United States Environmental Protection Agency Office of Policy (2127)
H Washington, D.C. 20460 EPA231-R-99-004
m 0 ^^lJr% September 1 999
Project XL and Atlantic Steel
Supporting Environmental
** . , -
Excellence and Smart Growth
Urban and Economic Development Division (2127) _ Summary
From State Houses to the ballot box, Americans have shown a desire for better growth and development
in their communities. Citizens want the jobs, tax base, revitalization and opportunity that growth can
bring. But, they want it without the growth-induced traffic, farmland destruction, and center city
disinvestment that has so often accompanied growth in the past. In short, communities are moving beyond
the "growth" versus "no growth" debates of the past in search of smart growth.
Nowhere is this trend more evident than in Atlanta, Georgia. Called by some the fastest growing
settlement in history, the Atlanta metropolitan region's north/south length grew from 65 miles in 1990 to
1 10 miles in 1997. Studies show that for each one percent growth in Atlanta's population there is a
corresponding increase of 10-20% in developed land. As a result Atlanta loses approximately 50 acres of
green space per day. In addition, Atlanta's ever-spreading development pattern means homes, work,
schools and entertainment grow even further from one another. Longer distances mean longer drives.
Atlantans now drive an average of 34 miles a day, the most in the US.
In response, Atlanta may be changing the way it grows. Increasingly, projects like Atlantic Steel — the
redevelopment of 138 acres of contaminated property in Midtown Atlanta — are seen as part of the
solution. Atlantic Steel uses new growth to alleviate some of Atlanta's most pressing problems. It brings
tax base and jobs to the region's core. It turns a brownfield site into a new neighborhood asset and creates
new housing opportunities in the city. It also increases accessibility and convenience, bringing stores
closer to work, and schools closer to housing.
Projects like Atlantic Steel require partnerships and cooperation to succeed. Local zoning often will not
permit smart growth developments. State infrastructure investments may be needed. Federal regulations
may affect development indirectly, or even directly, as in Atlantic Steel's case. Under a traditional
interpretation of EPA rules, Atlanta's current "conformity lapse" under the Clean Air Act would preclude
construction of a bridge and ramps to Atlantic Steel. These elements are key to the project's success. The
bridge connects the project to public transit and the ramps connect the site to the adjacent highway.
Stopping their construction effectively halts the project.
However, through programs like Project XL, a regulatory flexibility program promoting environmental
excellence and Leadership (XL), EPA is committed to removing obstacles and becoming a resource for
communities in pursuit of smart growth. The Atlantic Steel XL project — a partnership between local,
state, and federal government, and the private sector — demonstrates the effectiveness of this approach and
its resulting environmental and transportation benefits.
This summary describes the Atlantic Steel XL project and its results. The full report, "Transportation
and Environmental Analysis of the Atlantic Steel Development Proposal," is available from EPA.
Contact Geoff Anderson (202 260 2769) or Tim Torma (202 260 5180) at EPA Headquarters, or
I Michelle Glenn (404 562 8674) at EPA Region 4 in Atlanta. The report is also available on the World
Wide Web athttp://yosemite.epa.gov/xl/xl_home.nsf/all/atlantic.html#documents. More information
on Project XL is available on the Web at http://www.epa.gov/projectxl.
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PROJECT XL AND ATLANTIC STEEL
ATLANTIC STEEL: A SUMMARY
Jacoby Development Inc., a developer in
Atlanta, has proposed redeveloping a 138-acre
site near central Atlanta, the former home of
Atlantic Steel. The site is a brownfield—that is,
it contains some contamination. Figure 1 shows
the site location. The development would mix
residential and business uses, and include an
auto and transit bridge. The bridge would re-
connect the neighborhood across the interstate
and provide a direct link to existing rail transit
service. In addition, Jacoby has proposed ramps
to improve interstate access for the project. The
bridge and ramps are shown in Figure 2.
Metro Atlanta has failed to demonstrate that its
regional transportation plans will not worsen or
create air quality problems. As a result Atlanta
is out of compliance with Clean Air Act
conformity requirements and may neither (with
limited exception) use federal funds to add to
its highway system nor construct certain types
of transportation projects that require federal
approval. Under the traditional application of
EPA regulations, construction of the proposed
bridge and ramps would be prohibited.
