EIS.
This is not just idle talk. They have raised
the mcney. They have hired me to do it. I am no
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i: ti o ¦ to tliOFe !:hm! of .*u:t ions . I will not .• ¦. .>
Lo lol ! you. And if the Agency is supposed lo 1 lie
Environmental Protection Agency, as it calls itselE,
you had better be environmenta exception agency as you
are performing here. That you will make sure that we
don't have to go to Court and it is not necessary.
I come with an olive branch, Mr. Chairman,
but 1 can tell you that with this studi here, we will
not be able to consummate any kind of this study here,
we will not be able to consummate any kind of
arrangement with this community and the problems that
we are confronted with here.
1 thank you for the opportunity.
MR. CcCLURE: My name is Gene McClure, ladies
and gentlemen, and 1 am a resident of 52 Gold Circle,
Atlanta in the historic Ansley Park District.
And as a member and resident of the Ansley
Park Civic Association, I am here to state that the
Ansley neighborhood and other mid-town neighborhoods
are now threatened with massive highway traffic
directed through our neighborhoods the Georgia DOT'S
proposed 17th Street bridge.
About a hundred years ago, that great robber
baron, J. P. Morgan said remember when somebody
propose Lometliin'j, Ihoie ai o always l.wo ro,i
ijooa reason and the real reason.
Now, ladies and gentlemen, tonight we are
going to hear what the real reason why 100,000 traffic
cars a day will be directed into mid-town
neighborhoods.
Our massive highway traffic directed us from
this nth Street bridge is going to show you the real
reason. This is the boondoggle bridge, because this is
the way the DOT officials hope to obtain more highway
funds from the federal government to pave more asphalt
in Atlanta which will create more smog and pollution
in mid-town.
This is the greatest threat to our mid-town
neighborhoods in more than thirty years. What type of
property development could we support which creates
smog, pollution and more than 100,000 new car trips
through this area, How will we ever handle if No
wonder the Mayor of Jacksonville is laughing at
Atlanta. And no wonder that Atlanta has taken over the
embarrassing spot of Number 1 in the nation for the
worst pollution and smog of any major metropolitan
area.
It is ludicrous to suggest or to think that
we would believe that there is no significant from a
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major bridge and road con->l met 1011 in th'.>
neighborhood. A bridge the size, sufficient to span
the Missisippi river -- if you have ever seen the
bridge from Memphis, Tennessee into Arkansas, you have
an idea of what is going to be placed into the
residential neighborhoods and into tiie midtown
business area of this community. What an unbelievable,
unworkable, unmanageable nightmare this would be. I
wonder, with this much money being involved, how do
the people of our State from all over the rural areas
of Georgia feel about an eighty to one hundred
million dollar boondoggle bridge being built in
Atlanta to help aid a private developer's project.
Now, we are pleased that a contaminated
brown field could be reclaimed, particularly if it
were a mixed use residential, work play environment in
the middle of our city. But we are not excited about
having something that is three times the size of the
Mall of Georgia supported by Spaghetti Junction to
ruin the beautiful, existing midtown neighborhoods
that are the back drop for the growth, stability and
vitality of this area.
Ladies and gentlemen, we must come to our
senses. We must use thoughtfulness in dealing with
this matter. Surely some elected official of our
Slato, our Lfvji s loUire, our city or some por.'-on rho i .
thoughtful at EPA, Georgia DOT, or the Governor's
Regional Transportation Authority will see this
situation as an opportunity to preserve neighborhoods
while promoting what could be a successful urban
redevelopment that is environmentally sound.
Let's work together and make that happen and
stop this boondoggle bridge.
* *
MR. PAXTON: Good evening. I am Greg Paxton,
President of the Attorney General Trust Resoiirce
Preservation. Just for the record, I live in Ansley
Park and I work across the street.
Georgia Trust is not objecting to the
development of the Atlantic Steel property, even
though it is already involved in the demolition of a
dozen buildings eligible for the National Register of
Historic Places. We aren't here tonight to discuss
that issue. But this demolition is cause for extra
care on the part of the project in the rest of this
area in avoiding impacts on other historic resources.
The environmental assessment prepared for
this project states, quote: "Implementation of the
proposed project would increase the amount of traffic
on most of the entrances into Ansley Park and
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rrri'hi i ln> " l?nt inexplicably i "i. !-i ; - li
there is no adverse i ipnct on Ansley Pork Historic.
District.
This is inconsistent with 4-F provisions of
the National Transportation Account and EA should be
amended to state that there is adverse effect on the
Ansley Park Historic District.
To mitigate this effect, the Georgia Trust
proposes the following changes external to Ansley Par);
Historic District.
First of all, oper. up on southbound Buford
Highway Extension exit currently onto Peachtree Road
North, that exit at that end of the old Equifax
Building, now IXL, remove the right turn only barrier
so that cars can go either north or soufh on Peachtree
from that exit as they used to do.
At that end of the Buford Highway Extension
South, at the corner where Rhodes South intersect
Peachtree Street, just south of Rhodes Hall, allow a
similar right turn only onto Peachtree Street. Remove
it from one place and put it on the other. Heading
south into midtown but not allowing traffic to go
straight across into Ansley Park.
Thirdly, on 17lh Street southbound, coming
off of the bridge, improve signage at West Peachtree
3J
Street, to encourage use of U'.iford lliqhiMy Extension lo
get to Monroe Drive and West Peachtree Street. And
northbound -- further northbound on Buford Highway
Extension, build a slip-lane exit onto Monroe Drive
that comes up opposite the Red Cross building to
funnel east -- west traffic directly onto Monroe and
avoid the neighborhood altogether.
Fourthly. On eastbound 17 !j Street at the
intersection of Peachtree Street, permit a right turn
only. This will deflect the traffic coming off of the
bridge away from Ansley Park once again.
The Georgia Trust supports the Ansley Park
Civic Association's request for planning funding and
funding to complement mitigation within -the
neighborhood as part of this.project, which will be
determined at the time the study is completed, and to
have a seat at the table in deciding on and
implementing these measures.
Finally, the context of this project. There
is no outlet for east and westbound traffic, in Atlanta
between 10,h Street and Monroe.
North-south, there is two pairs of one-way
streets, Spring and West Peachtree and Juniper and
Piedmont. And one two-way streets, Peachtree Street
south of Ansley Park. But if you pursue north, these
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f i \ o _1.Le.jl3 i:v.-ii"=o 1 nl.ite by 01 I'-'.il' An.'.lo, 1 u
Historic District into only two less efficient t..o-Wii/
streets, Peachtree and Piedmont.
If historic flow-through neighborhoods are
to remain stable, substantial introduction of new cars
into these areas must be avoided. Historic
neighborhoods with multiple entrance and exits act
like a wetland filtering cars through. It is
inappropriate to build a culvert that directly dumps
cars into a flow-through neighborhood, thereby making
its residents threatened species.
In conclusion, if the Atlantic Steel Project
development undermines the stability of Ansley Park
Historic District, the net gain for Atlanta will be
dramatically diminished. We urge the development of
mitigation measures that will allow successful
development of this project while minimizing the
negative effects on midtown Ansley Park for a totally
positive net gain.
Thank you.
4 «
MR. WEDDELL: Mr. Chairman, I appreciate the
opportunity to be heard. My name is Bruce Weddell. I
live at 41 South Prado.
I have lived in Ansley Park for almost a
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til'i'l i: f i c • 111 'ii '/ I .in I In: p-v^L |>l i:s : < 1 111 ot I lif
Ar.slijy Park Civic Association. I have been on the
Board of Directors for over a decade. I have served on
the Ansley Park Beautification Foundation.
And I come to you to endorse what has been
stated already, in opposition to the planning process
that we have seen.
Frequently when the situation developes as
we have seen it, there is an embarrassing silence when
people ask for a named plaintiff, one who is
definitely interested and definitely attached there,
one who has a stance.
The Ansley Park Civic Association has a
tnamed plaintiff.
* *
MR. JONES: Mr. Chairman, my name is Milton
Jones.
I am a resident of Ansley Park and live on
Peachtree Circle. I am a relatively new resident to
the area. But I am certainly not a new resident to the
City of Atlanta. I have seen a lot of progress happen.
I have supported a lot of progress. And like my
neighbors, support continued progress for the City.
But progress is an interesting thing.
Progress requires balance. What seems to be missing
ifi
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Ii.mo i1: :!¦,! C'111~mi l1 W-> i' 'V J .! i-
re'...i' l-i-rii; ' I .llnin h'.itri , viL'i
Iraditions for growth and development and for
weathering the storm.
Be we have got a hurricane coming in t way
of this bridge. As a neighborhood, as we look at the
information that would have seen, as I have looked at
the charts tonight and had conversation, there are
several questions come to mind.
Number 1 is a design that calls for multi-
modal use of the bridge. There has been no written
guarantee to protect against what happens if there is
no funding to cause the rapid transit piece or the
transit piece to happen and to cause the bridge to be
nine lanes for automobiles, or eight lanes for
automobiles. That is a major concern.
Secondly, there is discussion but no
funding. And discussion without funding is
meaningless. So there has been funding made necessary
to Ansley Park to implement any changes of any studies
that were spoken to in the documents that you have
handed, to have studies without funding means that we
are left with no ability to take action.
Third, in earlier documents there was
promises made regarding tax allocation district
UHuiiii'J Tor acvin m- lohborhoo' !¦>. Tli.it 1m-, n-i i i'.-n
in I lio lusloiy in Un" Instoiy "f I h.il i nn -I: > I i I 7
of Georgia. It is a hollow promise.
