From: Marcus Griswold, PhD

Principal
Calm Waters Group
[email protected]

To:
Alecia Brewster
Michael Brown
Iyunia Aiken
New Washington Heights Community

January 12, 2022

Overview
Greenlink Transit Authority (GTA) is proposing to construct a new bus operations and
maintenance facility at 205 Arcadia Drive. The Bus Operations and Maintenance Facility will
include administration and operation areas for GTA as well as maintenance and service bays to
fuel and wash the buses. A community meeting room and other community site amenities are
planned.

The Project will consist of a new 18,000-square foot operations and administration building,
connected by an enclosed bridge to a separate 42,000-square foot maintenance and service
building for GTA, drive aisles, up to 186 passenger vehicle parking spaces, and up to 84 bus
parking spaces.

The project will also include a memorial for the former Washington High School that
previously occupied the project property and recreational facilities and/or greenspace will be
implemented between the New Washington Heights neighborhood and the proposed facility
to serve as a buffer. Additional amenities include trails and open lawn on the project
property that will be open to the public. A community room is proposed as a place for GTA
Board meetings, general meetings, events, etc. for the public. GTA has also committed to
transition of their fleet from diesel to electric by 2025.

Calm Waters Group conducted an initial third party review of planning documents from GTA and
provides recommendations for community members to address key concerns around
environmental justice, cumulative impacts, air quality, water quality and noise.
Key Findings
Environmental Justice and Racial Equity

The Transportation Equity analysis by the GTA contractor, Main Street Connections includes a
minimal analysis of environmental justice of the proposed facility. The Transit Equity Analysis
Study (May 2021) prepared for the Project was completed to comply with FTA’s Title VI, Civil
Rights regulations. This facility will be constructed utilizing grant funds received from the
Federal Transit Administration (FTA), and FTA’s Title VI, Civil Rights regulations for the
proposed operations and maintenance facility states: Title 49 CFR Section 21.9 (b)(3) states “In
determining the site or location of facilities, a recipient or applicant may not make selections with
the purpose or effect of excluding persons from, denying them the benefits of, or subjecting
them to discrimination under any program to which this regulation applies, on the grounds of
race, color, national origin; or with the purpose or effect of defeating or substantially impairing
the accomplishment of the Act or this part.” Title 49 CFR part 21, Appendix C, Section (3)(iv).1
FTA’s definition of a disparate impact from (FTA C 4702.1B) – “refers to a facially neutral policy
or practice that disproportionately affects members of a group identified by race, color, or
national origin, where the recipient’s policy or practice lacks a substantial legitimate
justification and where there exist one or more alternatives that would serve the same
legitimate objectives but with less disproportionate effect on the basis of race, color, or
national origin.”

“If GTA determines that the location of the project will result in a disparate impact on the
basis of race, color, or national origin, the recipient may only locate the project in that
location if there is a substantial legitimate justification for locating the project there, and
where there are no alternative locations that would have a less disparate impact on the basis
of race, color, or national origin.”

On January 27, 2021, President Biden signed Executive Order (EO) 14008, “Tackling the
Climate Crisis at Home and Abroad” which created a government-wide “Justice40 Initiative” that
aims to deliver 40 percent of the overall benefits of relevant federal investments to
disadvantaged communities. This Order aims to benefit environmental justice communities
rather than harm them.

Because this site is funded by the federal government, EJ SCREEN is a standard

measurement tool used by federal agencies to conduct environmental justice analysis, and
recommended by Biden’s Justice40 Initiative. We evaluated the site using EJ SCREEN. A
summary is below. As noted the community is located in an area of high environmental justice
concern according to the US EPA. Further as noted in Table 1 the community has a number of
existing pollution burdens and social vulnerabilities that should be addressed by GTA in a
Cumulative Impacts analysis. The community is already burdened with air pollution from
1 These requirements are defined in FTA’s Circular C 4702.1B, dated October 1, 2012. Chapter
III, Section 13 refers to the Determination of Site or Location of Facilities.
Particulate Matter, Ozone, and diesel that is more than 80 percent of other communities in the
State. The community is also ranked high in terms of proximity to Superfund sites and potential
for lead paint - both of which could exacerbate environmental health impacts in the community.
Lastly, GTA’s equity analysis did not include factors for social vulnerability ranked high in the
EJSCREEN analysis, including young children - who are active in afterschool programs at the
nearest property - the Happy Hearts Community Center.
Changes in Zoning