Jacoby believed that developing the Atlantic
Steel site, including the bridge and ramps,
would result in fewer auto emissions than not
developing the site. Jacoby reasoned that:
1. Atlanta will continue to grow.
2. That growth is projected to locate mainly at
the region's edge.
3. This growth pattern is largely responsible
for producing Atlanta's current
transportation patterns, which force the
average Atlanta resident to drive 34 miles a
day, the most in the nation.
4. The Atlantic Steel site is an opportunity to
shift some of this growth inward, increasing
regional convenience and accessibility, and
reducing future driving.
1-75
1-85
Figure 1: The Atlantic Steel site (North A) The site is
bounded by railroad tracks to the north, and by 1-75/85 to
the east, cutting it off from Midtown Atlanta.
Figure 2: The proposed bridge and ramps. From
developer Project XL proposal. The feasibility of the HOV
ramp is being examined.
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PROJECT XL AND ATLANTIC STEEL
With this reasoning, Jacoby presented the United States Environmental Protection Agency (EPA) with a
straightforward proposition: Atlanta would be a healthier place with the project than without it. Because
the development would be centrally located in the region and accessible without a car, it would produce
less driving and less air pollution than if the same project were built on Atlanta's fringe.
Empirical data show that compact, mixed-use, transit- and pedestrian-accessible infill development does
lead to less driving than the development typical in Atlanta.1 Based on that data, EPA accepted the Atlantic
Steel project as a candidate for its Project XL program. Project XL works with applicants to develop
projects that promise superior environmental performance and economic efficiency in exchange for
regulatory flexibility.
In consultation with stakeholders including the Federal Highway Administration, the Atlanta Regional
Commission, and local citizen's groups, EPA undertook three analyses of the impacts of the Atlantic Steel
proposal:
1. Regional transportation and air emissions impacts;
2. Site level travel and air, open space, brownfields, and impervious surface impacts; and
3. Local emissions hot spot impacts.
ANALYSIS 1: THE EFFECT OF LOCATION ON TRANSPORTATION AND AIR EMISSIONS
In evaluating the impact of developing the Atlantic Steel site, EPA started from two important premises.
First, Atlanta will continue to grow over the next 20 years. Second, if the 138-acre Atlantic Steel site is
not redeveloped, more of this growth will go to outlying areas. To analyze the transportation and
emissions impacts of new development at the Atlantic Steel site, EPA compared the site with three other
Atlanta area sites able to absorb projects of similar size.
EPA worked with regional stakeholders to select the following sites: Sandy Springs in the Perimeter
Center area, a site near the border of Cobb and Fulton counties, and a site in south Henry County. These
three sites, and the Atlantic Steel site, are shown in Figure 3.
Together, the sites capture important variables that help determine travel behavior:
Location
Development density Regional location
MARTA rail served?
Atlantic Steel Urban
Cobb/Fulton Suburban
South Henry County Suburban
Sandy Springs Urban
Central Yes
Suburban No
Exurban/Rural No
Just past the perimeter Yes
Hagler Bailly Inc., "The Transportation and Environmental Impacts of Infill versus Greenfield Development: A Comparative
Case Study Analysis," prepared for US EPA, April 1998.
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PROJECT XL AND ATLANTIC STEEL
Atlanta Greenfield/Brownfield Sites
Figure 3: The four sites analyzed. The four sites represent a wide set of development options.
Although these sites do not cover all possible locational variations, they represent the available options. The
South Henry and Cobb/Fulton sites were chosen because their development would be consistent with the
region's projected suburban and exurban growth. The Perimeter Center/Sandy Springs site was chosen
because its development would illustrate the impact of Atlantic Steel shifting growth from more unlikely
locations. Thus, this site was
Figure 4: The effect of regional
location on Vehicle Miles
considered a conservative point
of comparison.
507,498
518,197
EPA used Atlanta's regional
travel model and EPA's
MOBILE 5 emissions model to
analyze the likely effects of
developing each site with the
same amount and mix of
development. Figures 4 and 5
show the results of the regional
location analysis.