Fourth. The traffic projections inadequately
considers a surface flood of traffic through Historic
Ansley Park and lessor developed areas to this new
development. And that is a major concern.
Fifth. And I quote from your document handed
out tonight. 'Traffic conditions on some roadways and
intersections in the study area are predicted to
worsen with implementation of the project, as compared
to the no action alternative." Again, that is a direct
quote. This is why there should be no 17'h Street
extension east of Spring Street in order to protect
Ansley Park roadways from these abominable outcomes.
And then at last, the memorandum of
understanding that you refer to, to address community
concerns is meaningless without specific commitment of
funds to Ansley Park and other affected neighborhoods
to implement changes to overcome these concerns and
issues now and in the future.
Thank you.
* i
MR. GUBERMAN: Sidney Guberman, a resident of
Ansley Park.
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When our Repi nsental i vc, Kali', ^ in or
i.nl.cicd the building tliij evening with her sim,;,
was told that no signs were allowed inside the
bu ildi ng
I understand that this project is wroth
millions and millions of dollars, not only to the
developers and to the owners, but to our servants, the
Georgia Department of Transportation. They have
forgotten whose servants they are
Four years ago when this post-warrant boom
was seeking in said the cars has got to be
controlled. That hasn't happened. But at least the
automobile has been rained in almost every day, but
not in Atlanta.
The 17"1 bridge is planning a monstrosity.
And it is altogether inappropriate as part of in-town
Atlanta, where almost magically has a scale of human
and at the same time accommodating the several office
buildings or travel circuits.
The City of Atlanta has concerns that the
existing City of Atlanta sewer lines and treatment
facilities are right at capacity
So, that is all I have got to say. I think
it is a bad idea. And I think that many of the people
who are establishing are trying to screw us.
39
MR. COWART: l-ly nnmo is Lawrence Cowa r L . I
live at 18 Park Lane in Ansley Park. I am a member of
the Ansley Park Civic Association.
I have been a resident of Ansley Park for
thirty years. Longer than some, not as long as many.
Ansley Park is a beautiful place. I suggest
you go look at it. And the reason it is a beautiful
place is because of the people in this room.
And it started forty years ago, recovering a
neighborhood that was deteriorating very rapidly. And
made it into one of the prettiest neighborhoods, and
most beautiful living places in the city of Atlanta.
And the reason it is, is because you people
fought, and we have fought and we will continue to
fight, because without fighting for the things we have
prepared and preserved to make this a neighborhood,
all of the work in the last 31 years would be gone --
and to decrease something unusually beautiful in this
part of the City, I think it would destroy something.
And my message is very simple. I would hate
to say that this project would not have any impact on
Ansley Park defies common sense. I don't see how they
can stand up and say it will have no impact on this
beautiful neighborhood.
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1.1 VI1' '.Oil.
MS. BIGGIN'S: My name is Veronica Higginos. 1
am a member of the Ansley Park Civic association. My
husband Franklin and I live in Peachtree Circle
between 16 h and 17th Street.
I love looking at this map that you have
mounted, because you have a number -- you have used,
what, eight, nine lanes that ends nowhere. Where they
end and what happens is in my back yard. It concerns
me greatly.
There are certaint things that come to mind.
Afterthought. I think that Ansley Park is an
afterthought. It became an un-huh. When we as a
neighborhood raised our hand and said what? We are
here.
Blue skies is another term that comes to
mind. For those of us who live in the City, it becomes
rare for us to see blue skies.
Another thing that comes to mind is respect.
As a community, I think we pay a lot of money when it
comes to taxes. When I think about the EPA and what we
do, when I think about the Department of
Transportation, and I think about where their salaries
come from, I think about the amount of money that we
41
put in l:ho pool I luii. ijons lo-j.inl Mini /\i>l I joul.l ,
you to respect lis as a community, to rn-.poi L Lli-i r.u I
that it would be very hard for us to take our
children, as we walk our dogs every day -- as I look
at the traffic that is increasing now as I try to back
out of my driveway which has become almost an
impossible process.
Say you respect us and give strong
consideration to where you are in your proposal in
thinking about the fact as a neighborhood, we have
been there and continue to be there, and we have --
we are not going any place. So I would ask you to not
allow -- to respect the blue skies and to respect us
as individuals.
Thank you.
« 4
MR. EVINS: Hello. 1 am John Evins. I live at
1211 Barnes Street in Home park.
I am not necessarily one of you all, but I
certainly empathize with what you are saying.
1 am a walker. I love to walk in cities. I
think it is a beautiful city to walk. I.wish the
sidewalks were a bit wider.
And which brings to mind the plan that we
are seeing tonight. It seems to have been a monster
42
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from what I had originally heard from the developers
for Atlantic Steel. And it seemed like, there was so
much discussion about current activity, which I
thought was a really nice work, because we are
beginning to be more connective.
But the manner in which we are connecting,
the plan seems to be disintegrating more than
connecting, in the sense that we are giving lip
service to transportation and transit alternatives,
but giving red carpet to the cars.
We don't have any more reason for cars. If
we have more lanes, we have more cars to put them. We
are just going to be run over by cars, really. I "am a - ¦
wa 1 ker.
I also drive my car too. But I do it with a
little bit of restraint. At least I plan my day to do
that. And I think it is possible for all of us in this
room, including those people who want to use this
facility, can also do the same thing.
Thank you.
* 4
MS. JIUNTA: My name is Jennifer Jiunta, and
we live in Inman Circle. We have been coming to Ansley
Pari. -- we have been here about five years.
] tivrii in rn Hi' "in tli
I
of our City, was people and not just amount of cars.
It was built for pedestrians to live and work and play
in this family. It is not something that we feel the
planners did for us.
I have a degree in design. And I have -- I
have been professionally a designer for fifteen years.
The design I am looking at we are not followd. Make
it more workable.
Thank you.
* *
MS. FLOCKS: Sally Flocks, PEDS. PEDS is a
non-profit organization dedicated to making metro
Atlanta safe and accessible to all pedestrians. And it
was anything to say I am very excited about this
access that this bridge will provide to a walkable
mixed use community. I think this project is very
sizeable and I don't want us to forget that.
I have a few concerns, however, about
safety. One is the concern seems to be limited to
speed of 35 miles an hour. The Georgia DOT has said
that having a higher designed speed will Increase
safety because it creates a longer sigh distance or
longer line of sight. What they are forgetting is tha
when we drive faster our field of vision shrinks. Yet
vhfMi yrt'.i rrc «*¦*• low-i : |i"f( , von '.on wid'*
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circle and you see the surrounding area, including the
sidewalk and the optical band. When you are going this
side, you see nothing but the land ahead and maybe a
tiny fragment on the lanes on either side.
Since this is a transportation control
measure, we need to get special concerns about the
safety of the pedestrians and the bicyclists. And you
won't be giving that with a design speed of 35.
In addition, studies show that if a
pedestrian is hit by a motorist traveling 20 miles an
hour, the risk of death is just five percent. If they
are hit when a driver is going thirty, the risk of
death is forty-five percent. And if the driver is'
going forty, the risk of death is eighty percent - I
am sorry, eighty-five percent.
This safety issue needs to be addressed on
the bridge by reducing the design speed. In addition,
we have a speeding issue in Ansley Park that needs to
be addressed. I think this increase in traffic from
this is inevitable, but I think there is much that can
be done to mitigate the speed and reduce the speed.
And I think that funding needs to be dedicated or
traffic count in an area-wide way.
] don'I agree with the neighborhood about
the- hpnefits of rl'-Finc the traffic "i.i ' ] V fl S'.if'-jL,
because then it will just all flow onto Beverly and
Peachtree Circle. But I do think it is critical that
you prepare for it to flow throughout the
neighborhood. Because traffic is like devil, you are
going to fill up whatever opening is available. And we
need to be prepared with area-wide traffic counting
that is funded by the DOT.
Thank you.
* *
MR. BARRY- My name is Rogers Barry. And I am the
vice—president of the Ansley Park Civic Association. I
reside at 19 Maddox Drive, and I have been for the
past several years one of the representatives from
Ansley Park at our neighborhood planning.
I have also been, until just recently, vice-
chair of NTD.
This has been a very long process. I
certainly have been involved in it from the beginning.
But there was this big flaw at the beginning.
And I want to put it on record. Mr. West and
I have discussed this before, but at the beginning of
the process when EPA hired, 1 believe EPD, Clark Gable
to manage this address. I had to beg to get into the
meetings. And 1 was not alJoved to participate. J was
a 1 I cn "nd I n o! i vf.
K-
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And at that time I spoke with Ms. Bless and
others who were present, and including the developer
and other consultants. And I said, on your map at that
time, the subject area stopped at Peachtree Street.
Now it goes to Peachtree Circle.
So at that time, 1 informed you that the
world didn't end at Peachtree Street, and that you
were making a very, very huge mistake by not including
Ansley Park in the beginning.
Since that time, all of the parties have
closed guns to understand that the noise that was
coming out of Ansley Park was not just in incoupel?)
and that it was real. What 1 am saying here tonight
is this isn't the end of environment assrssment.
We are at the beginning. And what I wish to
inform I have to serve and represent my neighborhood.
And none of the parties, none of the potential
conveyors of any kind of memorandum or belief should
for one moment not only underestimate my community's
resolve to defend itself and to, you know, look after
in a fair way and consider there, but that we will do
it forever.
« *
MS. ADAMS: I am Sharon Adams. My husband A1
and I live at 56 Westminster Drive in Ansley Park. We
47
have been residents of the park for fifteen years.
