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BROWNFIELDS

CPEO's Brownfields Assistance Project provides technical assistance and training to environmental justice and other communities where Brownfields activities are planned or underway, and we communicate what we learn to the full range of Brownfields constituencies. This work is based upon the premise that communities where Brownfields are located can play a constructive role in Brownfields revitalization-if they organize-and in turn, those Brownfields projects will better serve the communities' interests.

CPEO publishes its free Internet newsgroup, the Brownfields Internet Forum (BIF); organizes workshops throughout the United States; and convenes the Enviornmental Justice/Community Caucus at U.S. EPA's annual national Brownfields conference. CPEO staff members visit Brownfields communities, write research papers, and speak at a variety of conferences on Brownfields, community involvement, and vapor intrusion.

Though CPEO's work is designed primarily to serve grassroots communities, our services-particularly the Brownfields Internet Forum are valued by the full range of Brownfields stakeholders.


GENERAL

ASSESSMENT

EJ/COMMUNITY CAUCUS

GULF COAST RECONSTRUCTION

VAPOR INTRUSION, TCE, and OTHER VOC'S

CPEO BROWNFIELDS FIELD VISITS

MCSMIndependent Review of the Cleanup Plan for the East 115th Street Manufactured Gas Plant Site, New York, New York
by Peter Strauss and Lenny Siegel
June, 2009

The New York City school building on the East 115th Street Manufactured Gas Plant site is currently home to the Manhattan Center for Science and Mathematics (MCSM) and the Isaac Newton Junior High School of Science and Math. Though most of the Gas Plant was demolished 70 years ago, some structures and residual contamination remain on site. Consolidated Edison (Con Ed), which purchased the property from the original plant operator, and the New York State Department of Environmental Conservation (DEC) have proposed a six-part remedy. The MCSM Parents’ Association retained the Center for Public Environmental Oversight to review the site documents and prepare comments on the proposed cleanup.

Download the 20-page, 6.8 MB PDF.

SkylineListing Brooklyn’s Gowanus Canal: A No-Brainer
by Lenny Siegel
May, 2009

The Gowanus Canal stretches about a mile and a half through western Brooklyn, terminating at the Gowanus Creek arm of the New York Harbor. Despite opposition from New York City officials and developers, EPA’s proposal to list the Canal on the “Superfund” National Priorities List is a no-brainer because only the Canal, not the adjacent land, is proposed for listing, and because development is currently proposed for only a very small stretch of the Canal waterfront.

Download the 3-page, 1.6 MB PDF.



Roy-HartManaging Risk at  the Roy-Hart Schools, Middleport, New York
by Lenny Siegel
March, 2009



Vapor intrusion is probably not a current source of exposure at the Roy-Hart schools in Middleport, New York. It is not clear, however, where the TCE vapor is coming from. The data are not strong enough, consistent enough, or dense enough to provide certainty that school occupants are not and will not be exposed to unsafe levels of TCE. A long-term site management plan is called for.

Download the 5-page, 948 KB PDF.

Meeker PlumesVapor Intrusion in New York City—Greenpoint: The Tip of the Iceberg
by Lenny Siegel
February, 2009



New York State’s environ- mental agencies have been conducting high-profile vapor intrusion responses upstate, but little has been reported about vapor intrusion in New York City, where about 42 percent of the state’s population lives. However, the state’s two-year-old investigation in Brooklyn’s Greenpoint district suggests that there are few vapor intrusion sites in the City only because no one has looked.

Download the 6-page, 2.2 MB PDF.  CTS front

Flowing through the Cracks: The CTS Site in Skyland, North Carolina
by Lenny Siegel
February, 2009


The 57-acre CTS Asheville site on Mills Gap Road in  Skyland, Buncombe County, North Carolina (just outside of Asheville), is a prime example of a hazardous waste site where the problem slipped through the cracks of the regulatory system. Large quantities of trichloroethylene (TCE) and other contaminants were released into the environment from the 1950s through the 1980s, and residents reported serious health consequences—that they believe are connected with toxic exposures—at least as early as 1990. In the early 2000s, new housing was built on a portion of the original property. However, no cleanup actions were taken until 2006. Since then, investigation has accelerated, but the response still appears fragmented and insufficient.