In addition to the inadequate environmental

justice analysis, to complete the construction of
the facility, the agency was required to change
land use zoning to allow industrial development
in a residential area. The report falsely notes
that “The study area is heavily developed with
both commercial and industrial business, and a
relatively low residential component.”

The Categorical Exclusion Report notes that

the project area land use designation is
“School” and zoning Single Family Residential.
The report further notes, “the Project is not
consistent with the existing land use
(designated as School, but currently vacant),
but is consistent with the future land use
designation (Mixed Employment Center).” This
counters the intent of the Title VI regulations for
two reasons. First, GTA essentially expands the
industrial zoning into a historically black residential neighborhood, the very definition of
environmental injustice. The community did not have reasonable expectations that they would
be exposed to industrial pollution when they moved into their homes, given this property was not
zoned or planned for industrial development. Second, GTA states that a bus maintenance
facility fits within expectations of the future land use designation of “Mixed Employment Center”,
which is not accurate and is outlined below. The report also notes that the New Washington
Heights neighborhood may be significant for its role in community planning and development
and Black heritage; therefore, it may be eligible for the National Register of Historic Places
(NRHP) under Criterion A for community planning and development as a historic district. It is
clear that the proposed GTA maintenance facility will alter the character of New Washington
Heights.

As noted in “Plan Greenville County”2, adopted in 2019, Mixed Employment Center is defined
as: “Mixed Employment Centers are a new type of office park or corporate campus-like
developments geared toward meeting the needs of mid- to large businesses. Typical features
include signature architectural elements and a campus-style development pattern that connects
jobs to amenities and places of residence in a well-organized fashion.” Further the Plan notes,
“Mixed employment centers can become the job hubs of the future. These centers provide an
abundance of employment and housing options by leveraging access to regional highway and
freight systems, but they require local transit and pedestrian connections to flourish. Mixed
employment centers can include restaurants and retailers to provide everyday shopping and
dining options for employees and residents, and high-quality open space can offer daytime
exercise opportunities and help promote quality of life for the area workforce.”

In no way does an industrial bus maintenance facility meet this definition, nor should the County
and City assume that adjacent neighborhoods would be comfortable with this significant change
in zoning. The most reasonable zoning that would fit a bus maintenance facility in the Plan
would be “Flex Industrial”. The Plan states that “Flex Industrial may accommodate large format
users with back-of-house spaces for industrial and warehouse uses as well as front-of-house
office and commercial space. Landscaping requirements should screen development from the
right-of-way and neighboring properties.” However, given this definition, the facility is not
allowable per the Comprehensive Plan. The GTA should provide justification for 1) moving
industrial development into a residential neighborhood and 2) for classification as Mixed
Employment versus Flexible Industrial. This misclassification could have significant, and
negative impacts on exposure to pollution, noise and vibration, aesthetics, and property values.
It is up to GTA, and the funder, FTA to address, and mitigate this damages. The agencies
should also survey the surrounding community for the potential impacts to displacement and
neighborhood change as a result of this development.

Lastly, if the site were considered a Mixed Employment Center, GTA should provide local
preference for employment to surrounding neighborhoods as a “Good Neighbor” hiring practice.
The community could ask for GTA to engage in a discussion regarding workforce development
and job training.