What I have to say may be largely
reiterative of what already has been said, but my
experience this evening leads me here to the
microphone.
I came into the room next door and walked up
to the chart and invest myself in a discussion between
a young woman and a DOT representative talking about
the effect of, the bridge on 17th street traffic. And
his comment to her was that it was hoped that traffic
would use West Peachtree. And she was commenting that,
the fact that it would proceed east on 17th Street to
Peachtree Street. And I then suggest that it wouldn't
stop at Peachtree Street, but might flovT through
Ansley Park. And also that there was an enormous
amount of traffic to be expected to turn through from
Piedmont to Peachtree. It happens now. There.is no
reason to think that it wouldn't continue to happen in
ever larger numbers.
Ultimately, he conceded that the traffic in
Ansley would be increased. But if I understood him
correctly, his comment was that it would not be
unacceptable under current DOT standards as applied to
urban streets.
My thought at the time, and I think I made
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a comment to him, that those streets were designed in
the urban present century when traffic was light and
slow. Anybody who lives there now knows that it is not
light any more. Those streets are abused now by people
who cut through speeding.
I don't expect people to stop coming through
Ansley without reconfiguration of those streets in a
•way that I don't think will ever happen. But I do
¦expect c6aperation despite DOT, to come up with a
traffic plan that implements other ways to access --
for east-west access, and provide funding, and the
tools where the people in Ansley Park could protect
themselves. And say that the flow will be acceptable
or not unacceptable, I think -- I feel insulted both
personally and as a member of the Ansley Park Civic
Association.
Thank you.
4 •
DR. ROGERS; I am Harrison Rogers. And I am
not a resident of Ansley Park. I am a Board Member of
the Atlanta Medical Heritage that owns Academy of
Medicine on West Peachtree Street below the Biltimore.
I am a member of the First Presbyterian Church that
sits on Peachtree at 16th. I am an Atlanta citizen and
I pay taxes to the City.
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I have heard several things tonight. First
of all, I heard that we are looking for the best
possible gateway bridge for this property. I have also
heard the need for east-west traffic solutions, from
the project to the rest of the City. I heard the
requirement for a mechanism to minimize a traffic dump
or drop on Peachtree Street directly into Ansley Park.
I have heard for a need to consider the esthetic needs
of all of our new and old citizens of midtown.
And this is an important area. We are all
aware of the tremendous growth of midtown that is
going on today and the needs of these for more help.
I feel that there is possibly an innovative
approach, an innovative solution to thes.p deeds. And I
would suggest that you seriously consider, cover the
expressway with a continuous bridge from 17th Street to
5th Street, cover it with dirt, plant grass, plant
trees, and have a wonderful park in this area. Have
places for those folks in midtown to walk and play and
send their children to play. This could be a great
thing. It could open all of the streets, all of the
crosc streets, minor and major from east to west. No
problem at all. You could have them as wide or as
narrow as you need.
And you talked about a best possible gateway
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bridge. Can you imagine a better gateway bridge than a
park in the center of the City of Atlanta under which
all of the traffic flows.
Thank you.
4 *
MR. HAILES: Brian Hailes. I live in the
Prado.
I was going to talk numbers. I don't believe
in giving numbers. I think that is incorrect.
In the light of what was said earlier maybe
it is best to talk in generalities -- how to make
points. I think it is time to put me on the table.
But, now, we have heard the passion and determination
of these residents of Ansley Park. And this is not
relevant to the function and specialty of the EPA and
the DOT.
But there are two contingencies that we are
concerned about. The politicians who have ground field
recollection forget. And the developers who have
millions of dollars involved.
Now, earlier on, we heard how Ansley was
reclaimed from the drug dealers and motorcycle gangs
of the 1960s. Well, today, Ansley Park neighborhood is
doctors and dentists, accountants, teachers, bankers.
There is more lawyers than you can shake a
51
stick at. So guess what? It is the preliminary way.
So it's not our intention to kill the brown
hill project and cost the developers hundreds of-
millions of dollars. You have been there longer than
the politicians and the developers. And if necessary,
you will accost the politicians and brown hill
developers. And it will cost the developer hundreds o
millions of dollars.
So, to me, it is very simple. Maybe it is
time for these people to get smart. Sit down at the
table, cut a deal that meets the needs of the
residents of Ansley Park and then everyone will be
happy. We will be able to protect our beloved
neighborhood in-town and the politicians will have
their proud recognition, and the developers will thei
hundreds of millions of dollars invested. If not, I
think everyone is specifically in danger and that is
just my way of thinking.
» *
MS. HAMMOND: My name is Jane Hammond. I
would like to speak this evening on behalf of the
Atlantians For In-town Neighbors. It is a group
consisting of residents from thirteen neighborhoods
across the City. It makes the alliance of Ansley Pari
28 Home Park, midtown, Morningside, Lenox Park,
52
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Northside and Piedmont Park, Ridgedale Park, Sherwood
Forrest, Virginia Highlands, Kirkuood and Garden
Hills. And this-is a neighborhood for lo, many, many
thousands of votes.
The Alliance actually is opposed to the 17th
Street bridge because it uses a historical area as a
dumping ground for traffic. We are not against the
development of the Atlantic Steel project. We want the
EPA, the developers, the City and State officials to
realize that the established neighborhoods in the
midtown area are vital to the success of this project.
We have been here safeguarding this midtown
and twenty-four hour community for close to a hundred
years. The viable neighborhood in the in-town plays a
huge part in the storm of development that is taking
place in this area of town.
The Atlantic Steel project would not be here
if we were not here. Now, this type of plan can lead
to the destruction of Ansley Park and other midtown
neighborhoods. The neighborhood sees this as a notice
of precedent setting for developing in their
community. So we have voted to stand together to
oppose the bridge as it is currently proposed.
Officially, the signs, the placards and the opponents,
and the way it ends at Peachtree Street where it is
53
pouring some thousand of cars into all of the
neighborhoods, and let me respect that, all of the
neighborhoods in midtown.
Maynard Jackson said that neighborhoods are
the crown jewels of Atlanta. You may not enjoy,this.
* 4
MR. LAMAR: My name is Tom Lamar. And 1 am
about to be a resident of Ansley Park. I represent my
family and others in Atlanta who have multiple
interests in this project.
The first thing I noticed is that no one
this evening, not the DOT, not the EPS, has mentioned
or discussed the notion of this environment. There is
no discussion at all about trees. There is no
discussion at all about parks.
I moved to a beautiful City that is
concerned about its environment. And has great impact
on our great nation. I believe that when I asked the
question, could any DOT engineer or EPA official, have
you taken into account the impact of the loads of cars
that should increased when the cars were brought into
the area. They say the cars still weight the same. And
that is unbelievable uneducated answer to a very blunt
issue.
Sewer lines. That is the environment. Back-
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ups, broken lines, costs, dig up the streets, tree
roots don't exist only where the truck hits the
ground. They go out a lot, depending on the height of
the tree. Impact of traffic on roads where beautiful
trees that cover the asphalt, and keep it cooler.
Protest the air quality.
The southern oxygen program performed at
Georgia Tech, founded by the United States government,
pushing Georgia Tech, Number 1 air quality study about
parks this year, shows that the problem with our great
air ~ f.ty in the State of Georgia is coal burning
power plants and automotive emission, combined with
loss of trees. Remove the trees and you add asphalt.
You increase the heat. And so on and so forth. It is
not in the study.
This is the beginning. Thank you for
including us in the early stages of this design
process. It is very clear that the one sketch that we
saw, which is missing any many lines and many
thoughts, is the beginning.
Thank you for letting us be here.
* 4
MR. BROWN: I Am Lake Brown, a fifteen year
resident of Ansley Park.
I think the Atlantic Steel project is
55
wonderful. It Is going to be -- do much for Atlanta
in the long run. It also must share the downsize as
well by taking increase in traffic.
The Ansley Park Civic Association, is
proposing that traffic be stopped at 17th Street and be
routed in a different direction. They also say that
traffic should be allowed on Peachtree Circle. The
traffic is going to get to Highlands, the other side
of town some way. And also in Ansley Park, the problem
is on Ansley Park. Unfortunately, I think that has to
be utilized more. Again, departure from fillers,
Utilizing more 4-way stops. The traffic can be slowed
rapidly through Ansley Park and have to stop every
couple of streets.
Thank you very much.
* +
MR. BRITTAIN: My name is Nancy Brittain.
And I have lived in Ansley Park for 32
years. I have raised my children there. And what a joy
it has been to live in downtown Atlanta. And thanks to
the people who have worked so hard for us over the
years, because I tell you, my kids were able to walk
in the park and without worry about getting hit by
cars.
Bless your hearts, those of you who are
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there now, I want to see your kids. You have got so
many people already coming through the neighborhoods.
And we all know what this weird bridge is going to do
in the future to us If we don't do something.
I would ask that a traffic expert be hired
by the development company and next door, about why
there would be an exit from 75-85 to this new
development, but there would be no entrance back onto
the expressway.
And I am reminded of an old commercial on
television several years ago. You remember the Roach
Motel. The bugs could get check in but they couldn't
check out. Well, 1 am afraid that is what have got,
because we have got to find a way to get to work. That
is only 75-85. We can't get to work.
* *
MR. RUDDERMAN: My name is Randy Rudderman. I
live with my wife on Irunan Circle.
And we are not opposed to progress, new jobs
and certainly not development. My concern regarding
the project is based on the day that it now becomes
self-validated. In terms of value, it has enormous
potential for revisionary development but it has yet
to demonstrate this to anybody.
