Big Boxes and The Environment

Thankfully, more and more communities are requiring environmental impact assessments for major projects. Unfortunately, they tend to examine each project in a vacuum. That is, the studies examine the impacts of the individual project and not the cumulative effects of development within an area.

For example, most traffic studies simply add a flat growth rate to develop a future traffic volume projection. This is wholly inadequate and does not reflect real world conditions, because major development affects an entire region rather than just a specific site or intersection. The same holds true in terms of how vehicle-generated air pollution is evaluated. The vehicle trips generated from a project produce a certain amount of pollution. If that pollution level is within acceptable levels, it is assumed that the project does not represent a health hazard. This is a very dangerous approach, as air pollution, like traffic congestion, is a cumulative process.

In essence, many of these studies do not allow for planning but merely for allocating capacity on a first come, first served basis within the finite bounds of the existing environment. With that in mind, special attention should be focused on developing impact assessments that are truly meaningful.

Traffic, Traffic Everywhere

Big box retail is automobile dependent and automobiles are road dependent. The road systems required to properly support a big box are extensive and must be capable of handling upwards of 5,000 additional cars a day for a single big box to over 10,000 additional cars a day for a mega-center complex. Also, recognize that big box retail stores are totally dependent on heavy truck traffic for product delivery. (In fact, a typical “home improvement center” is capable of generating 35 tractor trailer trips a day.)

When dealing with the traffic issues surrounding a big box center, perhaps the most frequent oversight is the failure to recognize off-site traffic impacts. Because big boxes are frequently located on major roads, those roads themselves may have the mid-block capacity (the section of the road between intersections) to handle the traffic loads. Project engineers will focus on providing intersection improvements immediately adjacent to the project to provide ingress and egress. However, it is imperative to study the totality of the road system within the community to evaluate its impact.

As a case in point, a recent proposal in Plumstead, Pennsylvania would place a 350,000 sq. ft. mega-center on PA 611, an open access two lane highway with theoretical mid block capacities sufficient to handle the increased volume. If one were to confine the traffic study to the area immediately impacted, a clever traffic engineer could probably show that the location was acceptable from a traffic perspective. This would be an illusion. Because of the nature of the location, a majority of the vehicles going to the new mega-center would utilize an intersection known as “Cross Keys,” the intersection of PA 313 and PA 611, which is nearly three miles away and not even located in the same township as the proposed project. This intersection is considered to be among the most congested in the entire region and fails from both a volume/capacity and LOS (Level of Service) perspective. Should the project in Plumstead be approved, the additional traffic that it will generate will have a crushing effect on this intersection.

As traffic backups deteriorate from very bad to intolerable, motorists, even those not heading to the mega-center, will seek alternate routes. Unfortunately, there aren’t any good ones. Traffic will be diverted into residential areas searching for ways to bypass the bottleneck. The fundamental traffic patterns will be changed for the entire region. Please keep in mind that we are talking about an intersection that is about three miles away so that you can see how necessary a full and complete review of regional road system really is.

The Air We Breathe

Unfortunately, big box retail presents a significant opportunity for major increases in air pollution. Not only are a large number of vehicles involved, but the congestion immediately surrounding big boxes magnifies the problem. Worse yet, approximately 50% of the pollution emitted from modern vehicles occurs during the starting and shutdown cycles. With 5,000 to 10,000 vehicles a day utilizing the parking lots of big box retailers, that is 10,000 to 20,000 occasions when cars will start or stop, causing a significant increase in air pollution.

Before doing air pollution modelling, make sure that a potential shift in traffic patterns, with a regional outlook, is properly taken into account. As an example, the enormous rise in big box retail along the PA 611 corridor in Bucks County, Pennsylvania has shifted traffic volumes dramatically from the US 202 corridor. Formally a major route to shopping, traffic volumes along US 202 have actually declined substantially despite heavy development activity in the region. The declines are so significant that the need for a proposed $300 million expressway to augment US 202 is being questioned.

The reason that this issue is being brought up under the air pollution section is to stress the necessity to study the whole of the region. Despite extensive environmental studies associated with the US 202 expressway project for NEPA purposes, the harsh reality is that no one knows what the air quality situation is nor are they able to predict what it is likely to be in the future other than to reasonably guess that will almost certainly deteriorate.

Water, Water Everywhere

Water runs downhill. Simple concept isn’t it? However, this rule is frequently ignored, explaining why increased development results in increased flooding.