Tr
aveled per day
340,300
389,672
Atlantic Steel Sandy Springs Cobb/Fulton Henry County
4
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PROJECT XL AND ATLANTIC STEEL
Regional Vehicle Miles Traveled
Associated
Regional total
Site
Atlantic Steel
Sandy Springs
Cobb/Fulton
Henry County
Using MOBILE 5, vehicle miles traveled lead to...
Regional Emissions
Site VMT
Regional total
(VMT/day)
139,172,200
139,221,572
139,339,398
139,350,097
with site
(VMT/day)
340,300
389,672
507,498
518,197
difference from
AS
14.5%
49.1%
52.3%
Site
NOx
Regional total
(tons/day)
Atlantic Steel 191.95
Sandy Springs 192.10
Cobb/Fulton 192.24
Henry County 192.27
Associated
with site
(tons/day)
0.400
0.548
0.690
0.724
Site NOx
difference from
AS
voc
Regional total
(tons/day)
153.230
37.00% 154.374
72.50% 154.312
81.00% 154.464
Associated
with site
(tons/day)
-0.390
0.754
0.692
0.844
Site VOC
difference from
AS
293.33%
277.44%
316.41%
Figure 5: Driving and emissions impacts of regional location
The Atlantic Steel location reduces driving and emissions substantially compared to the alternatives. The
Sandy Springs location on the perimeter would produce 14% more driving. The Cobb/Fulton and Henry
County locations would each produce roughly 50% more driving. These differences in driving translate into
substantial differences in emissions. Because car and light truck emissions change with speed, and the miles
driven in each case would be on a mix of roads with different congestion levels and speeds, the emissions
differences exceed the differences in the number of miles driven.2
In addition to quantifying Vehicle Miles Traveled, a necessary input to emissions calculation, EPA also
quantified other travel-related performance indicators of concern to project stakeholders. Results include:
Measure
Transit share of
work trips
Average work trip
time
Regional
Average
7.7%
37.0 minutes
Sandy
Atlantic Steel Springs
27.1% 12.5%
33.8 45.0
Henry
Cobb/Fulton County
1.8% 0%
33.9 86.1
Atlantic Steel shows a net decrease in VOC emissions because the new interstate ramps relieve local congestion. This emissions
decrease is not expected to persist over time, because drivers will likely shift to recongest the area in a phenomenon known as
induced demand. Therefore the short-term VOC reduction is not the basis for EPA's decision. Expected continued traffic growth
is not likely to change the performance of alternatives relative to each other. It is this comparative environmental performance
that is the basis for EPA's finding that developing the Atlantic Steel site would produce Superior Environmental Performance.
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PROJECT XL AND ATLANTIC STEEL
Accessibility: % n.a.
of jobs within
30/45 minutes
congested travel
27.0%/30 min
52.1%/45min
18.6%/30
47.6%/45
10.7%/30
32.5%/45
1.1%/30
1.6%/45
ANALYSIS 2: THE EFFECT OF SITE DESIGN ON TRAVEL AND EMISSIONS
Location affects environmental performance, but site design is also important. EPA evaluated the original
Jacoby site design, and determined that the site design could be improved to reduce driving and
emissions. EPA hired planners Duany Plater-Zyberk (DPZ) to help develop a site design that took
advantage of those opportunities. EPA hired DPZ not only because of the firm's expertise in mixed-use,
infill development, but also because its projects are commercially successful. EPA wanted
recommendations that would improve performance while maintaining or enhancing the project's
marketability.
EPA and DPZ held a design charette in which government agencies, prospective developers, the
community—including representatives of the adjacent Home Park neighborhood—and other Atlanta
stakeholders, voiced concerns about and hopes for the site. The DPZ site design responded to this input.
Atlantic Steel Jacoby Design
0.1 Miles
Block Level Land-Use
I | Multi-family
| | Mixed
I 1 Motel
| 1 Office
| | Retail
| [Park
^B Lake
Figure 6: Atlantic Steel site, original Jacoby design
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PROJECT XL AND ATLANTIC STEEL
DPZ Atlantic Steel Design
0.1
Block Level Land Use
I 1 Mufti-family
ID Mixed
l_j Office
| Park
Garage
Lake
0.1 Miles
Figure 1: Atlantic Steel site, DPZ design
Jacoby incorporated many of the DPZ design elements and submitted a revised site design to EPA. Figure
6 shows the original Jacoby design, Figure 1 the DPZ design, and Figure 8 the Jacoby redesign.3
EPA was most interested in design differences affecting travel choices and subsequent auto emissions.