You know, examine your own data. The date
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that you have got out there. And your average annual
dally traffic flow. And we all talk about the traffic
that they are talking about, Peachtree going north,
Peachtree going south. Their own data states the
northbound traffic after the bridge, going in front of
Rhodes Hall and Peachtree, is going to be left of the
bridge. Right in there. The southbound traffic on
Peachtree in front of Symphony Hall and Colony Square
will be left of the bridge.
I asked four of the officials from DOT
tonight if they believed this. And not a single one of
them could respond. Mr. Chairman, you expect us to
take you at your word, that your own people don*t
believe your own data.
We also heard that excessive plans to the
plans that are, you know, great vision for our
future. Now, we are opposed to plans based on
conclusions, based on various data that we were given.
Thank you.
* *
MR. KOBLENTZ: Michael Koblentz. I live in
the NPU West Loring Heights.
A few years back I attempted to gain a
consensus among the NEPU E neighborhoods to develop a
position regarding the Atlantic Steel Redevelopment.
-------
And after many meetings and negotiations with the
developers, I sponsored and the NPU passed by an eight
to zero vote, which included Ansley Park I might add.
A resolution which included many conditions to support
the redevelopment of Atlantic Steel.
One neighborhood, Home Park, abstained on
the vote. However, later on, because of the input and
support of Home park, the project evolved into a more
urban oriented mixed use site which would be woven in
a far greater way with their own neighborhood.
In the last year or two, a revisionist view
of history has emerged which would make one thing
that neighborhoods were somehow left out of the
process. I was at the first meeting held on this
project with the most adjacent neighborhoods, Loring
Heights and Home Park, as well as Georgia Tech. And 1
can attest four years or so later, that neighborhood
input was not only sought but most of the conditions
adopted, including the 17,h Street bridge, were put
into the final documents as a result of negotiations
between the neighborhood and the developer.
In fact, as an eight year and longest
serving member of the Not Planning Unit E, and with
scores of projects and developers which have come
online in the last few years, particularly in midtown,
59
no developer has been more forthright and negotiable
than the Atlantic Steel Developers led by Charlie
Brown. I have seen the good ones and the bad ones, and
many over the years have had no regard for the
surrounding community. Some have been openly hostile
of neighborhood impact -- input. Some have attempted
to avoid the process and their shoddy and
inappropriate buildings and developments are their
lasting legacy to Atlanta.
In the last few years, some of us have
created a third way of looking at development in
Atlanta. Instead of the note in my neighborhood
approach of some cities and neighborhoods, and the
growth at.any cost of others, we have attempted to
promote the balanced projects which mix sound and
smart land use with profitability. Particularly as a
result of both NPU E, the vigilance of the Midtown
Neighborhood Association and the foresight of the
Midtown Alliance, growth has been planned with a
purpose. Pedestrian friendly buildings, mixed use,
green space, have been some of the prerequisites of
most plans. As a result, midtown has become midtown.
There are two questions that have to be
asked of growth; will it be smart growth and will the
burden of the projects be equally distributed? This
60
-------
leads me back to Atlantic Steel.
This site has been legacted for many years,
and growth was going to come one way or another. My
feeling is that the project is sound and the burden is
equally distributed. We take a hit in Loring Heights
as a result of the l"7th Street bridge. There may be
some excessive traffic coming into the neighborhood.
However, we feel that the 17th Street bridges relieves
10th and 14th Streets which are bottlenecked and are
used all of the time by our residents.
We don't know definitely how it will all
play out. There are no certainties. The point is the
growth had to happen. This was a developer we could do
business with. It will no longer be an environmental
eyesore. And we as a neighborhood are willing to take
some risk for the greater good of the project. Yes,
there are no hundred percent guarantees on traffic,
but overall we are looking at a net plus.
We feel that other neighborhoods should
share this attitude. Some risk, yes, but let's look at
the big picture. And there are safeguards and
something called good will and trust that has
developed between the neighborhoods, most of them, and
the developers that if something unforeseen appears
will be dealt with. We have the assurance from the
61
City and we will hold them accountable and we will
sign the memorandum of understanding.
Atlantic Steel, now Atlantic Station, can be
a model of in-town growth and a firm and clear
statement against a sprawl. Let's get on with the
show. No more delays.
* *
MS. PETERS: In the interest of time I will
just make a short statement. I am in the real estate
business. And I am sure it must be great to get eight
million dollars in public funding for one developer.
* *
MR. DEDEMADAS: I am Peter Dedemadas --
VOICES: Can't hear you.
MR. DEDEMADAS: I am Peter Dedemadas. I own
some property at Northside Drive and Bishop. This
project will increase the ground, not for me, not for
you, all of the people -- (inaudible).
I say one thing. You are good people. But
some people -- (inaudible)
Thank you very much. Thank you.
* t
MS. KLENI30RT: Good evening. My name is
Marcia Klenbort, and I am here as a citizen of
Atlanta.
62
-------
I happen to live in Ansley Park. But I am
very aware that our neighborhood is just one of the
neighborhoods being impacted. And I would like to
speak to several of the proposed ideas, that I think
are voicing a disaster to the entire city.
We cannot stand a new major mall at the
Atlantic Steel site. I do not know to accept whether
this is a done deal or whether the deals have been
made, but we cannot stand a mall, which cars and
traffic like malls do. We can't stand the traffic that
the mall will bring. And whether it comes off on this
dreadful 17th Street or whether it gets to use some
other way. We simply cannot stand this traffic.
We could stand non—automobile alternatives.
And all of us have got to figure out some way that we
are going to make plans for the City that do not
depend on us each getting one person, one at a time,
in automobiles. It is just going to kill us all.
We can't stand the terrible air quality that
we know from this traffic, by, very hopeful, after
tonight, because I think that perhaps the best part
about this meeting is that the Atlanta people have
found each other, and even though there should been
presence in the most outspoken spokesperson in this
group, I believe that the neighborhoods and that all
of the citizens in Atlanta were concerned about these
things.
I wrote a letter to the EPA on July 14,
1999. And I will read a slight bit of it. As far as I
can understand all of my letter of objections did was
to get me on the mailing list, so I have gotten
alcohol other of things that I cannot understand in
the mail from the EPA.
I wrote in this letter that the purpose of
developers and development is to make money. The
purpose of residential neighborhoods, once we get our
own families cared for, is the be the collective
bowler that preserves the City. The purpose of the EPA
is to protect City residents and institutions that
already exist from the irretrievable erosion which
destroy needs and developments in the City itself.
Thank you.
* *
MR. HOFFARTH: I am Dennis Hoffarth. 1 am the
Executive Director of the Atlanta Bicycle Campaign. We
work in the ten county region, but we are situated in
the City and we like living in the City.
I am not a resident of Ansley Park. But I am
thinking about moving there. It sounds like a nice
place to live. I do live in a inner city neighborhood
64
-------
and we are reclaiming some of that. But 1 think that
it is so important that any project you develop with
some sort of vision, not well, maybe put it this
way; One environmental hero of mine once said: You
can't do one thing. In other words, you have one thing
in mind but you have lots of side effects that could
be affected here.
One of the things you need to stand pat on
in this City Is that we will protect the inner City
neighborhoods. Probably the thing that has had the
most impact in inner City neighborhoods over the years
is transportation projects. So I hope that -- frankly,
I was not aware of some of these issues before the
meetings. Like you had the protest table out there.
But I certainly heard some things that give me pause
as far as making sure we address some of these
neighborhood issues when the project is built.
At the same time, we have a lot of folks
with disability. And an exemplary example project
especially internally and how it affects the
transportation for the future. To give an example of
how we can do the inner city and urban project that
will encourage other options. The City is totally
lacking in that. This could be the harbinger if it is
done right and protect the inner city neighborhoods
at the same time.
Someone said earlier that this was an
experiment. And you felt really -- you can't prove
that It is going to have the problem resulting as far
as traffic that you guys are claiming.
Some of the concerns we have from the
bicycle campaign is that it doesn't seem to be loaded
with those position things that are cutting edge and
on the slope for us for what can be done as far as --
I don't think it includes some things that other
Cities are already doing.
So we are talking with the developer and we
would like to make sure that EPA is aware of all of
the options that are available are maximizing the use
of transit, of bicycles and walking.
Those are our hopes of getting people out of
these cars. Some carpooling. But by and large that is
going to be the answer.
I have got a couple of little specific
things for bicycle lanes. And then I will submit
written comments by letter. The 14,h Street bridge, you
are building a brand new bridge that is not going to
be replaced for at least another eighty years. That is
the average. It has got to have bicycle lanes
included. If you don't have it on there now, please
fir,
-------
add it.
We like the idea -- this is the first time
we are going to see it in the Atlanta area, shared bus
and bike lanes. I was just up in Philadelphia and they
are doing it there. It is looking great. I wasn't too
sure. But that is going to be a very innovative idea
that could be, helpfully spread through more of the
City over the years.
Of course, we support that, as well as the
trails being built as part of the project to encourage
people to use their bicycle. And let's be reminded
that bicycling and walking also help keep people alive
and healthy. And transit, if we don't have this
connection, bicycling and walking to the transit, it
won't be used. So we need to make all of these
connections.
In that respect, I would like to see us look
at bike racks on the busses that are going to be used.
And it will just provide a much larger capture area
for those that want to ride bicycles, to get to the
bus.
Internally, bicycle parking. We need more
detail on that. We need more encouragement for
businesses to actually work with their employees to
not bring their cars into Ansley Park or anywhere
67
else. Don't bring into the City, If you can come in by
some other way. And encourage -- provide those
incentives to the employers and the land owners —
the landlords, whoever is providing property, there
are very frugal ways to do that. And we need to do
these state of the arc on this for this project to be
trusted and this project to go forward and really show
a great thing.
