DECATUR, GA –Hank Johnson (GA-04) has sent a letter to Georgia Department of Transportation Commissioner Russell R. McMurry raising concerns that the agency’s planned expansion of the I-20 and I-285 interchange east of Atlanta in South DeKalb will exacerbate pollution and climate problems in the area and almost certainly be at the expense of the planning of heavy rail service down the I-20 East corridor.
Johnson, a senior member of House Transportation & Infrastructure Committee, wrote in the letter:
“I am writing to share my significant concerns regarding the Georgia Department of Transportation’s (GDOT) planned expansion of the I-20 and I-285 interchange east of Atlanta. I am requesting a detailed description of how this project complies with Title VI of the Civil Rights Act of 1964, the National Environmental Policy Act (NEPA) and federal executive orders, and how this project and GDOT will support plans for heavy rail and high-capacity bus rapid transit in the corridor. Finally, I am requesting an analysis of the project’s impact on overall mobility in the corridor and an assessment of its impact on greenhouse gas emissions and other air pollution.”
The letter was also shared with U.S. Department of Transportation Secretary Pete Buttigieg. It comes on the heels of the DeKalb County Board of Commissioners approving by a 5-2 vote a resolution last week supporting heavy rail “transit extending from the Indian Creek MARTA Station to the Mall at Stonecrest.” [AJC]
Rep. Johnson further states: “The proposed I-20/I-285 East Interchange expansion will adversely impact property values and health outcomes for the Black and minority population that resides in the area by adding new lanes and access roads, expanding the highway significantly closer to homes in the surrounding area, and increasing the noise and air pollution from the roadway. Further, I am deeply concerned about the potential for this planned interchange expansion to make it more difficult, if not impossible, to expand heavy rail public transit through this corridor that has been long sought by the local community and promised by the region.”
Read the full letter here
February 4, 2022
Russell R. McMurry, P.E.
Georgia Department of Transportation
One Georgia Center
600 West Peachtree NW Atlanta, GA 30308
Dear Commissioner McMurry:
I am writing to share my significant concerns regarding the Georgia Department of Transportation’s (GDOT) planned expansion of the I-20 and I-285 interchange east of Atlanta. I am requesting a detailed description of how this project complies with Title VI of the Civil Rights Act of 1964, the National Environmental Policy Act (NEPA) and federal executive orders 12898 and 14008, and how this project and GDOT will support plans for heavy rail and high-capacity bus rapid transit in the corridor. Finally, I am requesting an analysis of the project’s impact on overall mobility in the corridor and an assessment of its impact on greenhouse gas emissions and other air pollution.
The proposed I-20/I-285 East Interchange expansion will adversely impact property values and health outcomes for the Black and minority population that resides in the area by adding new lanes and access roads, expanding the highway significantly closer to homes in the surrounding area, and increasing the noise and air pollution from the roadway. Further, I am deeply concerned about the potential for this planned interchange expansion to make it more difficult, if not impossible, to expand heavy rail public transit through this corridor that has been long sought by the local community and promised by the region. As a result, I am concerned that the project reflects an outdated road-centric approach that focuses solely on reducing traffic congestion through new roadway capacity rather than improving overall mobility for area residents which has been shown to more effectively addresses congestion.
The project is located in south DeKalb County, which I represent, and which is a majority minority community. These hardworking people must too often travel to other parts of the county or region to access jobs. Those who are able to afford to drive suffer some of the worst congestion and travel times in the country, while those who are unable to drive have significantly reduced access to jobs and opportunity as a result of inadequate transit, pedestrian, and cyclist infrastructure.
Since the 1970s, the residents of south DeKalb County have financially supported the Metropolitan Atlanta Rapid Transit Authority (MARTA) despite the fact that there is no heavy rail service in the southern part of DeKalb County. In 2012, MARTA adopted a Locally Preferred Alternative for high-capacity transit service in this area. The Locally Preferred Alternative includes an extension of the heavy rail line and bus rapid transit service, and both proposed transit lines would use the I-20/I-285 East Interchange that GDOT plans to modify. The proposed interchange expansion project will utilize right of way necessary for the proposed transit service, thereby making it more difficult and more expensive, and potentially impossible to construct these transit projects in the future—unless it accommodates them now.