Many land use and transportation planning decisions that drive transportation behavior and thus affect
environmental performance are captured by what planners call the three Ds: diversity, design, and
density.4 Improvements in each have been observed to reduce auto travel.
Diversity refers to the mix of land uses: whether stores, residences, and businesses are mixed together, or far
apart. Use mixing reduces auto trips by allowing trips to be made, chained, or combined without using an auto.
For use mixing to be effective, destinations must be within easy walking distances of each other. Design refers
to the choices that affect the physical and aesthetic experience of being in an area. How far are most people
from transit stops? How direct is the route? Do sidewalks pass by parking lots, or are storefronts continuous
along a sidewalk? Density refers to the concentration of housing, shops, and offices. Location of dense areas on
the site is important. Concentration around transit stops, for example, is likely to reduce auto use.
The three figures show slightly different site boundaries because the land anticipated to participate in the plan changed during
le course of the project.
See Robert Cervero and Kara Kockelman, "Travel I
Research D: Transportation and Environment, 1997.
the course of the project.
See Robert Cervero and Kara Kockelman, "Travel Demand and the 3 Ds: Density, Diversity, and Design," Transportation
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PROJECT XL AND ATLANTIC STEEL
Atlantic Steel Redesign
BlocK Level Land-Use
Multi-family
~ Mixed
10 Office
Freewav ROW
0.1
0.1 Mitt
l>
Lake
May 2, 1090
Figure 8: Atlantic Steel site, Jacoby redesign
Diversity, design, and density interact with each other, and with the transportation network. Data from
around the country shows that travel choices reflect such design differences. A mixed-use, walkable
development will make it likely that many people will walk to lunch and shopping during the day. But if
such a development is not transit accessible, or is far from other destinations, auto use will be higher both
to and from the development and within the development.
Each of the three Atlantic Steel site designs differs in important ways that affect travel and thus
emissions. Compared to Jacoby's original design, the DPZ design and Jacoby redesign excel in three
areas. First, they improve the mix of uses on-site by integrating them more closely. Second, they provide
better connectivity on- and off-site. Third, they enhance the pedestrian environment through street design
and slower traffic.
As with the regional locational analysis, EPA needed to quantitatively analyze performance differences
between the site designs. To judge the effect of site design, EPA used a two-step analytic approach.
First, EPA quantified the differences among designs with INDEX®5, a Geographic Information Systems
(GIS) tool. By evaluating a detailed GIS project map, INDEX® measures spatial characteristics such as
residential or employment density. These measures permit quantitative comparison of design differences.
From EPA contractor Criterion Planners/Engineers, Inc.
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PROJECT XL AND ATLANTIC STEEL
Using data on travelers' responses to site design, EPA adjusted predictions of travel choices for each of
the three Atlantic Steel site designs. As a baseline for its adjustments, EPA used the travel predictions
from the earlier analysis of the original Jacoby design using TRANPLAN, the regional transportation
model. TRANPLAN assumed that the Atlantic Steel site would be developed like a typical Atlanta area
project. For example, when EPA calculated the "Intensity Factor" (a measure of the degree to which
activity is focused on site) for Jacoby's original design it was found to be 24% greater than TRANPLAN
predicted. Data show that for each 10% increase in the intensity factor, vehicle trips for work decrease by
1.2%. This means that the model overestimated the work trips by single-occupant vehicles for the original
Jacoby design, so we adjusted travel accordingly.
Together, the quantification of the three Ds and adjustments to the Jacoby baseline produced the site
travel estimates shown in Figure 9.
Regional Vehicle Miles Traveled
Regional Associated Site difference
total with site from generic
(VMT/day) (VMT/day) development
Site, design
Atlantic Steel, not
design-adjusted
AS, Jacoby
AS, DPZ
139,172,200
139,159,289
139,152,340
340,300
327,389
320,440
AS, Jacoby redesign 139,154,690 322,790
Using MOBILE 5, vehicle miles traveled lead to...