Download the 8-page, 2.3 MB PDF. 

MH AerialIndependent Review of the 
Draft Site Management Plan for the Mott Haven Schools Complex, Bronx, New York
by Lenny Siegel & Peter Strauss
March, 2008



 CPEO comments on the January 2008 draft Site Management Plan (SMP) for the Mott Haven school campus, now under construction in the South Bronx. The School Construction Authority cleanup of this site is robust, and with proper site management, the students, teachers, and others who will occupy this site will not be at risk of unacceptable environmental exposures. While the draft SMP contains many of the elements necessary to guide long-term site management, we find that it is incomplete. The chronic health risks from exposure to contaminants on site must be taken seriously. The time to ensure the long-term safety of the site is now. The officials and consultants who design and oversee both cleanup and construction will be long gone in decades, but the need to manage the site will continue.

Download the 21-page, 3.1 MB PDF.

HopkinsA Visit to East Baltimore
by Lenny Siegel
August, 2007

The East Baltimore Revitalization Story: A Resident’s View
by Rosa Hart Burenstine
July, 2007

 On May 26, 2007 Baltimore environmental justice leader Rosa Hart Burenstine took Lenny Siegel on a tour of East Baltimore. Led by the bioscience-based East Baltimore Redevelopment Project (EBRP), this depopulated area appears to be on the verge of rebirth. Burenstine describes the promise she sees in the EBRP partnership. Siegel suggests that existing housing stock is ready for rehabilitation.

For a formatted version of Siegel’s report, with photos, download the 2-page, 700 KB PDF.

For a formatted version of Burenstine’s  report, with photos, download the four-page, 1.4 MB PDF

Danger IBMFive Vapor Intrusion Sites in New York State
by Lenny Siegel
August, 2007

 From July 31 through August 3, 2007, Lenny Siegel visited five vapor intrusion sites in New York state. He found that redevelopment does not generally provide the resources to support the cleanup of plumes migrating under neighboring homes, and that many industrial properties that are the sources of such plumes—technically brownfields—are being reused without redevelopment. Impacted community members are seeking more information on how vapor intrusion is evaluated, but even without “technical expertise” many offer important insights that deserve attention from the experts.

For a formatted version of his report, with photos, download the 6-page, 1.9 MB PDF

CorridorArea-Wide Brownfields Redevelopment in Milwaukee, Wisconsin: The 30th Street Industrial Corridor
by Bob Hersh
July, 2007

The 30th Street industrial corridor in Milwaukee, Wisconsin is an example of how area-wide brownfields redevelopment strategies can be designed to achieve both community benefits and regional planning objectives. City and state officials, local non-profits, and residents’ associations are attempting to use brownfields cleanup and redevelopment as a core part of an area-wide initiative in one of the most disadvantaged sections of the city. Located in the north central part of Milwaukee, the corridor runs five miles from north to south and is roughly a quarter of a mile wide. It is bisected by rail lines, along which scores of factories were constructed at the end of the 19th century.

For a formatted version of his report, with photos, download the 5 page, 4.4 MB DOC

MilfordTwo Connecticut Vapor Intrusion Sites
by Lenny Siegel
June, 2007

On May 29, 2007 Lenny Siegel visited two major vapor intrusion sites on the Connecticut coast, the Raymark Superfund site in Stratford and the Milford Condominiums, in nearby Milford. Connecticut was one of the first states to actively investigate vapor intrusion, and it appears to have a strong, protective program. In his brief visit he learned a number of practical lessons.

For a formatted version of his report, with photos, download the 5 page, 1.7 MB PDF

Osage BeforeDenver’s Osage Mercado: A Community Vision for a Transit-Oriented Brownfields
by Lenny Siegel
May, 2007

A community coalition has proposed a mixed-used development on a three-acre site adjacent to the 10th and Osage Light Rail Station in Denver. Their proposal calls for a year-round public marketplace, emphasizing work-sell activity and drawing upon the neighborhood’s cultural heritage. The City and County of Denver has applied for a U.S. EPA Brownfields grant to help pay for the removal of contaminated soil, with the apparent objective of advancing the community vision for the property.