Title VI of the Civil Rights Act of 1964 requires that no person in the United States, based on race, color, or national origin, be excluded from participation in, denied the benefits of, or otherwise subjected to discrimination under any program that DOT financially assists. NEPA and USDOT regulations require projects to mitigate their impacts on the environment and environmental justice. Executive Order 12898 directs federal agencies to identify and address disproportionately high and adverse human health or environmental effects of their actions on low-income communities and communities of color, to the greatest extent practicable and permitted by law. Executive Order 14008 sets out additional environmental justice review obligations for federal agencies, including reviews related to directing federal investments to support clean transit to vulnerable communities.
According to the project’s Environmental Assessment (EA), residents adjacent to the I-20/I-285 East Interchange project are predominantly people of color. In fact, every Census Tract in the project area is at least 87% people of color and many are over 98%. Given this demographic information, I am concerned that the EA’s review of the project’s environmental justice impacts is cursory and superficial. It asserts that the project will not divide or create barriers between communities, despite the fact that the project adds lanes and access roads to an enormous interchange and two major interstates that have already divided them. In addressing the project’s impact on air quality, the EA contends that the project will not cause the entire region to violate the federal air quality standard for air pollutants. However, the document fails to evaluate the localized increase in air pollution that the project will cause due to increased vehicle travel. This area already has elevated levels of particulate matter air pollution  and this pollution is endured almost exclusively by people of color. I am deeply concerned about the quality and veracity of any Title VI civil rights compliance review, NEPA review, or environmental justice executive order review process which relies on such deficient analysis and ignores the negative impacts to the surrounding community of color.
The Atlanta region already faces some of the worst congestion in the nation. Despite decades of highway and road construction and expansion, this congestion has only increased. This is because of induced demand, a proven  phenomenon wherein a 10 percent increase in lane miles leads to a 10 percent increase in driving. This results in a newly constructed or expanded roadway rapidly becoming congested, and associated increases in regional congestion and emissions. This phenomenon is borne out by the EA, which anticipates that the project will lead to more vehicles on the road and that the interchange will remain congested even with the project. A project that worsens pollution, fails to remove congestion, and makes it more difficult to build proposed transit expansion projects in the corridor seems like a particularly ineffective use of federal transportation funds.
Our nation is facing the dual crises of climate change and inequity. As Secretary of Transportation Buttigieg has noted numerous times, America’s overreliance on highways and driving has contributed to both crises, and we cannot solve either without changing how we invest in infrastructure. The transportation sector is now the leading source of greenhouse gas emissions in the United States.  Yet GDOT falls short of addressing the challenge of climate change, both by designing a project that will encourage more driving and by failing to evaluate the project’s contribution to the region’s transportation emissions in the EA. GDOT is uniquely posed to demonstrate leadership on the climate crisis by incorporating greenhouse gas emissions into its design for projects like the I-20/I-285 Interchange and by pursuing projects that reduce the region’s transportation emission. We cannot address the transportation sector’s contribution to the climate crisis by encouraging more driving and making it more difficult to expand public transit.
I thank you for your consideration and your careful review of these concerns.