2 http://www.greenvillecounty.org/apps/comprehensiveplanblog/blog.aspx
Cumulative and Indirect Effects

The report notes that “The Project would have a negligible contribution to cumulative effects on
environmental, cultural, and socioeconomic resources…” because no other City or County
projects are planned near to the project property. GTA does not address the cumulative impacts
of multiple past historical industrial impacts on the community, which resulted from permitting
decisions made by the City, and have led to pollution burdens in the community. Examples
include a large concrete supply company, auto body shop, and tire shop to the immediate south
of the community and two additional auto shops to the immediate west. The Norfolk-Southern
railroad line goes through the community and contributes to neighborhood impacts from air
pollution, noise and vibration. Additionally, Greenco Beverage Company is immediately west of
the community, and has contributed to water pollution based on conversations with the
community.

Air Pollution

GTA’s analysis of growth at the facility assumes the buildout for the facility is year 2029 and will
include up to 185 employees, 88 transit vehicles, and 32 maintenance/support Vehicles. The
number of new vehicles, especially those using diesel fuel will drastically increase, leading to
local air pollution burdens.

Motor vehicles emit carbon monoxide (CO), nitrogen oxide (NOx), hydrocarbons (HC),
particulate matter (PM), sulfur dioxide (SO2), and lead (Pb) (listed in order of decreasing
emission rate). The primary pollutants from motor vehicles are unburned hydrocarbons (HC),
nitrogen oxides (NOx), CO, and particulates. Diesel exhaust also contains volatile
hydrocarbons, benzene, formaldehyde and arsenic. The GTA report dismisses the public health
implication of diesel buses and the increased traffic for employees working onsite.

Air pollution is the largest environmental cause of disease and early death in the world and is
associated with more than 5 million global premature deaths every year.3 NOx emissions also
contribute to acid deposition, regional haze and the eutrophication of water bodies.4
Poor air quality results in serious and often deadly health outcomes, especially for those already
at risk, including children, the elderly, Black, Indigenous and People of Color and people in
disadvantaged communities. Black people and lower income populations are at a greater risk
for health impacts from fine particulates and have a higher risk of premature death from ozone

3 Academy of Science of South Africa, Brazilian Academy of Sciences, German National Academy of Sciences Leopoldina, U. S.
National Academy of Medicine and U. S. National Academy of Sciences. 2019. Air Pollution and Health – A Science-Policy Initiative,
Annals of Global Health, 85, 140, 1-9. https://www.annalsofglobalhealth.org/articles/10.5334/aogh.2656/
4 Riley, S., Wallace, J., & Nair, P. 2012. Proximity to Major Roadways is a Risk Factor for Airway Hyper-Responsiveness in Adults.
Can. Respir. J., 19(2):89-95. McConnell, R. et al. 2010. Childhood Incident Asthma and Traffic-Related Air Pollution at Home and
School. Envtl. Health Perspect.,118(7):1021-6. Huynh, P. et al. 2010. Residential Proximity to Freeways is Associated with
Uncontrolled Asthma in Inner-City Hispanic Children and Adolescents, J. Allergy (Cairo). Chang, J. et al. 2009. Repeated
Respiratory Hospital Encounters Among Children with Asthma and Residential Proximity to Traffic. Occup. Envtl. Med., 66(2):90-8.
Salam, M.T., Islam, T, & Gilliland, F.D. 2008. Recent Evidence for Adverse Effects of Residential Proximity to Traffic Sources on
Asthma. Curr. Opin. Pulm. Med., 14(1):3-8.
and particle pollution than Whites.5 In 2017, approximately 107,500 people died prematurely in
the U.S. due to health burdens from ground level ozone (smog) and fine particulate matter
(PM2.5).6 A newly published study estimates that more than 20,000 people die prematurely
every year as a result of the health burden from motor vehicle pollution on our roads and
highways. And millions more suffer from respiratory illnesses, lost work days and lost school
days.7