Lenny Siegel visited Douglas April 12, 2007. For a formatted version of his report, with photos, download the 4 page, 1 MB DOC

Douglas SiteDouglas, Michigan: Proposed Development over a TCE Plume
by Lenny Siegel
February, 2007

The tools for evaluating, mitigating, and remediating vapor intrusion—the upward migration of toxic vapors from the subsurface—at sites with existing buildings are well proven and relatively easy to learn about. Nationally, however, much less thought has gone into determining when and where it is appropriate to develop or redevelop properties with underlying contamination with volatile compounds. Douglas, Michigan, which I visited on February 12, 2007, is a good example. A developer plans to build 64 single-family homes and 78 triplex units on about 15 acres of Douglas’ former West Shore Golf course. A plume of TCE and other pollutants flows from the former Chase Manufacturing plant, just to the southeast, to Wick’s creek, a tributary of Kalamazoo Lake that bisects the development parcel.

Lenny Siegel visited Douglas February 12, 2007. For a formatted version of his report, with photos, download the 5 page, 1 MB PDF

Asbestos & MacDonalds
BoRit Asbestos Piles, Ambler, Pennsylvania
by Lenny Siegel
February, 2007

The 38-acre BoRit Asbestos Piles site in Ambler, Pennsylvania, received asbestos production wastes for decades. It consists of a potential development parcel, a reservoir/wildlife area, and a closed neighborhood park, U.S. EPA, in partnership with the Pennsylvania Department of Environmental Protection, is in the midst of removal action, which thus far has including sampling of soil, sediment, surface water, and nearby air. Local activists are concerned that soil disturbance from the proposed development would release chrysotile into the neighborhood. Indeed, capping under Superfund regulations, as conducted as the nearby Ambler Asbestos piles site more than a decade ago, seems like a viable approach.

Lenny Siegel visited Ambler January 28, 2007. For a formatted version of his report, with photos, download the 5 page, 2MB PDF

Mott Haven Schools Complex, New YorkMott Haven Schools Complex, New York
by Lenny Siegel & Peter Strauss
January, 2007

New York City is building four new schools on a former Bronx railyard contaminated with semi-volatile organic compounds, gasoline-related contaminants, chlorinated solvents, and other pollutants. On behalf of the Bronx Committee for Toxic Free Schools, New York Lawyers for the Public Interest (NYLPI) sought and received funding from the New York City School Construction Authority (SCA) for an independent review of its plans for cleanup and construction. NYLPI contracted with CPEO to conduct the review, and CPEO executive director Lenny Siegel visited New York January 3-5, 2007. CPEO's report, authored by Siegel and Peter M. Strauss, found that the investigation and remedial planning for the Mott Haven site have been conducted professionally, and furthermore, that the SCA has committed to spending substantial resources on remedial action. However, CPEO recommended that the SCA excavate additional toxic hotspots, and it proposed that long-term management of the site be strengthened to protect better the health and well-being of schoolchildren and others who will be using the site, as well as the occupants of two, existing adjacent schools.

To download the full 18-page, 1.9 MB, report as a PDF file …

Rhode Island SchoolsProvidence, Rhode Island Schools
by Lenny Siegel
October, 2006

On September 29, 2006 I visited a number of brownfield sites in Providence, Rhode Island. My host was Steve Fischbach, an attorney with Rhode Island Legal Services (RILS). Below I describe the two school sites we visited, the occupied Pell Complex and the un-named high school under construction at the former Gorham Silver property. I have added information about the Gorham site from neighborhood activist Robert Dorr as well as from a draft Health Consultation recently released by the federal Agency for Toxic Substances and Disease Registry (ATSDR).

For a formatted version of this report, with photos, download the 7 page PDF

New Bedford, MANew Bedford, Massachusetts
by Lenny Siegel
September, 2006

On September 28, 2006, I visited New Bedford, Massachusetts. My principal host was John "Buddy" Andrade, of the Old Bedford Village Community Development Corporation. One of the oldest European settlements in the United States, New Bedford originally gained renown as home to whaling fleets. Later, its textile mills played a major part in the American industrial revolution. Today it is the number one fishing port in the continental United States. (continued)

To download this 7-page, 2.7 MB PDF file with pictures, click on the link above.