Thank you.
* *
MR. LOTT: My name is Michael Lott. And I was
living in west midtown for ten years.
And I am going to say, 1 am a little
confused by the attitude of a lot of people here
tonight. And let me just bring up a few things that,
the way I perceive things.
You have a ground kill. You have an area
that had no trees. A factory -- toxic waste, slowly
seeping into our soil, contaminating our
neighborhoods.
And the government and a private industry
has agreed to come together and clean it up. That
seems like a great thing. Not only that, they are
going to put in a development which will provide
grocery -- hopefully a grocery store, hopefully other
fi8
-------
things that will serve our community as well as an
entertainment destination.
Now, this is the thing that people -- I live
on the south end towards downtown. And the downtown
neighborhood, they have been clamoring for this kind
of development downtown. Build small, light
developments downtown. I don't understand what the
problem is. You are getting what we wished for.
Now, you have the great development here and
integrated well into Oak Park and Lonng Heights and
into West Midtown where I live, the other side of
Northside. Reclaim the neighborhood. And then it would
be in great shape for us.
. Now, the bridge. You are saying, well, maybe
that is okay for those people over there. But I don't
believe in the nexus for all of that. So what makes a
good City. When I was in Georgia Tech, going through
the architecture program, what needed to be studied
was City planning — which Georgia city did we look at
when we looked at good state planning? So it wasn't
Atlanta. It was Savannah.
Why Savannah? What makes most great major
cities? Not walls, not barriers, not divisions
between, but connections. We need to get from one
place to the other, one neighborhood next to the other
neighborhood. It seems like your neighborhood wants to
be a cul de sac. You want to be a Post Apartment
Complex. It seems like if you just put up a little
gate at every entrance, and that would solve it.
And some of us -- one part of the city to
the next part of the city witho9ut having to hedge tne
highway to get to one place from the other. I like to
walk down streets and go from one place to the other.
This bridge will help you walk, it will you fight, it
will help you get around. It won't help me drive
through your neighborhood to get to something on the
other side.
Most people now -- most people that I have
ever talked to don't even know how to get through
Ansley Park. There will be mutiny. So I wish that you
would look at Atlanta's legacy of building bypasses.
So named, as the new roads that have been planned,
there were roads over time -- dividing the interest
and about keeping people from getting one place to to
other, through the "60s, we were notorious of putting
inroads to divide white neighborhoods from black
neighborhoods, dividing poor neighborhoods from
affluent neighborhoods. People would go so far as to
put roadblocks in the middle of the road. They
wouldn't live in the same area as the other guys.
70
-------
That seems what you guys -- like what you
guys are trying to do. You are too good to be part of
our side of town. All I am saying is let's connect
downtown, be a city, a community, not a cul de sac.
Thank you.
* *
MR.ROSS: Thank you for allowing me to speak.
My name is Jeff Ross. I live in Home Park. And my
concern about this project is that, I wanted to -- I
wonder if anyone knew about the Atlantic Steel Project
when it was in operation. It was the largest producer
of airborne carcinogens in its day. It has been shut
down for some time now. But those products are still
in the soil.
And -- excuse me. I didn't prepare for this.
But I was noticing my window sills getting very dirty
lately. And I am sure that these parcels are not the
cleanest in the world. And I wanted the EPA to make
sure method of keeping that site watered down while
they are doing this destruction, is important, and it
is not merely setting a set of standards in an office
building.
Thank you.
(Public hearing concluded)
71
CERTIFICATE
GEORGIA
FULTON COUNTY
The within and foregoing Public Hearing was
taken before me as stated in the caption, and the
same was reduced to writing by the undersigned.
I further certify the within and foregoing
pages 1 through 71 constitutes a true, correct
and complete transcript of the proceedings as
recorded by the undersigned in the within
captioned matter.
I further certify I am neither-of kin nor
counsel to any of the parties, nor in anyway
interested in the out come of said case.
This 6th day of October, 2000.
£ !
HOWARD E. WORtEY, CERTIFIED COURT REPORTER
Certificate A-2 - RPR - CM
-------
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To. Ben Wast/FM/USEPA/US
cc John Hankmaon/R4/USEPA/US. Kitzman Jim^epamail apa gov.
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Uia(&anileypirk.com To Ben West/R4/USEPA/US
00/22/2000 04 SO PM
cc.
Sub)ect 17th street bridge
Mr Ben West
United Stales Environmental Protection Agency
Atlanta Federal Center
61 Forsyth Street. S.W.
Atlanta, Georgia 30303
He. Projecl NH7141 00(900) Fullon County
GDOTPI No 714190
17th Street Bridge Irom West Peactitree Street to Northslde Orive
Dear Mr West
As a director ol Ansley Park's Civic Association and a Ansley Park
Traffic Committee member, I'm wnting in opposition lo the infrastructure
proposals in the Concept Report.
We've been woiking on ways lo Keep our neighborhood safe in regards to
traffic The 1 7th street bridge as It Is now designed will impact our
neighborhood greatly.
We are an intown, elegant, historic neighborhood designed around large
common spaces conducive to biking .walking and visillng your neighbors. Many
ol us walh to the library, the museum, to the Ans Center, to church and our
children to preschool. A number ol residents watt to work In mldtown or
lake Marta at the Arts Center. (Nol exactly the norm in Atlanta) This is
very similar to what the Atlanta Sleel Project Is trying lo accomplish. An
Increase in traffic will change the dynamics of this unique neighborhood.
Ansley Park already suffers from Increasing cut-through traffic and
speeding, but nol lo Ihe extent It will In the hilure. Millions ol square
feet ol development are under construction or are proposed lor the area
surrounding Ansley Park By far Ihe largest Is Ihe Atlantic Steel project.
Although I applaud your effort9 to clean up a brownlleld site and lo help
create a live-work community. I cannot support your efforts II It encourages
more traffic to travel through our historic residential neighborhood In an
effort to escape the congestion predicted to occur on surrounding surface
streets
f applaud your efforts to create an intown walk/live community but I cannot
support the bridge In ihe design il is now.
Sincerely.
Lisa Cannon Taylor
10 Inman Circle
Atlanta, GA 30309
404 872 8132
Il8a@ansl8ypark.com
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CHAMBERLAIN, HRDLICKA, WHITE, WILLIAMS & MARTIN
A PAftTHIflSHIP Of PMOPCttlONAL CORPORATION•
ATTORNIVI AT LAW
itt piachtrii >TM«rr n c • ninth ploon
_ HOUSTON
ATLANTA, OSOROIA 30303 1747
ATLANTA
WCMMOM Ml*CM 14041 ese 1410 4SOO) 800-074B SAVANNAH
^wJL iH»
FAX 14041 090-1693
September 22.2000
Via Hand Delivery «nd Facsimile No. 404-562-9598
Mr. Ben West
Office of EAD
United States Environmental Protection Agency
Atlanta Federal Center
61 Forsyth Street, S.W.
Atlanta, Georgia 30303
Re: Environmental Assessment 17th Street Extension
and Atlantic Steel Redevelopment Project, Fulton County, Georgia
(vj Dear Mr. West:
I write on behalf of the Ansley Park Civic Association ("APCA") which represents
1,300 households in the historic Ansley Park neighborhood. We have reviewed the above
Environmental Assessment dated August 2000 (the "EA"). This letter addresses the EA and the
deficiencies we believe must be addressed before the IT* Street extension and Atlantic Steel
redevelopment (the "Project") proceeds. Our review of the EA indicates that a number of serious
issues have not yet been addressed in analyzing and disclosing the environmental impacts of this
Project. Further the EA fails to analyze the cumulative environmental impacts of other transportation
proposals for this area, such as the proposed ramp connecting 1 -75 to 1-85 and proposals for HOV
access to the midtown area. As a result, this letter discusses only the most serious deficiencies of
the EA. We reserve the right to provide further comments at a future date.
The National Environmental Policy Act of 1969 ("NEPA") places upon each federal
agency "the obligation to consider every significant aspect of the environmental impact of a
proposed action and to inform the public that it has considered the environmental concerns in its
decision-making process." Baltimore Gas and Electric v. Natural Resources Defense Council, 462
U.S. 87,97,103 S.Ct. 2246,2252, 76 L.Ed. 2d. 437,446-447 (1983). NEPA also authorizes and
directed "that, to the fullest extent possible ... the policy regulation and public laws of the United
States shall be interpreted and administered in accordance with the national environmental policy
declared in NEPA." 42 U.S.C. § 4332(1). Additionally, federal agencies in compliance with the
policy of NEPA are required to prepare "a detailed statement" for "every recommendation or report
on proposals for legislation and other major Federal actions significantly affecting the quality of the
human environment." 42 U.S.C. § 4332(2)(C). Federal agencies are enjoined lo comply with the
Mr. Ben West
Office of EAD
United States Environmental Protection Agency
September 22, 2000
Page 2
procedural requirements of the Act "to the fullest extent possible." An Environmental Impact
Statement ("EIS") is the "action-force" mechanism of NEPA. Robertson v Methow Valley Citizens
Council. 490 U.S. 332 109 S.Ct. 1835, 1844, 104 L.Ed. 2d. 351 (1989). The Supreme Court in its
analysis has commented that an EIS serves two distinct purposes. It "insures that the agency, in
reaching its decision will have available and will carefully consider detail information concerning
significant environmental impact and guarantees that the relevant information will be made available
to the larger audience that may also play a role in both the decision-making process and the
implementation of that decision." Id 109 S.Ct. at 1845. Thus, APCA firmly believes that an EIS
will be required in as much as the Project involves $82 million of public funds and will create an
estimated 72,000 new automobile trips a day lo and from the proposed Project. It also requires
construction of an 8-lane roadway and bridge connecting the Atlantic Steel site to Midtown Atlanta
and the MARTA station. APCA, based on the facts set forth below, urges the Environmental
Protection Agency ("EPA") to undertake through independent contractors a full-blown EIS based
on the statement regarding the types of projects that justify an EIS as set forth in 23 CFR 771.115.