The transportation sector is the largest source of air pollution in the U.S. including harmful
tailpipe pollutants, including ozone-forming NOx, PM2.5, and hundreds of toxic contaminants.
Hundreds of studies over multiple decades have found that exposure to vehicle
pollution causes adverse health impacts in utero, in infants and children, and in adults, and
those that live closest to our nation’s roads and highways face the greatest harm.They
concluded that the area most impacted is within 300 to 500 meters of the Highway.8 Dirty air
contributes to and exacerbates upper and lower respiratory infections and asthma, risk of heart
disease, reduced cognition in older men, increases preterm birth and hypertensive disorders in
pregnancy, and contributes to Autism Spectrum Disorder (ASD), and may also affect pediatric
cancer and infant mortality and weight.9

The closest residences, which are in the New Washington Heights neighborhood,
are approximately 550 ft west of the proposed bus parking area. The report notes “While the
addition of transit facilities can cause slight local increases in certain air quality pollutants, a
reduction of emission levels at a regional scale due to a smaller number of passenger vehicles

5 EPA and NIH. 2017. NIEHS/EPA Children’s Environmental Health and Disease Prevention Research Centers Impact Report.
https://www.epa.gov/sites/production/files/2017-10/documents/niehs_epa_childrens_centers_impact_report_2017_0.pdf.;Padula A,
Mortimer K, Tager I, Hammond S, Lurmann F, Yang W, Stevenson D, et al. 2014. Traffic related air pollution and risk of preterm
birth in the San Joaquin Valley of California. Annals of Epidemiology, 24(12), 888-895.e4.
http://www.sciencedirect.com/science/article/pii/S1047279714004463. Cossi M, Zuta S, Padula AM, Gould JB, Stevenson DK and
Shaw GM. 2015. Role of infant sex in the association between air pollution and preterm birth. Annals of Epidemiology, 25(11), 874-
876. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4671488/; Padula AM, Noth EM, Hammond SK,
Lurmann FW, Yang W, Tager IB and Shaw GM. 2014. Exposure to airborne polycyclic aromatic hydrocarbons during pregnancy and
risk of preterm birth. Environmental Research, 135, 221-226. https://www.ncbi.nlm.nih.gov/pubmed/25282280; National Toxicology
Program. 2019. NTP Monograph on the Systematic Review of Traffic-related Air Pollution and Hypertensive Disorders of
Pregnancy.
https://ntp.niehs.nih.gov/ntp/ohat/trap/mgraph/trap_final_508.pdf; Volk H, Hertz-Picciotto I, Delwiche L, Lurmann F and McConnell
R. 2011. Residential proximity to freeways and autism in the CHARGE Study. Environmental Health Perspectives, 119(6), 873-877.
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3114825/; Ward-Caviness, C., W. Kraus, C. Blach, C. Haynes, E. Dowdy, M.
Miranda, R. Devlin, D. Diaz- Sanchez, W. Cascio, S. Mukerjee, C. Stallings, L. Smith, S. Gregory, S. Shah, L. Neas, E. Hauser.
2018. Associations Between Residential Proximity to Traffic and Vascular Disease in a Cardiac
Catheterization Cohort. Arteriosclerosis, Thrombosis, and Vascular Biology, 38(1):275-282.
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5972827/; Power MC, Weisskopf MG, Alexeeff SE, et al. 2011. Traffic-related air
pollution and cognitive function in a cohort of older men. Environ Health Perspect, 119:682–687.
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3094421/
6 2020 EDF - Accelerating to 100% Clean:Zero Emitting Vehicles Save Lives, Advance Justice, Create Jobs
7 U.S. EPA. 2019. Integrated Science Assessment (ISA) for Particulate Matter, Final Report.
EPA/600/R-19/188.; Kioumourtzoglou MA, Schwartz J, James P, Dominici F, Zanobetti A. 2016. PM2.5 and mortality in 207 US
cities: Modification by temperature and city characteristics. Epidemiology, 27: 221-227. https://pubmed.ncbi.nlm.nih.gov/26600257/
Di Q, et al. 2017. Air Pollution and Mortality in the Medicare Population. N Engl J Med, 376:2513-2522.
https://www.nejm.org/doi/full/10.1056/NEJMoa170274; Bell ML, Dominici F. 2008. Effect modification by community characteristics
on the short-term effects of ozone exposure and mortality in 98 US communities. Am J Epidemiol. 167: 986-997.
https://pubmed.ncbi.nlm.nih.gov/18303005/
8 Health Effects Institute. 2019. State of Global Air 2019. https://www.stateofglobalair.org/sites/default/files/soga_2019_usa.pdf
9 Kenneth F Davidson et al. 2020. The recent and future health burden of the U.S. mobile sector apportioned by source. Environ.
Res. Lett. 15 (7) Table 4 and Figure 1.. https://doi.org/10.1088/1748- 9326/ab83a8
resulting from enhanced transit is anticipated.” Essentially, GTA is creating a sacrifice zone in
New Washington Heights for the greater good of the region.