Gates DenverGates Rubber, Denver, Colorado
by Lenny Siegel
September, 2006

On September 7, 2006, I visited the Gates Rubber redevelopment site just south of downtown Denver. The 80-acre site, which straddles Broadway, produced belts, hoses, and even tires for the automobile industry. Established in 1911, in its heyday it provided over 6,000 workers a living wage and strong benefits. Once the nation's sixth largest rubber company, Gates began downsizing in the 1980s, as it moved operations overseas. It closed permanently in 1995. (continued)

To download this 3-page, 420 K Word file with pictures, click on the link above.

Playa Vista, Los AngelesPlaya Vista,
Los Angeles, California
by Lenny Siegel
Summer, 2006

On July 18, 2006, I visited Playa Vista, at nearly 1,100 acres one of the largest developments in the history of Los Angeles County, California. My host was activist Patricia McPherson, of the Grassroots Coalition (http://www.grassrootscoalition.org). McPherson and many others, including my parents, have opposed and/or criticized Playa Vista for its impact on one of the last remaining wetlands areas in Los Angeles, the massive seepage of methane gas from underground, and other problems, including toxic contamination. Continued ...

For a formatted version of this report, with photos, download the 1.2 MB Word Doc

Morris Canal Area, New JerseyMorris Canal Area,
Jersey City, New Jersey
by Lenny Siegel
June, 2006

On June 9, 2006, I re-visited the Morris Canal area in Jersey City, New Jersey, and met with June Jones-Hawkins, leader of the Morris Canal Redevelopment Area Community Development Corporation (MCRACDC). I first visited the area in 2002 as part of joint research project on local government and Brownfields, in which CPEO worked with the International City/County Management Association. In 2004 CPEO teamed with the city of Jersey City to hold a workshop on "Community-Led Brownfields Revitalization. (continued)

For a formatted version of this report, with photos, download the 338 KB Word Doc

Orland PondOrland Park, Illinois
by Lenny Siegel
June, 2006

On June 29, 2006 I visited the home of Tricia Krause in Orland Park, Illinois, a Chicago suburb. Krause's home appears to suffer from petroleum product vapor intrusion, and adjacent ditches and ponds are contaminated, much of the time, with an oily sheen.
(continued)

To download this 3-page, 586 K Word file with pictures, click on the link above.

Disposal Gardens wallDisposal Gardens, Torrance, California
by Lenny Siegel
May, 2006

Disposal Gardens, in Torrance, California, is one of the names for a subdivision built on former sand and gravel pits which received liquid oil wastes and reportedly received military solid wastes as well. The site is adjacent to the toxic Palos Verdes Landfill. Since construction, the subdivision has been plagued with collapsing hillsides,  cracking foundations and driveways, and discolored water bubbling up into basements and garages.

To download this 2-page, 336 K Word file with pictures, click on the link above.

For a reply from Los Angeles County Sanitation Districts engineer David Rothbart, click here.

Brisbane OilVisit to the Brisbane, California Baylands
by Lenny Siegel
March, 2006

The Brisbane Baylands comprises several hundred acres between the U.S. 101 freeway and the developed portion of the city. Roughly half is a former municipal landfill that operated in the pre-regulation area, from 1932-1967. Most of the remainder was a major Southern Pacific railyard, including tracks, a roundhouse, and shops. The City of Brisbane and a private developer are planning for a major, mixed-use, transit-oriented redevelopment of the area. Concerned residents successfully petitioned for a Community Advisory Group.

To download this 3-page, 452 kilobyte Word file with picture, click on the link above.

Gretz BreweryNorthern Liberties and South Kensington, Philadelphia, Pennsylvania
by Lenny Siegel
March, 2006

These two neighborhoods contain a mix of homes, active businesses, abandoned industrial structures and vacant lots. Northern Liberties, at least, is on the rebound, but community members are concerned than contamination may be capped, not treated or removed, and that residents are exposed to hazardous dirt and debris.

To download this 7-page, 1.1 Megabyte Word file with pictures, click on the link above.

