There were a lot of lessons learned up to this point. These are just a few.
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Mark Rivers, representing the Middleford Commons project addressed the council and provided an update.
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The first phase of the current grant work has been completed. Check the Interactive Map for more details.
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Because the land designated for The Commons has been used extensively by various petroleum based industries and businesses, the Environmental Protection Agency considers the land to be Brownfields.
Brownfields are more complicated than construction on fresh lands, because there is moderate testing and cleanup that accompanies a construction project.
For a general overview of Brownfield testing and cleanup, visit our About Brownfields section.
For the current results of The Commons testing and cleanup, visit our project progress section.
Please contact us for more specific information.
Scope. The Commons project involves an area covering eight blocks, which was initially the scope of the EPA Brownfield Grant. Considering the amount of the grant ($200,000) and the time necessary to evaluate all properties, the initial undertaking was unreasonable. A lot of time was, and money, was spent on completing Phase I ESAs for 37 properties. In reality, the focus of the investigation should have been limited to the eight properties that the Agency was required to purchase for the Commons Park.
Site Access. Absolute access to all sites undergoing a Phase II ESA is imperative. Considering that most of the sites were occupied with buildings and businesses, most of which were not under the control of the Agency, made it impossible to collect adequate samples to determine if there were any residual petroleum contamination of the site.
Redevelopment & Brownfields. Under the best of circumstance urban redevelopment is a complex undertaking. When associated with properties known to be contaminated, it becomes increasingly complicated. This is particularly true when measuring the risk involved in any particular real estate development project. The spectrum of risk ranges from absolute risk takers, i.e. we hope there will be no contamination, so let's commit and see what we find, to absolute risk avoiders, i.e. until all environmental contamination has been cleared we are not interested. Each organization has a different risk tolerance. Fiducially, government organizations, being accountable to the general public, are typically risk averse, and the more information available the better decision that can be made, including an estimate of the costs to correct. On the other hand, a lot of money can be spent to determine the extent of contamination and the cost to mitigate, with no guarantees until the site is opened up and actual mitigation occurs.
With the EPA Brownfield Grant valuable information was collected, and suspicions of contamination confirmed, or rebuked. Unfortunately, due to financial limitations, the grant was unable to estimate the cost of mitigation. The question still remains -- what is the cost to mitigate? The real question -- shall we proceed with the information we have available at this time?
Disposition and Development Agreements (DDAs). The relationship of the environmental mitigation process, land acquisition, demolition, and development needs to be clearly spelled-out in a DDA, particularly if the area has a history of contamination. In the case of the EPA Brownfield Grant the timing of the grant was not well coordinated with the DDA Process. In hindsight it would have preferable if all environmental attention were focused on the eight properties to be acquired by the Agency. This would have saved money and time.
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