The stupid decision to relocate a regional EPA headquarters to an Applebee's office across from a wheatfield in the middle of nowhere
Aerial view of Kansas City, Kansas. Wikimedia Commons
In defiance of the environmental values it supposedly stands for, the
federal Environmental Protection Agency is moving its regional
headquarters from a walkable, transit-rich, downtown Kansas City
(Kansas) neighborhood to one of the worst examples of suburban sprawl
it could have possibly found, some 20 miles from downtown. The result
could nearly triple transportation carbon emissions associated with the
In addition, around 600 federal and associated civilian employees will abandon a central city at a time when the agency's own staff is writing reports
suggesting that central cities in the U.S. are making a comeback. Kansas
City, Kansas (population 145,786) is much smaller than neighboring
Kansas City, Missouri; the loss of 600 downtown jobs is a major blow to
the city's efforts to strengthen its core.
This decision is horrible in so many ways that it's hard to know
where to start. How the hell did EPA administrator Lisa Jackson sign
off on this?
Let's look at the facts. The satellite image above shows the
location of the current Region 7 headquarters in downtown Kansas City,
Kansas. It's not perfect when viewed through a smart growth and
sustainable communities lens, but it's not bad.
Now consider the new location (just above), a low-rise "landscraper"
of a building fronted by large parking lots outside of a suburb called
Lenexa, Kansas, and across the road from, among other things, a
Let's look at some analytical maps and data:
I ran the addresses for the current and new facilities through Walk Score, a site that calculates walkability, and Abogo,
the calculator developed by the Center for Neighborhood Technology that
estimates carbon emissions (and household costs) from transportation by
location. Above, EPA's current headquarters location gets a Walk Score of 62,
better than 81 percent of Kansas City as a whole (see top map of the
two just above). You can see the locations of nearby amenities on the
Walk Score map, which also identifies six bus transit lines within a
quarter-mile walk of the facility.
Abogo (the second map, just above) calculates
that an average resident in the vicinity of the current EPA Region 7
headquarters emits 0.39 metric tons of carbon dioxide per month,
slightly more than half the regional average of 0.74 tons per month.
Symbolically, it's a great location for an agency that is attempting to
address global warming. All that yellow and green on the map indicates
that the average transportation costs associated with residences in the
area are below the regional average.
(Abogo doesn't directly calculate emissions and costs associated
with commercial and civic facilities, but one can extrapolate that the
differences between good- and poor-performing locations would be even
greater because of the number of visitors associated with commercial
and civic locations.)
Now let's compare the same calculations and maps for the sprawl site to which EPA intends to move. The Walk Score is only a "car-dependent" 28. That is not only far below that of the downtown location and the
average for Kansas City sites; it is also far below the average even
for the fringe suburb of Lenexa, 86 percent of whose residents are said
to have a higher score. You could see all the nearby amenities on the
Walk Score map if there were any. Sheesh.
But, wait, it gets worse. See all that orange and red on the Abogo map? Abogo calculates
that the transportation carbon emissions associated with the new
location are a whopping 1.08 metric tons per person per month. That's
nearly three times the average associated with the current location and
one and a half times the regional average. This is not just some random corporation making a crappy location decision: This is the agency charged with protecting the environment for the United States of America.
(Ironically, EPA's new regional headquarters did, in fact, recently
belong to a corporation. The agency apparently decided that, if the
site was once good enough for Applebee's corporate honchos, it's good
enough for us.)
Well, here's what the building looks like from the "street", such as it is:
I think the parking lot between the road and the building has been enlarged since that photo was taken.
When EPA joined the Department of Housing and Urban Development and
Department of Transportation in the federal Partnership for Sustainable
Communities, I applauded them. When the partnership issued its first-year report of
achievement amidst an impressive array of actions to support local
sustainability efforts, I applauded them again. Here's one of the six core "livability principles" that EPA pledged to uphold as a participant in the partnership:
"Support existing communities. Target federal
funding toward existing communities--through strategies like transit
oriented, mixed-use development, and land recycling--to increase
community revitalization and the efficiency of public works investments
and safeguard rural landscapes."
How's that promise to support transit-oriented, mixed-use
development, and community revitalization looking now, Administrator
As for the commitment to "safeguard rural landscapes," the area of
sprawling office space where EPA will be locating is, in fact, rapidly
converting agricultural land to pavement. Directly across the road
from the EPA facility is another low-rise office park whose building
footprint is dwarfed by the size of surface parking built to
accommodate it. But adjacent to that property (and in the lower left
quadrant of the satellite image above in this post) is this farmland:
And it's not just the principles of the sustainability partnership
that the agency has decided to ignore. EPA is also thumbing its nose
at a series of federal executive orders that clearly establish
government policy with regard to facilities location. In particular,
on October 5, 2009 President Obama signed Executive Order 13514,
"Federal Leadership in Environmental, Energy, and Economic
Performance." That order makes it the policy of the United States of
America for federal agencies to "reduce their greenhouse gas
emissions from direct and indirect activities." As shown above, this
move will increase those emissions, not reduce them.