That regulation suggests that a four-lane federal highway is a development which would normally
require an EIS.
Aside from the mandates of NEPA and the regulations, APCA draws the agency's
attention to the fact that there is currently pending a settlement agreement and ongoing litigation
between Georgians for Transportation Alternatives, the Georgia Conservancy and the Sierra Club
claims against Wayne Shackleford and other federal agencies in civil action 99CV0160 in the United
States District Court for the Northern District of Georgia. That lawsuit challenges decisions made
by the defendants to adopt, approve funds, or assist certain highway projects in 13 counties in the
Atlanta metropolitan area on the grounds that the decisions violate, among others, Section 106(c)
of the Clean Air Act, 42 U.S.C. §7506 and NEPA 42 U.S.C. §§ 4321 -4370(d) Plaintiffs sought an
order enjoining defendants from taking any steps lo adopt, approve funds or assist the highway
projects that are attached as Exhibit "A" to the settlement agreement. The construction of the
proposed 17th Street Bridge Project would clearly fall within the purview of the type of projects that
are subject to the injunction that is enforced in the GTA v. Shackleford litigation
Further, APCA is aware of pending litigation in the Northern District of Georgia
involving the City of Atlanta and the Clean Water Act which has been the subject matter of
numerous fines and noncompliance orders issued by that court involving metro Atlanta's polluted
rivers and streams. It is obvious that existence of that lawsuit carries with it potential jurisdiction
over surface water/storm water and sewage problems that arise from the cleanup and development
of the Atlantic Steel site. The existence of these lawsuits involving the Clean Air Act and the Clean
Water Act, themselves, would dictate a fuller exploration of the impacts that might occur in
development of this Project.
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Mr. Ben West
Office of EAD
United States Environmental Protection Agency
September 22,2000
Page 3
Finally, and most importantly, before turning to the specific omissions and errors in
the analysis of this particular Project, we would suggest that the EA itself acknowledges that the
proposed development would in fact violate existing federal air pollution standards, and under
normal circumstances (i.e., but for the application of a project XL designation as an exception and
experimental solution to this problem) would be a bar to building the types of roads and bridges
contemplated by the 17th Street Bridge Extension. The EPA has acknowledged that it has "never
evaluated a project of this size and complexity as a transportation control measure." (Transportation
Control Measure is hereafter referred to as "TCM.") Thus, the current Project would not, under
normal circumstances, receive federal approval. The application of Project XL and the TCM
designation represent a unique circumstance that requires a full environmental impact statement be
issued in this case.
The material omissions from and specific errors in the analysis included in the EA
identified below demonstrate that the requirements for a detailed statement of the environmental
impacts of the Project set out in NEPA have not been met. Further, given its scope in terms of size,
cost, location in an urban area and potential environmental impacts, this Project presents a clear case
for a full and complete EIS. As presented, this EA does not present a rational basis to support an
administrative finding of no significant impact (FONSI) that would permit this Project to proceed.
The principal concerns of the APCA with the EA are as follows:
1. The EA FaUs to Acknowledge the Existence of Air Quality Problems In the Atlanta
Metropolitan Region and Active Litigation Challenging the Current ReglonalTransportatlon
Plan.
The existence of 72,000 new car trips a day to and from the mix-use development proposed
for the Atlantic Steel site abound with problems that are not addressed in the EA and which are
directly inconsistent with and contradictory to the Consent Order entered in the case of GTA v.
Shackleford, 99CV-0160, Northern District of Georgia. This lawsuit eliminated certain "grandfather
projects" identified in the interim Atlanta Regional Transportation Improvement Program as adopted
by the Atlanta Regional Commission on January 28, 1998. Pursuant to the opinion, only 17 projects
which were being constructed were approved for further construction. All other projects identified
in Exhibit "B" were denied advance or approved funding for construction during the period that the
Atlanta metropolitan region "remains in a conformity lapse as that term is used in connection with
the Clean Air Act and its implementing regulations." The court order also prohibits right-of-way
acquisition or additional right-of-way condemnation where there has not been a written offer already
accepted and further prohibits Federal Aid Highway and Transit Funds from being used or approved
for reimbursement for projects that are being designed in the Atlanta region until elimination of its
conformity lapse.
Mr. Ben West
Office of EAD
United States Environmental Protection Agency
September 11, 2000
Page 4
The District of Columbia Circuit Court decision attached and incorporated into the GTA v
Shackleford opinion contains under the Design and Right-of-Way Acquisition Projects the following
language:
Design and right-of-way acquisitions for exempt
projects contained in 40 CFR 93.126 and 93.127 and
TCMs in an approved SIP may continue. This
includes engineering and design activities that are
necessary to assess social, economic and
environmental effects of the proposed actions or
alternatives as part of the NEPA process. However,
as noted above, we cannot complete the NEPA
process (I e., approve a CE, FONSI, or FE1S) until the
area has established conformity. Even projects
previously found to conform and had completed the
NEPA will not be advanced in non attainment and
maintenance areas which do not have a currently
conforming plan and transportation improvement
program. Thus, the only projects which can receive
further approval or grants during a plan and TIP
conformity lapse are (I) projects exempted from the
conformity process, (2) transportation control
measures (TCMs) which are included in an approved
state implementation plan (SIP).
The compliance or noncompliance of this Project with this portion of the federal Clean Air
lawsuit is not discussed in the EA in any fashion except to state that the EPA has never evaluated
a project of this size and complexity as a TCM. EPA also has admitted it is using an innovative (/. t,
experimental) approach to approve the entire Project as a TCM. The analysis in the EA focuses on
access to the Atlantic Steel Site and does not deal with questions of direct traffic flow into the
historic Ansley Park neighborhood or the through-traffic that will affect the area with the attendant
air quality and smog problems that will be created. In approving the TCM before the EA process
is concluded, the entire process is turned on its head and renders this exercise superfluous.
In spite of the Federal Court action that eliminated grandfathering and required a cessation
of funding for all the projects in the affected area throughout the 13 county non attainment of North
Georgia, the EA states that "no significant short-term construction air quality impacts or long-term
traffic-related air quality impacts are anticipated. Such bold assertions, without an analysis based
on objective data as has been shown in previous comments by APCA, become a mere declaration
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Mr. Ben West
Office of EAD
United States Environmental Protection Agency
September 22, 2000
Page 5
of preference and flaccid apology for EPA prediction. The EA itself, in section 2.3, slates that "the
entire Atlantic Steel re-development would attract new automobile trips and result in new emissions.
Therefore, redevelopment of the site when considered in isolation would not qualify as a TCM in
the traditional sense." Thus, in order to justify what is otherwise a project that would violate EPA
standards and court orders, the EA engages in a "stretch analysis" which requires the reader to
engage in the suspension of willing disbelief and accept the site location alternatives set forth in
Figure 2.1. There is not justification for such an analysis and assumption except in result in the
predetermined conclusion that this Project must be built.
APCA has formed the decided opinion and conclusion that based on factual data set forth in
the EA and the lack of attentiveness of the EPA representatives at the public hearing, that this Project
will be the subject of a FONSI or other exceptions to the standards set forth in the statute, not
because the statute authorizes it, but because of the "policy" formulated by the EPA to provide so-
called flexible (read as: evasive) means to achieve the statutory requirements in lieu of an in-depth
environment analysis which would ordinarily be performed in a full blown EIS. The implementation
of the policy over the statutory intent, and denigration thereof, also violates the Federal Court Orders
which are extant and applicable to this Project. For these reasons, APCA ask the EPA to undertake
and construe this Project as requiring a lull EIS.
2. The EA Fails to Acknowledge the Existence of Statewide Water Supply Problems,
and particularly, the Impact on Atlanta of Efforts Currently Underway to Address Those
Problems.
In the case of Upper Chattahoochee River Keeper Fund, Inc. v. The City of Atlanta,
95CV2550-TWT, various environmental groups, cities, counties and landowners brought an action
under the Clean Water Act against the city alleging violations of National Pollutant Discharge
Elimination System (NPDES) permits by Combined Sewer Overflow (CSO) treatment facilities.
Plaintiffs were accorded relief on Count II based on the Court's finding that the undisputed facts
demonstrate the City of Atlanta is violating the NPDES permits and the Clean Water Act with
respect to the subject CSO's by failing to maintain accurate records, by failing to conduct first flush
sampling, by failing to conduct composite sampling, by failing to beat each CSO treatment facility
discharge in accordance with the CSO plan, by violating Georgia Water quality standards with
respect to discharges and finally by violating the Georgia Water quality standards with respect to
fecal coliform bacteria in the receiving streams below the CSO facilities. The relief then accorded
pursuant to this court order is ongoing and the City continues to incur fines as late as the week of
September 11,2000 according to newspaper accounts. Among violations just cited by the EPA and
the state Environmental Protection Division were illegal discharges of raw or partially treated
sewage from city facilities during the past 18 months; the failure of the city to file several reports
Mr. Ben West
Office of EAD
United States Environmental Protection Agency
September 22,2000
Page 6
on time as required by the consent order; and discharges "to or from" the Atlantic Steel facility,
which currently are under investigation.
