We are residents of Fulton County, with many of us residents of Midtown who will be directly subjected to the adverse impacts of this proposed development, currently marketed as Midtown Medical by 272 Ponce, LLC. We are just now commenting on this application, as we were not aware of the Letter of Inducement and the Authority's consideration on the matter in December 2020. We appreciate the opportunity to submit these written comments for your consideration.

Our comments are framed within the mission of the Authority, as expressed on its web site; i.e. to stimulate economic development that, among other things, retains existing businesses and sustains quality of life. We would like to stress that we are not against development per se, but believe the development should be in concert with the spirit of your mission.

For the reasons that follow, we contend that this development will not sustain the quality of life currently enjoyed by residents and will not retain existing businesses. We, the undersigned, request that the Authority deny the application for tax abatement for 272 Ponce, LLC.

1. Promotional material of the developer, Capital City Real Estate states that the project “integrates medical office, a ground floor grocer, and a boutique multi-family component into a single mixed-use project.” The project will occupy all five contiguous lots that extend from Penn to Argonne, all controlled by 272 Ponce LLC.
   
   Nevertheless, the applicant wants to sever the residential component from the office and retail component for purposes of tax abatement, one of the consequences of which is to avoid the City’s affordable housing mandate for the residential component. By granting abatement for the office and retail portion of the project, the Authority is reducing the developer’s overall costs for the entire project and exempting them from the affordable housing mandate.
2. The construction of this development will have an adverse effect on existing businesses. One of the few businesses on Argonne, is a small husband and wife operated grocery store, just two blocks away from the proposed project. This store has served the neighborhood for well over fifty years. Granting tax abatement to a large developer who wants to bring in a large grocer can only have an adverse impact on one of the few small businesses left in Midtown. And it isn’t as if there are no other grocery stores in the area. There is a Publix within three blocks of this site, and there are 11 grocer/markets within a mile of this site. Also, there are currently several black owned businesses on the site that will inevitably be displaced. We believe maintaining existing small businesses in our neighborhood is an essential component in sustaining in-town quality of life.
3. From a design and scale perspective, these buildings are not only out of character for the historic Midtown Garden District, but are also too big for this location. As shown via Google Earth, the development will back up to residential properties. This rendering depicts how the proposed office tower would totally dwarf the existing neighbors. The tower would rise nine storeys above ground on the rear side of the building adjacent to the neighborhood. From the Ponce side, the building is more than twice as tall as any existing building on the north side of Ponce between Piedmont Avenue and Monroe Drive. The transitional height plane is an important zoning condition on transitional lots between residential neighborhoods and more densely developed corridors, and provides appropriateness of scale for the neighborhood. We believe a transitional height plane to be essential across the entire northern edge of this site. The transitional height plane ensures adequate sunlight to neighboring properties and protects quality of life for nearby residents.
4. Vehicle entry and exit to this project will be via two almost entirely residential streets, i.e. Penn and Argonne Avenues. The development as proposed will have 60 residential parking spaces, 100 public pay to park spaces, 450 spaces for offices, and 92 spaces for the grocer. Given the volume of traffic on Ponce (46,000 vehicles per day, according to the developer), it is inevitable that vehicles leaving the development will head north on these residential streets rather than waiting for lights or traffic to clear on Ponce. This is especially true on Penn, where there is no traffic signal at the intersection with Ponce. This Google Earth image shows the overwhelmingly residential nature of these two city streets. Adding commercial traffic to residential streets does not sustain or improve the quality of life for anyone living in Midtown. With more children living in Midtown, many of whom walk to bus stops or to school, this is not the time to be inviting commercial traffic to use residential streets.
5. We note that most of the former Bell South/AT&T office complex at North Avenue is vacant and looking for tenants, with over one million feet of space available. That site is obviously closer to MARTA than the proposed project and provides lots of opportunity for expansion. In addition, Grady Medical on Ponce is currently undergoing a $38M expansion, along with Emory Midtown $475M current expansion, and the addition of the already open, 12-story, Northside Midtown Medical. We fail to see any improvement in quality of life by erecting yet another office building while existing offices remain vacant.
6. We understand that the applicant has applied for a tax abatement, so that the developer can meet it’s rate of return requirements for investment. We, in principle, support tax abatement, but hold it should be reserved for projects consistent with the mission statement of the tax board and especially reserved to support applications which promote diversity among business owners and types of businesses and increase quality of life for the surrounding residents. This application meets none of those objectives.

In conclusion, for the reasons above we believe that approving this application for tax abatement will have a substantial adverse impact on existing businesses and quality of life for residents in the historical Midtown Garden District neighborhood. We don’t need another grocery store, and we don’t need more office space.