Soundview CampusSoundview Educational Campus, the Bronx, New York
by Lenny Siegel
March 14, 2006

The Soundview Educational Campus is a high school building without playing fields or plazas, built on the abandoned Loral plant in the Bronx, New York. According to local activists, the school was built without adequate environmental investigation, and little is being done to address the larger site around it.

To download this 2-page, 692 K Word file with pictures, click on the link above.

Hopewell SuperfundHopewell Precision Superfund Site, Hopewell Junction, New York
by Lenny Siegel
March 14, 2006

A groundwater plume of trichlorethylene and trichloroethane lies under nearly 150 homes in Hopewell Junction, New York. Many homes have water filters on their private water supplies now, and many of the same residences have subslab depressurization systems to mitigate vapor intrusion. A small amount of new development is occurring within the affected area.

To download this 2-page, 720 K Word file with pictures, click on the link above.

Dupont-Stauffer LandfillDupont-Stauffer Landfill, Newburgh, New York
by Lenny Siegel
March 14, 2006

Remediation, in the form of off-site disposal of hazardous wastes and on-site consolidation of other wastes, is expected to make this 50-acre site ready for development within the next year. The owner, Stauffer chemical, has promised to donate the land to the Newburgh Community Action Committee, which is seeking partners to help turn it into open space and an Eco-Industrial Park.

To download this 2-page, 304 K Word file with one picture, click on the link above.

BROWNFIELDS BRIEFS

Youth Organizing and Brownfields
Robert Hersh
July 2007

In low-income and minority neighborhoods, young people are using brownfields as a means to organize local residents and to encourage youth political engagement. This Brief highlights the Toxic Soil Busters (TSB), a group of high school students in Worcester, Massachusetts that has developed the expertise and resources to test soils for lead in backyards and in community gardens. Not only are the students helping local residents from the city's poorest neighborhoods protect themselves from lead in soils, but they are also conducting long-term phytoremediation experiments.

Cleaning Up Brownfields through Community Land Trusts
Robert Hersh
April 2007

For neighborhood groups, addressing brownfield clusters is a complex undertaking. The properties are often a mixed bag; they can range from those in public hands acquired through tax delinquency to privately held properties subject to substantial tax lien. They may also include parcels where owners, concerned about liability for any cleanup, have chosen to mothball their properties to avoid regulatory scrutiny. Perhaps even more daunting are the institutional demands that a community-based organization faces when it attempts to broaden its mission and rebuild blighted neighborhoods. This CPEO brownfields brief discusses how community land trusts (CLTs) have addressed the challenges and, more specifically, how they have been used as a vehicle to revitalize brownfields.
To download this 6-page document as a 4.8 MB PDF file, click on the title above. 

Homes, Schools, and Parks: Where, When, and How to Build on Contaminated Sites
Lenny Siegel and Robert Hersh
December 2006

Despite the growing significance of affordable housing, schools, and park projects in the brownfields context, there is little consensus on where, when, and how it is appropriate to build these community sanctioned uses on contaminated properties. The question is not simply a technical matter of how clean is clean. The larger issue is how should community-based redevelopment efforts balance the relationship between the need for streamlined, less costly remediation and environmental protection in the long term. What are the justifications for these tradeoffs and how should these decisions be made? And if bargaining in brownfields revitalization becomes more pervasive as communities attempt to transform contaminated properties into desirable public uses— schools, parks, and affordable housing—how should community members advocate for the public interest in preserving more stringent environmental standards and maintaining adequate controls over residual contamination?

To download this 7-page document as a PDF file, click on the title above. 

The Biggest “Brownfield”
Gulf Coast Reconstruction
by Lenny Siegel
October, 2005

The recovery of Gulf Coast areas devastated by hurricanes Katrina and Rita, in the late summer of 2005, will be the largest reconstruction project in U.S. history. Evidence thus far shows that many impacted areas, particularly in New Orleans, are contaminated. Pollutants include industrial chemicals, petroleum and other hazardous substances from cars and other common products, and biological wastes. Thus, the Louisiana-Mississippi Gulf Coast has become the nation’s largest “Brownfield.”

Revitalizing these areas raises many of the same issues that have arisen at smaller Brownfield sites across the country.