Based on the existence of that federal court order, APCA can legitimately inquire as to the
conclusions slated in the EA that relate to the sufficiency of the water and sewer capacities. The
responses received by the City of Atlanta officials including Remedios K. Del Rosario,
Commissioner, Department of Water, May 22, 2000 and Norm A Koplon, P.E.'s responses dated
July 6, 2000 (2) and August I, 2000 contained in Appendix 8 deal with the available capacity for
domestic and fire protection as well as sewer and storm water management. Their responses
strongly assure the EPA/developer that there would not be a further violation of the Clean Water Act
as set forth in Judge Thrash's Order. The circumstances yield some suspicion as to exactly what is
being verified and guaranteed, however. A careful review of the correspondence of August 1,2000,
and July 6, 2000, regarding certain requests for clarification evinces some equivocation. Of
particular note is the first letter dated July 6. in which Jacoby is directed to comply with all Codes,
ordinances and regulations related to on-site storm water systems and to provide detention facilities
to reduce the peak runoff from the post-developed site conditions to assure that it is less than or
equal to the pre-development condition. It also directs that additional detention capacity must be
provided to ofTset the net increase in sanitary sewer flow in the downstream combined or the street
sewer according to short term capacity certification protocols. The proposed construction of sewer
is deemed to meet the city's minimum requirements if, but only if, the storm drainage bypass system
is properly designed, both horizontally and vertically to allow future extension to the connection
point at the Tanyard Creek CSO facility. All conditions are subject to the City of Atlanta's further
approval. The letter states "at this time, funding has not been identified for this extension". The July
6 communication seems to be hardly an unconditional statement of compliance and ability to serve
this important project in terms of water/sewer needs.
As is evidenced by the Department of Public Works Confirmation of Adequate Capacity to
Convey New Flows in the Wastewater Collection and Transmission System dated July S, 2000
(q.v.), the application of Jacoby Atlantic Redevelopment, LLC shown in the Appendix, specifically
alludes to the requirements of City Ordinance § 154-145 entitled "Plans and specifications generally"
which in turn directly requires the satisfaction of the conditions stated in "Federal Lawsuit initiated
by the U.S. Environmental Protection Division including Paragraph VIII.B.8 of the First Amended
Consent Decree between the United TWT. The terms and conditions of the Consent Decree are set
forth in the application The application is approved subject to, and only subject to, salisfaciion of
the conditions set forth therein. It is dated the 5 th day of July, 2000, and is signed by Valentino T
Bates. A fair reading of the application ar.d letter indicate that, far from being approved and a
guaranteed capacity and compliance with the Federal Court Decree, the approval is only subject to
conditions yet to be met. The July 6 letter to Dr. Hillestad from Norman Koplon also equivocates
on the question of whether or not the RM Clayton facility which currenlly treats an average daily
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Mr. Ben West
Office ofEAD
United States Environmental Protection Agency
September 22, 2000
Page 7
flow of 86 MGD +/- and is "currently being expanded to treat an average daily flow of 103MGD,"
is, in reality, a projection as what the City can expect as relates to capacity rather than a guarantee
of that capacity. Koplon's tetter indicates that the City has sufficient waste water treatment capacity
available to allow "development of the proposed Atlantic Steel Project at the following projected
daily sewer flows. Clearly, what is approved is a limitation on sewer and water capacity which relies
on the development of a new sanitary sewer collections system through the Atlantic Steel
Development which is to be built in the future. Mr Koplon's "understanding" is based on Jacoby
Development, LLC's engineering analysis, which is not supported or supplied in the EA. From this,
Mr. Koplon opines that the city's sewer system has adequate conveyance capacity to service the
proposed development of the Atlantic Steel site. The analysis indicates tftaUittofctiUivocal and
subject to limitations, particularly those of the federal lawsuit, that the apj$(nw£e based on
projections, systems are not in place and that the capacity that can accommodate the water discharge
and sewer use and its projected water discharge and sewer use at this time are yet to be lawfully
accomplished.
Mr. Koplon's letter of August 1st seeks to "clarify" his two referenced letters dated July 6,
2000 and discusses the need to continually update data to the public including clarification of any
information relevant to the draft environmental assessment that the EPA released on August 2. Mr.
Koplon's "second thought" letter concludes that the capacity "will be available" to convey and treat
the waste water that "you predict" will be generated by your development between 2000 and 2012.
His letter then identified the need for some clarification. Clarification includes upgrades that "will
soon be completed at the RM Clayton water reclamation plant." Finally Mr. Koplon opines that this
upgrade "should increase treatment capacity substantially to handle the maximum average daily
flows of approximately 122 MGD, in contrast to his expectations for average annual daily flows
referenced in previous letters" Clearly, the information in previous letters was not reliable and does
not represent fair and accurate estimates. Mr. Koplon suggests that there is planning and other work
that is "underway" to reduce flows from the Hemphill plant to (he Orme Street combined sewer and
equivocally states in the third paragraph of his letter, "accordingly we are in a good position to
process your permits when you are able to provide design parameters including proposed connection
locations for review by the City staff and consultants." That approval is prospective. The letter then
indicates the need for implementing and developing sound alternatives for managing storm water
in the short term and indicates that his understanding has been less than perfect as to the complex
inter-relationship of pipes, valves and storage ponds which function to capture and convey several
waste water and storm water flows, past and present. He complains that he has limited experience
with the effects of setting the control valve to reduce the use of the process ponds for conveying
storm water and other flows.
Mr. Koplon is clearly depending on rehabilitation of the combined sewers and separate
sewers on the Atlantic Steel property to reduce the contribution of flows from Hemphill and
Mr. Ben West
Office of EAD
United States Environmental Protection Agency
September 22, 2000
Page 8
upstream dry weather flows. He "expects" the Atlantic Steel Development plans to incorporate
advanced control of both storm water and wastewater and bases his approval on the understanding
that Jacoby will reconfigure its systemof ponds and channels obviously expecting in the future some
amelioration of the problem.
At no point do Koplon's equivocal several responses provide assurance that (I) the Project
will comply with the Federal Clean Water Act litigation or (2) will be constructed in such a way as
to guarantee the existence of sufficient water and sewage capacity. APCA consequently disregards
the EA analysis of the compliance with the Clepn Water Act and availability of water capacity and
conveyance verification. It is lacking in specific detail, is based on conjecture and future projects
being completed. It also takes into account capacity figures regarded as achieved that are only being
estimated at this time, before ihey are precisely known. Accordingly, there is an obvious lack of
sufficient detail and information (or Court approval) with which to satisfy the citizens/stakeholders
of APCA that this problem is being addressed in a way that will not jeopardize the environment as
to these conditions. The site that is being reclaimed is subject to storm and ground water mnofTand
detention. It is, after all, a contaminated site which presumably will require extraordinary treatment
to rid the water of pollutants in the future. The EA does not demonstrate that this has been or can
be remotely achieved at a level which meets federal court standards in the near future.
3. The Designation of the 17" Street Extension and the Atlantic Sletl Redevelopment
as a Transportation Control Measure by Ihe EPA b Ultra Vires.
EPA proposes to grant the approval necessary for this Project to proceed under the regulatory
flexibility provided by the Project XL Program. However, there is no statutory or regulatory
authority for the adoption of the Project XL program by EPA. Consequently, any decisions made
by the EPA in furtherance of this program are lacking in any legal foundation and are ultra vires.
Moreover, even assuming any legal authority could be found for the adoption of the Project
XL Program, there is no statutory or regulatory authority that would permit EPA to designate as a
TCM a development that increases regional air emissions on an empirical basis as this Project clearly
would. EPA proposes that this Project should be designated as a TCM under a novel and unlawful
analysis. That analysis would permit the EPA to analyze the air quality impacts of this Project by
comparing those impacts not on a build/ no-build basis as they are legally required to do and have
traditionally done, but rather to compare Project impacts with those of a similar development at an
alternative regional location. Under a traditional build/no-build analysis, it is improbable that this
Project would be designated as a TCM. No legal authority or precedent is offered for this novel
approach, a fact conceded by the EPA in the EA at Section 2 3 and in its response to APCA dated
August 16, 2000.
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©
Mr. Ben West
Office of EAD
United States Environmental Protection Agency
September 22, 2000
Page 9
4. Even Assuming EPA has the Legal Authority to Designate this Project as a TCM, the
Project Lacks the Necessary Criteria to Qualify as a TCM.
Several criteria for designation of a project as a TCM are not adequately addressed in the E A.
First, a critical component of this Project is the transit connection to the MARTA Arts Center
Station to be provided by means of a free shuttle bus service by the developer. The EA assumes that
when the developer's obligation to maintain the shuttle service expires, transit service at the site will
continue. However, no firm commitments exist to develop a transit link through this site. While a
feasibility study of a transit link between the MARTA Arts Center Station and Cumberland Mall
through the Atlajuic Steel site is programmed for FY 2001, such a study provides no commitment
that any transit will in fact be built. The EA includes no analysis of potential impacts on regional
air emissions should a transit service connecting the site to MARTA fail to be developed. Second.
as we indicated in our letter to Ms. Prince on May 10, 2000, there is insufficient evidence that
funding has been (or will be) obligated to implement the TCM. Third, while the TCM agreement
discusses the enforceability of the TCM obligations against the City of Atlanta and the State of
Georgia, it is silent as to its enforceability against the developer or its successors or assigns. Given
the importance of the obligations imposed on the developer, such an omission must be addressed.