-3.8%
-5.8%
-5.1%
Regional Emissions
Site, design
Atlantic Steel, not
design-adjusted
AS, Jacoby
AS, DPZ
AS, Jacoby redesign
NOx
Regional Associated Site difference
total with site from generic
(tons/day) (tons/day) development
voc
Associated Site difference
Regional total with site from generic
(tons/day) (tons/day) development
191.95
191.94
191.93
191.93
0.400
0.386
0.376
0.381
-3.5%
-6.0%
-4.7%
153.230
153.216
153.206
153.208
-0.390
-0.404
-0.414
-0.412
-3.6%
-6.2%
-5.8%
Figure 9: Travel and emissions impacts of site design. Jacoby's original design would have produced
327,389 miles of vehicle travel per day. The DPZ design and the Jacoby redesign would reduce VMT,
with the latter producing 322,790 miles of travel per day.
ANALYSIS 3: POTENTIAL LOCAL HOTSPOT IMPACTS
Finally, EPA analyzed whether additional traffic resulting from the redevelopment of Atlantic Steel would
cause Carbon Monoxide (CO) hotspots — levels of CO exceeding national environmental and safety
standards. Analysis indicates that development would create no violations of EPA standards. Areas where
analysis shows CO would increase tend to be those that currently report a low CO concentration.
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PROJECT XL AND ATLANTIC STEEL
CONCLUSION
The three analyses show that by shifting growth away from Atlanta's developing fringe and locating it
downtown with access to transit, the Atlantic Steel development remediates a brownfield, reduces long term
growth in vehicle miles traveled, reduces air emissions, and saves open space. In addition, no CO hot spots
are created in Atlanta's Midtown neighborhoods. On the basis of these environmental outcomes, EPA is able
to accept the proposal as an XL project, and exercise regulatory flexibility to allow the Atlantic Steel
development to proceed. Atlantic Steel's benefits are not limited to environmental outcomes. It offers
economic opportunity, improves neighborhood amenities, and creates new housing opportunities.
ATLANTIC STEEL: SMART GROWTH IN ACTION
Traffic congestion and air pollution recently cost Atlanta access to its federal highway funds and caused
Hewlett-Packard to scrap plans for a second office tower. Emerging Trends in Real Estate, a real estate
investment journal, reports: ".. .how the region addresses traffic congestion; inadequate infrastructure,
including water/ sewer capacities; and extension of its subway system will determine whether it expands
into suburban oblivion or takes on a healthy urban dynamic. The jury is out." Atlanta is responding to these
challenges. Atlantic Steel may signify a broader change in Atlanta's development patterns: a change to a
smarter pattern of growth, with more infill, more transportation choices, more mixed-use projects, and more
accessibility and convenience.
Evidence of such a change is emerging. Governor Roy Barnes and Atlanta businesses pushed through
legislation consolidating broad land use and transportation power in the new Georgia Regional Transportation
Authority. BellSouth, the area's second largest employer, recently decided to relocate 13,000 employees
from its 75 suburban offices to three new centers inside the perimeter and adjacent to rail transit. And
Atlantic Steel is part of a wave of downtown and infill development. Mayor Bill Campbell notes that
Atlanta "issued more construction building permits in the last three years than any other time in our history."
While Atlantic Steel demonstrates Atlanta's new direction, it also indicates a still broader trend. Suburbs,
cities, states, and communities across the country are facing the basic question, not of whether to grow, but
of how. And they are finding that to pursue smart growth, partnerships are essential. To build with a mix of
uses, a developer needs the cooperation of the local government and citizen groups. To focus development
in desired areas, local governments need state programs that reinforce their goals. And, in cases like Atlantic
Steel, a developer and city may be in agreement and still need cooperation from the federal government.
THE FEDERAL ROLE IN SMART GROWTH
EPA is committed to being an effective partner for communities in their pursuit of smart growth. Atlantic
Steel is an example of how EPA supports community smart growth efforts by:
* removing barriers to smart growth;
* helping communities get the information and tools to build the communities they want; and
* creating new incentives and resources for communities to successfully carry out their vision.
Clearly, development decisions are the province of state and local governments. Equally clear, as Atlantic
Steel demonstrates, is the fact that the federal government directly and indirectly affects these decisions.
EPA is learning from these experiences to make its policies and programs supportive of communities in new
ways.
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