Rather than rehash the whole issue of stormwater management. However, there are two points that we wish to make abundantly clear:

1. Municipalities have a moral obligation to insist that Best Management Practices (BMPs) be used. No one has the right to flood out their downstream neighbors.

2. When dealing with big boxes you are dealing with LARGE quantities of water. The amount will vary from site to site and is dependent on the rainfall in your area, but here is one example and the method for calculating stormwater volume.

Impervious surface has a runoff coefficient of 0.9, meaning that 90% of the water that falls upon it will runoff.

Meadow conditions (commonly used for undeveloped land) have a runoff coefficient of 0.25, meaning that 75% of the water is absorbed on-site.

The difference between the two is 0.65.

Take the total rainfall for your area. Doylestown, PA was used in the example above, has a total rainfall of 47.93” per year or 3.99416 feet per year.

3.99416 Rainfall

X 43,560 Square feet per acre = cubic feet

X 7.48 Gallons per cubic foot = gallons

X 0.65 Gallons of runoff per acre per year when changed from a meadow to impervious

845,919 Gallons per acre.

The Impact of NPDES Permit Requirements

Section 402 of the 1972 Clean Water Act (CWA) prohibits the unauthorized discharge of pollutants from a point source into water of the United States. Phase I of the National Pollutant Discharge Elimination System (NPDES) permit program was established in 1990 under the CWA, requiring that all discharges from municipalities with a population of 100,000 or more, commercial/industrial facilities, and large animal feeding operations be permitted by the EPA or authorized state agency. These permittees must verify compliance with the permit requirements by monitoring their discharges, maintaining records, and filing periodic reports.

In December of 1999, Phase II of the NPDES Stormwater program was signed into law. The new regulation builds upon the existing Phase I program by requiring smaller communities, also known as small municipal separate storm sewer systems (MS4s), to be permitted. All MS4s that are to be regulated were required to apply for a permit by March 2003.

Although a full discussion of NPDES II is contain in our Stormwater Section, the importance of NPDES II cannot be overlooked when dealing with big boxes. Under NPDES II, a municipality becomes responsible for the quality of the stormwater running through its pipes even though it is not the municipality that is producing the stormwater. Think about the automotive fluids and product spills that grace most parking lots and you’ll realize the potential problem facing municipalities.

Thus, it is absolutely essential that all runoff be properly addressed, including cleansing, from the design stage through long term implementation. The property owner should be required, by contract with the municipality, to properly maintain the stormwater system. All costs associated with mitigating an improperly functioning system should revert to the property owner. The desirability of dedicating the facilities to the municipality is questionable and should be discussed with the municipal solicitor. However, in no case should the financial responsibility for the water quality flowing off of a private site become one that the taxpayers are forced to absorb.

Lights, Litter and Noise

You can’t smell it, hear it, or eat it and it won’t kill you in the long run, but light pollution is an increasing problem in every growing area. Glare from retail lighting is among the worst offenders and all too often seriously impacts the neighboring areas as well as casts a glow that can be seen for miles.

Few municipalities have effective lighting ordinances and the result is almost always the use of too many lights, which are too bright and placed on poles that are too high. The problem is further compounded by the use of shields that allow a major portion of the illumination to be directed sideways and upwards rather than to the ground where it would actually do some good.

The best defense against light pollution is a strong ordinance that protects the rights of those who live in your community. Suggestions for what you might consider including in such an ordinance as well as more detailed information on light pollution may be found in Sprawl section of our Environmental Resource Center.

Most communities have tried to regulate adult bookstores, but they are not the only “dirty” places that should be controlled. Big boxes are a multifaceted visual pollution source. In addition to being among the least visual appealing architecturally, big boxes produce big litter problems, much of which blows off-site. In part, the litter stems from the consumers that frequent these establishments, but it is also magnified by improper material handling by the store’s employees. Special care should be given to designing the shipping and receiving areas as well as the trash receptacles and any outside storage to make certain that they do not become a pollution source.

Noise pollution is another byproduct of big box establishments that should be addressed. There is an awful lot of activity going on at your typical big box store even without the noise from the 5,000 plus cars a day that will enter its parking lot. Depending on the proximity to residential areas, the degree to which noise is a problem will vary. In some cases, the construction of sound barriers may be appropriate even though they are hideously ugly. In others, extensive berming and plantings may suffice. Additionally, restricting the hours of operation and/or the hours for deliveries and trash collection can go a long way towards reducing noise levels to something that is bearable for the neighbors.