More specifically with regard to the siting of federal facilities, the order establishes mechanisms to accomplish the following:
"Ensuring that planning for new Federal facilities or new
leases includes consideration of sites that are pedestrian friendly,
near existing employment centers, and accessible to public transit, and
emphasizes existing central cities and, in rural communities, existing
or planned town centers"
"The recommendations shall be consistent with principles of
sustainable development including prioritizing central business
district and rural town center locations, prioritizing sites well
served by transit, including site design elements that ensure safe and
convenient pedestrian access, consideration of transit access and
proximity to housing affordable to a wide range of Federal employees,
adaptive reuse or renovation of buildings, avoidance of development of
sensitive land resources, and evaluation of parking management
Silly me, I had assumed that EPA actually had something to do with
drafting this order for the President to consider and sign. Now I
wonder if the agency has even bothered to read it.
Admittedly, the sprawling building looks better from the rear than
from the front. But does it look like a site in a "central business
district" that is "well served by transit," with "convenient pedestrian
access"? Maybe if you're a duck.
If this matter is litigated, which I'm starting to think might not
be a bad idea, could EPA's lawyers find loopholes enabling the agency
to avoid the intent of the order? Maybe. But the fact that the
nation's most important environmental institution would be resorting to
find reasons to escape sustainability practices that both it and the
nation's chief executive have indicated are important says all we need
to know about what a mockery of principle this decision is.
And that's not the only relevant executive order, by the way. Then-President Clinton signed Executive Order 13006, "encouraging the location of Federal facilities in our central cities." Then-President Carter issued Executive Order 12072,
requiring federal location decisions to "conserve existing urban
resources and encourage the development and redevelopment of cities"
and "give first consideration to a centralized community business area
and adjacent areas of similar character." These directives, as with
President Obama's, are still in effect. (Even then-President Nixon
issued an order to "protect and enhance the cultural environment" through historic preservation.)
Officials in Kansas City are not happy
about EPA's abandonment of downtown, as you might imagine. Neither is
former Kansas Senator and GOP presidential candidate Bob Dole, who
helped Kansas City secure the building that now houses the Region 7
staff and was built specifically for them. Dole, who now represents
the owners of the downtown building, pointed to its importance to the
city's revitalization in an opinion column in the Kansas City Star:
"The EPA building, which remains in pristine condition, has
anchored the revitalization and growth of downtown Kansas City, Kan.,
driving out much of the blight and crime that once plagued this
community. About 550 federal government employees and 122 private
employees work at Region VII headquarters. ...
"The federal government should also contemplate the effects a
move will have on Kansas City, Kan. Traditionally the federal
government has supported choosing urban sites for federal facilities
taking into consideration the economic, social and cultural conditions,
public transportation, and the economic development and employment
opportunities in the area."
Put another way, insofar as this matter is concerned Bob Dole
appears to care more about urban sustainability than the Obama
administration's EPA. (See more coverage of the opposition to EPA's
decision here, here, and here.)
A second argument advanced in favor of the sprawl site is,
ironically, that the former Applebee's building is LEED-certified while
the current building, which was built to then-prevailing green
standards in 1998 but predates LEED, is not. If that is the real
reason, it more than anything else I have come across illustrates the perversity of LEED building standards that largely ignore the environmental consequences of location. Research
shows that transportation energy use and emissions of purportedly green
buildings, when they are placed in sprawl, wipe out any benefits
conferred by the technology of the buildings themselves. I've written
about that repeatedly.
"The building is situated on a brownfield site and was planned
from the beginning to serve as a model for economically and
environmentally sustainable building practices.
"Every aspect of this building's design, construction,
operation, and maintenance was considered for sustainable applications
and practices. Water conservation is achieved through native
landscaping and low-flow interior fixtures. Building materials were
selected for their recycled content and their contribution to a healthy
indoor environment. Strategies for energy conservation range from
siting decisions and the use of daylighting to efficient HVAC
The owner of the downtown building has said that it is willing to
obtain LEED-gold certification for the building's operation and
maintenance, at its own expense, within a year.
In today's rancorous political climate, conservatives charge
that the federal government's interest in sustainability is basically a
statist plot to force Americans into a lifestyle that they don't want.
To them I say, rest easy, my friends; go back to fighting that other
statist plot, decent health care for all Americans. You have
absolutely nothing to fear from this one.
Amazingly, in this case it is by ignoring sustainability
that the government may be forcing its employees into a lifestyle and
increased costs that they likely do not want. The much-heralded
government interest in sustainability not only is not forcing ordinary
Americans to do anything: It isn't even having an effect on the
government's own practices.
This post also appears at NRDC's Switchboard. Bottom image: KansasCity.com