Henry C. “Hank” Johnson
Member of Congress
Cc: The Honorable Pete Buttigieg, Secretary, US Department of Transportation
1: Atlanta Roadside Emissions Exposure Study, Atlanta Regional Commission (2016)https://atlregional.github.io/DASH/arees.html
WHAT THEY ARE SAYING
“For over half a century, residents of South DeKalb have paid into the MARTA system, with the expectation that Heavy Rail would someday reach their neighborhoods in South DeKalb. This promise is long overdue, and we must do everything we can to ensure that nothing stands in the way of possible expansion. For that reason, I am proud to sign on to Congressman Hank Johnson’s letter.” – DeKalb County District 5 Commissioner Mereda Davis Johnson
“As a DeKalb County Commissioner, I am committed to working with our Congressman, other elected officials, and necessary stakeholders to make mass transit a reality in south and unincorporated DeKalb. Due to expected growth and to foster economic development, the presence of rail and/or mass transit is imperative to the future of DeKalb and the time to act is now.” – DeKalb County District 7 Commissioner, Lorraine Cochran-Johnson
“Road building and other infrastructure agencies must be held accountable for damage they have historically inflicted on minority populations through destruction of property and environmental neglect. Protection of health and property must be prioritized in GDOT’s proposed I-20/I-285 East Interchange. Any other approach is unacceptable.” — Deborah Scott, Chief Executive Officer, Georgia STAND-UP
Sierra Club Georgia Chapter
“Rep. Johnson is a strong ally for racial equity, better air quality, and transit expansion. GDOT needs to re-evaluate how it can be a better partner to provide mobility and access to people and not just cars by flexing current funding towards buses and rail.” — Tejas Kotak, Transportation Chair, Sierra Club Georgia Chapter
“It is important that transportation officials at all levels, from local to state and federal, prioritize regional transit projects over highway expansion projects due to the equitable impacts of air quality and mobility for residents, especially those impacted locally. Instead of investing in projects that continue to expand road capacity, there needs to be an increased focus on completing transit projects that benefit the local population and encourage more sustainable transportation that reduces the demand for travel by car.” — Matt Stigall, Chair, Engagement, Advance Atlanta
Southern Environmental Law Center
“Addressing the role of transportation in the climate crisis requires a change in mindset from our federal and state Departments of Transportation. Instead of building bigger roads, projects like the I-20/285 Interchange must focus on expanding transit options, reducing carbon pollution, and improving the health of local residents.” — Brian Gist, Senior Attorney, Southern Environmental Law Center
Partnership for Southern Equity
“Not only would this planned expansion fail to address the negative consequences of living close to the existing highway infrastructure, but it would also worsen them in some cases. The Partnership for Southern Equity shares Congressman Johnson’s concerns that continued investment in traditional highway infrastructure, as opposed to modes of collective transportation, will only serve to exacerbate inequities in some of the Atlanta Metro Area’s most vulnerable communities.” — Suzanne Burns, Director, Just Growth Portfolio, Partnership for Southern Equity
Atlanta Bicycle Coalition
GDOT’s mission is to “deliver a transportation system focused on innovation, safety, sustainability and mobility.” In order to achieve this, it will need to start prioritizing transit projects over highway expansions. Transit is a more effective approach to boost Georgia’s economy through greater access to opportunities for residents and businesses along the I-20 corridor, while also improving community and personal health and financial stability. The benefits transit offers are essential to creating a more equitable state. — Rebecca Serna, Executive Director, Atlanta Bicycle Coalition
Additional Background: PSE’s research into transportation inequities finds just cause for concern regarding the Georgia Department of Transportation’s planned expansion of the I-20 and I-285 interchange east of Atlanta.
Asthma rates for adults in the census tracts immediately bordering I-20 and I-285 are 3% to 5% higher than in most census tracts further north and further away from the interstates. (CDC Population Level Analysis and Community Estimates (PLACES), 2018). Additionally, the rate of asthma ER visits for children in DeKalb County in 2018 was highest in the census tracts bordering I-20, I-285, and I-85. While the average rate across the county is 14.7 per 1,000, the rate of asthma ER visits for census tracts surrounding the I-285/I-20 interchange is between 20-26, with most census tracts along I-20 having a rate of 25 or higher. (GA Dept. of Public Health, OASIS, 2018). The I-20/I-285 East Interchange project would worsen air quality due to increased vehicle travel, which would in turn worsen health outcomes for communities that live within the project area, all of which are at least 87% people of color, with many over 98%.
Finally, it is clear that this focus on car-centric transportation not only fails to serve the transportation needs of the constituents in these communities, but also would serve to impede accessibility to alternatives like public transit. In most of the census tracts surrounding the interchange and along I-20 in South DeKalb, anywhere from 15-25% of owner-occupied housing units do not own any vehicles. Further, some of the longest mean travel times in DeKalb County are for those who live in census tracts along I-20. (US Census Bureau ACS 5-year 2015-2019).