Further, neither the zoning conditions nor the TCM itself impose an obligation on the developer to
complete this Project. It is possible that the TCM site design criteria and zoning conditions attached
to the property will be satisfied following completion of the first phase of construction during which
time the entire public investment of funds in this Project will occur. Therefore, as presently
documented, the Atlantic Steel redevelopment may not result in the development described in the
EA and presented to the public at various public meetings notwithstanding an investment of more
than $82 million in related transportation infrastructure. At a minimum, the documents should
require the developer to complete the proposed development within an acceptable period of time.
This serious omission must be addressed prior to approval of the TCM.
5. The Failure to Study the Impacts of this Project on the Ansley Park Neighborhood
as Required under Federal law is a Glaring Omission.
As we indicated to you in our letter of April 26,2000, a full analysis of the impacts of this
project on the historic Ansley Park neighborhood is required under Section 4(0 of the United States
Department of Transportation Act (49 USC § 303(c)) ("US DOT'). Notwithstanding our earlier
comment, no such analysis is provided in the EA. The EA merely asserts that the 17th Street
Extension would have no adverse effect on historic resources, including the Ansley Park
neighborhood. (Ex - 4; 4.3.7) This assertion is fundamentally flawed. First, the traffic analysis
included in the EA itself acknowledges that there will be adverse impacts on several Ansley Park
streets. Second, the EA incorrectly and arbitrarily defines the eastern border of the "Area of Potential
Effects" (APE) as Peachtree Circle and thus precluded any analysis of the impacts of the Project on
Mr. Ben West
Office of EAD
United Stales Environmental Protection Agency
September 22, 2000
Page 10
the entire Ansley Park neighborhood. No explanation is provided for drawing the APE boundary
along Peachtree Circle. Clearly, once eastbound traffic enters the Ansley Park neighborhood on
Peachtree Circle it must travel through other parts of the neighborhood to exit. Likewise, traffic
along the Piedmont corridor seeking to use the new 17th Street extension as an east-west link to
Northside Drive (as planners clearly contemplate) will inevitably use the Ansley Park neighborhood
for lack of other means of access to the 17a Street Extension. No analysis of these traffic impacts
is provided in the EA. Without the full and complete analysis of the impacts of this Project on
historic Ansley Park and the determination of the United States Secretary of Transportation, the EA
fails to meet the requirements of NEPA and Section 4(0 of the US DOT
6. The 17" Street Bridge Design is not in Compliance with the Zoning Conditions
attached to the Atlantic Steel Property.
The Atlantic Steel redevelopment is required to be built in accordance with the zoning
conditions imposed by the City of Atlanta. The second such condition requires that "the property
shall be developed in accordance with the Use Diagram ("Diagram")..." The EA inexplicably failed
to include the Diagram. However, the Diagram reflects a 17th Street bridge that varies significantly
from and is inconsistent with the plan proposed by the EA. Any modification of the 17th Street
bridge and extension from that included in the Diagram may only be made in accordance with the
procedures for modification of zoning approvals applicable in the City of Atlanta. We are not
aware of any steps taken to date to seek approval of this significant modification.
7. The Analysis of Traffic Impacts Included in the EA is Flawed.
As we indicated in ACPA's letter to you dated April 26,2000, the calculation of future traffic
volume estimates rest on incorrect assumptions and may grossly underestimate future volumes. The
traffic growth assumption used for freeway traffic is 1.5% in spite of an historical growth rate
ranging from 8.4% • 9.7%. The traffic growth assumption used for surface traffic is 2% in spile of
an historical growth rate of 2.85%. ACPA's April 26 letter explains in detail why these assumptions
are incorrect and unjustified. Notwithstanding our earlier comments, these assumption continue to
be used in the EA without any additional justification.
8. The Analysis of Air Quality Emissions included in the EA is Incorrect.
Even assuming the approach to calculating regional air emissions benefits from this Project
is correct, which we do not accept as indicated above, the analysis of air quality emissions benefits
accruing to the region as a result of implementation of this Project is incorrect. First, as we indicated
10
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©
Mr. Ben West
Office of HAD
United States Environmental Protection Agency
September 22,2000
Page II
to Mi. Prince of your office in our letter of May 10, 2000, the carbon monoxide ("CO") hotspot
analysis is flawed. This analysis must be recomputed using accurate forecasts of traffic volumes for
the midtown, Atlanta area. In the EPA's response to our letter to Ms. Prince, it indicated that the
background traffic volumes used for calculating potential CO emissions are the same traffic volumes
referred to above. As we indicate above, these traffic volumes are speculative and incoiTect. By
materially underestimating potential traffic volumes in the project area, the CO hotspot analysis
lacks the necessary factual foundation. It cannot be used to support the conclusion that
implementation of this Project will not result in any local CO hotspots. Second, as we indicated to
you in our earlier letter, the transit usage assumptions used for calculating regional air quality
impacts from this Project are incorrect.
9. The Assumption In the EA as to the No Build Alternative Is Unsound.
, . The City of Atlanta and the developer provided a no build scenario for purposes of
^ comparison of impacts. This no build scenario is outlined in Appendix B to the EA. However, this
scenario fails to acknowledge that the Atlantic Steel property was primarily rezoned from Heavy
On Industrial (1-2) to Commercial Residential - Conditional (C-4-C) because of the requirement to
build the 17* Street Extension. Any proposed redevelopment of the site without the 17* Street
| Extension would require rezoning. No analysis or justification is provided in the EA to indicate why
the concerns prompting the zoning condition that the IT* Street Extens'jn be built would no longer
be relevant in any rezoning application. Accordingly, nothing in the EA justifies the conclusion that
the property would "probably" be developed as indicated in Appendix B or "probably" be run-of-the-
mill quality is purely speculative and revealing of a prompted predisposition on the park of Mike
Dobbins. Any comparison of build/no build made in the EA is contrived and unsound.
10. The draft Memorandum of Understanding and the Five Design Alternatives for 17*
Street Fall to Address the Concerns Raised by APCA to this Project and have been Rejected
by the APCA.
While the EA refers to concerns raised by neighborhoods, including Ansley Park, it states
that those concerns are addressed by means of the draft Memorandum of Understanding ( MOU )
attached as Appendix I to the EA. The APCA expressly rejects that draft MOU as an adequate means
of addressing neighborhood concerns. In addition, the five alternatives for modifications to 17*
Street presented to neighborhood representatives at a meeting on May 17,2000 have been rejected
by the APCA. Before this Project proceeds and prior to any decision by the APCA or the Ansley
Park neighborhood on acceptable mitigation, a full and complete Environmental Impact Statement
should be completed that identifies all potential impacts of this Project on all potential areas of
it
Mr. Ben West
Office of EAD
United States Environmental Protection Agency
September 22, 2000
Page 12
impacts, including the entire historic Ansley Park neighborhood. Without such an analysis, neither
the APCA nor the neighborhood can reasonably determine what specific remedies should be
adopted to mitigate the impacts of this Project. Further, no rational administrative body could
conclude that the requirements of NEPA have been satisfied.
Conclusion
The above comments are made without the benefit of the response of the EPA to
APCA's FOIA request. Accordingly, APCA requests the right and opportunity to supplement this
comment to the EA. Notwithstanding that request, APCA urges that the EA as presently proposed
be rejected and an E1S be ordered for the project.
I
Aic'h
Attorney for Ansley Park Civic Association,
Inc.
12
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t&ce,Uck. fjlojco
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CO Hanklraon fohn^epe gov. Kutrman Jmftepa gov
CC Jeny.tankllnQfladot gov
CC' Kash®46©mlndspi1ng com. Rptn«©cl.attanta ga.us
CC Lany.dreihaupQtwa dot gov
as a resident ef ansley park and e taxpayer of allante and fatten county, i em OPPOSED le the traffic flow the 17th
street bridge will create-i listened to yetr presentation last tuesday end am wry disappointed that a man of your
position and character could honestly state that ansley park will not be affected Jut the shoe en the other footJfit
were your famty and children and your historic home end neighborhood, how would you respond t?f THERE ABE
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09/22/2000 05 20 PM
B«n Wesl/R4AJSEPAAJS. John Hanklnaon/R4/USEPA/US. Jim
Kut2man/R4/USEPA/US. «im dir@grta org,
coteman@dot.ttite ga ui. |oe palladi@dot.ttBte ga ut,
Jerry tfanklm@tta dol.gov, larry.mfndspnng com. rprtts@ci.attanta.ga.uf,
wation a<5>gilaw com
CC'
Subject. Atlantic Steal Redevelopment
I am a resident ol Colony House in Ansley Park and also work on 17th Street
I am writing to express my outrage at the completely sell-serving nature of
the environmental assessment ol the impact on the 17th Street extension I
am appalled In a city that has ore ot the worst smog records in the nation,
an entire development would be concentrated on the automobile. The fact
that MARTA has been eliminated from the planning process Is disturbing at
the least When will Atlanta admit that it cannot continue to tocus on the
automobile as the primary means of transportation?
In addition, the conclusion that there would be no significant impact on the
traffic problem defies logic Working on f 7th Street over the past 5 years
I can say that there has been a appreciable increase in the traffic on this
street. How could anyone suggest that thousands of cars per day dumping
onto West Peachfree and traveling directly up f 7th Street to Peachlree would
have no Impact on the surrounding businesses and neighborhoods7
I applaud the attempt to develop the AilanHc Steel Development but Ihe plan
certainly seems significantly flawed in the means of dealing with Ihe
traffic problems Before this project proceeds, the design musl consider
diverting traffic away from 17th Street and Ansfey Park, fn addition, the
impact on Ansley Park must be Identified and a remedy provided
Grace M Paul
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