Reference Air Monitoring Stations

The GTA report on air quality references two air quality monitors within the Greenville County
area that were considered at 133 Perry Avenue in Greenville and at 510 Garrison Road
(Hillcrest Middle School) in Simpsonville. 133 Perry Ave is 4 miles south of the site and south of
downtown Greenville. 510 Garrison Road is 20 miles south of the site, and not close to
Greenville. Both monitoring stations are south of the site, with the second site being outside of
Greenville. It’s important to note that both sites are south of the proposed bus facility. GTA did
not provide evidence that these sites are representative of the proposed bus facility, nor did they
make reference to the direction of air pollution flow in the region. While we recognize it can be
difficult to find active air monitoring equipment, best practices would include reference sites in
different cardinal directions of the site, and where possible to engage the community in air
monitoring near the site. The US EPA encourages community air monitoring as a public
participation tool.

Omission of PM2.5 and PM10 Analysis

The GTA report notes that “This project is within an attainment area for PM2.5 and PM10 and
does not include significant increases in diesel traffic. Therefore, no quantitative PM2.5 or PM10
analysis is required.” Regardless of whether the current area meets EPA’s standards for air
pollution, GTA has an obligation to the community to understand the impacts of the bus facility
and the transportation and maintenance of the buses on particulate matter. As noted above PM
emissions have a significant impact on the health of neighboring communities.

We Recommend GTA and/or FTA complete the following activities:

● Conduct an analysis of the potential air quality impacts of the operations and
maintenance of the buses on the surrounding community, including PM2.5 and PM10.
● Install onsite air quality monitoring devices to provide the community with data on all
potential pollutants from operations of the facility.
● Implement enhanced mitigation strategies, in coordination with the community, such as
those below.

GTA could consider additional mitigation strategies including:

● Designating the site a no-idle zone

● Committing to accelerated transition from diesel to electric buses, focusing on the oldest
and most-polluting buses in the fleet first
● Working with the community to develop clear and transparent conflict mediation
approaches to address community concerns and needs
 ● Working with the community to develop practices to reduce traffic, noise, and vibration
impacts
● Implementing pollution controls to meet no-emission standards for air and water
resources.

Water Quality

According to US EPA’s Enviroscreen, the site is in the Brushy Creek-Reedy River watershed
and is in the headwaters, making it particularly sensitive to pollutants and development. The
Project would convert approximately 11 acres of existing vegetated area to impervious area,
which may impact water quality; this will be mitigated with implementing best management
practices as part of the design and construction of two stormwater retention areas.There is
limited data from the State of South Carolina or County of Greenville on the creek that runs
alongside the site, however the community has noted that the New Washington Heights
neighborhood floods more since the school was demolished and that sinkholes and severe
erosion are increasing along roads. Additionally historic water quality impacts have occurred
from polluted runoff from upstream properties such as the Humane Society and runoff from the
railroad tracks. For this reason, the additional impervious surface created by GTA could
increase localized flooding in the New Washington Heights neighborhood.

According to EPA most of the waterways are already polluted in the watershed10 with more than
30 percent developed with impervious surfaces, and any additional runoff or seepage into the
groundwater from the bus facility will make conditions worse. The GTA report notes that “an
unnamed tributary of Richland Creek is located approximately 900 feet west” of the project area.
Although the GTA report does not appear to place any value on the creek, the City of Greenville
has committed to restore Richland Creek to reduce flooding as part of their Stormwater
Management 2.0 plan throughout other parts of the City.11 Because the site is in the headwaters
of the creek, reducing runoff can reduce downstream flooding and erosion.

We Recommend GTA and/or FTA complete the following activities:

● Work with the County of Greenville and/or State of South Carolina to establish a long
term water quality monitoring station at the site to support hydrology and water pollution
monitoring so that the community can be alerted to flood risks and potential water quality
violations.
● Provide evidence that the site development will improve localized flooding and erosion
conditions at adjacent sites, both reducing existing flooding and future chances of
flooding and erosion.

10https://mywaterway.epa.gov/community/205%20Arcadia%20Dr,%20Greenville,%20SC,
%2029609,%20USA/identified-issues
11 https://richlandcreekwater.wordpress.com/the-projects/richland-creek-mainstem/
Recommendations
Federal Transit Administration

Engage with FTA staff12 to explore options for 1) a more in-depth social equity analysis, 2)
meaningful and inclusive engagement, 3) in-depth air quality impacts analysis, and 4) a
community-based agreement. GTA acknowledges that FTA may request, at its discretion,
information other than that required by this Circular from a recipient in order for FTA to
investigate complaints of discrimination or to resolve concerns about possible noncompliance
with DOT’s Title VI Regulations.

Greenville Transit Authority (Greenlink)

Engage with GTA to:

● Better understand the agreement for transition of their fleet to all-electric by 2025 and to
explore early transition options here. Consider existing or upcoming funding sources
such as the State of South Carolina’s Diesel Reduction Grants to accelerate transition.
● Ask that an anti-idling policy be developed for the facility. Examples include:
○ Idle Reduction Policy (Sustainable Environment for the Quality of Life)
○ Lexington County Anti-Idling Policy
○ SC School Bus Idling Law (Section 59-67-190, SC Code of Laws)
○ Engine Idling Control (Catawba Regional Council of Governments)

S.C. Department of Health and Environmental Control (DHEC) and County of Greenville

Ask the State and/or County establish long term water quality, erosion and air quality monitoring
stations at the site to address community concerns regarding historic and existing flooding,
erosion, and air quality challenges in the neighborhood.

Engage with Regional and National Environmental Justice Organizations

Based on this analysis, we recommended the community reach out to other environmental
justice organizations to understand additional advocacy and communications strategies,
especially related to the zoning changes and cumulative impacts.

National and Regional Organizations: NAACP could be engaged around legal and racial
injustice advocacy strategies regarding land use and zoning issues aligned with a national EJ
effort. WEACT (www.weact.org) was formed to fight this very issue in New York and now works
at the National level and likely could share thoughts. They are also leading the Justice 40
initiative mentioned earlier. Consider connecting with the Southern Environmental Law Center to
explore environmental law and advocacy strategies.

12 Staff who reviewed the GTA environmental and equity documents: [email protected] and
[email protected]
Similar Efforts: Reach out to groups with similar battles in DC. In October 2021, residents of
Brentwood, in Northeast D.C., filed a suit against the District over a plan to build a school bus
depot on a 4-acre site adjacent to a residential area. Residents say the bus terminal and parking
lot would unduly burden a neighborhood that already suffers from poor air quality and noise
pollution from numerous light industrial facilities in the area. The lawsuit alleges that the District
failed to conduct an environmental impact study, as required by D.C. law, failed to inform the
local Advisory Neighborhood Commission, as required by D.C. law, and disregarded the city’s
comprehensive plan and zoning regulations. The Brentwood residents teamed up to form a
group called Justice for Brentwood, and they’re working with the local community organizing
group Empower DC.