•    Health Risk and Public Involvement
•    Redevelopment and Gentrification
•    Worker Training and Local Hiring
•    Debris Removal
.…

To download this 4-page document as a PDF file, click on the title above.

A Stakeholder’s Guide to “All Appropriate Inquiries” (AAI)
U.S. EPA’s new proposed rule for environmental site assessment
by Lenny Siegel
August, 2005

On August 26, 2004, U.S. EPA proposed a new rule, “Standards and Practices for All Appropriate Inquiries.”  Required by the January 2002 “Brownfields Amendments,”  when finalized this rule is expected to become the national standard for conducting “All Appropriate Inquiries,” a process commonly referred to as Phase One Environmental Site Assessment. ASTM (formerly known as the American Society for Testing and Materials), which for many years has provided the industry standards for environmental site assessments, is revising its “Standard Practice for Environmental Site Assessment” (E–1527) to be compatible with the new EPA standard. EPA based its proposal on the Brownfields Amendments and the work of a Negotiated Rulemaking committee, 25 people representing diverse interests who met several times in 2003 to develop the rule’s language.…

To download this 6-page document as a PDF file, click on the title above.

Brownfields and Vapor Intrusion
by Lenny Siegel
August, 2005

Vapor intrusion, the emerging pathway now being investigated at sites across the country, is one of the most significant obstacles to the safe use of contaminated property. The science and regulatory framework for vapor intrusion has been developed for existing structures. Only recently has anyone begun to address redevelopment at sites likely to experience vapor intrusion.…

To download this 6-page document as a PDF file, click on the title above.

JOINT STUDY WITH R.F.F.

A three-part study on Brownfields Policy in Wisconsin

The Brownfield Bargain: Negotiating Site Cleanup Policies in Wisconsin
Robert Hersh and Kris Wernstedt, 03-52

Brownfields Redevelopment in Wisconsin: Program, Citywide, and Site-Level Studies
Kris Wernstedt and Robert Hersh, 03-53

Brownfields Redevelopment in Wisconsin: A Survey of the Field
Kris Wernstedt, Lisa Crooks, and Robert Hersh, 03-54

During the past decade, the primary responsibility for addressing contaminated sites - known as "brownfields" - has shifted from the EPA to state regulatory agencies and local governments. Recent federal legislation, the "Small Business Liability Relief and Brownfields Revitalization Act," acknowledges this change. The new law increases funding for state cleanup programs and limits the authority of EPA to take enforcement actions at sites cleaned up and certified by state programs.

This decentralization of brownfields policies has made extraordinary, and at times painful, demands on state regulatory agencies to enlarge their mission from a traditional focus on environmental protection and risk reduction at brownfield sites to one that seeks to incorporate into rules and procedures other important social goals, such as economic development, efficient infrastructure use, and job creation. For many brownfields practitioners, however, this array of policies makes brownfields attractive because it provides opportunities for creative negotiations, deal-making, and the possibility of reforming regulatory practices.

The brownfields literature has little to say about how such transformations occur, or how regulatory agencies and policy entrepreneurs respond strategically to the political preferences of state legislatures; we know relatively little in detail about how new brownfields policies emerge at the state level, what groups or political interests push them forward, how these negotiations are structured, what incentives are valued by different parties, and under what conditions these inducements find favor and are actually implemented at the local level.

These questions are addressed in three new reports issued jointly by Kris Wernstedt of Resources for the Future (RFF) and Robert Hersh of the Center for Public Environmental Oversight (CPEO). In their study, which was funded by the Andrew W. Mellon Foundation, Wernstedt and Hersh rely on extensive interviews, document review, case studies, and a survey, to examine the emergence and implementation of brownfields policies in Wisconsin, one of the most innovative states in the country in brownfields.

The first paper, "The Brownfield Bargain: Negotiating Site Cleanup Policies in Wisconsin," is an historical analysis of the politics and process of brownfield development in the state during the past two decades. The second paper, "Brownfield Redevelopment in Wisconsin: Program, Citywide and Site Level Studies," relies primarily on case studies to examine how the legislative and administrative reforms of the state's brownfield program influenced the behavior and choices of local government officials and private sector participants. And in the final paper, "Brownfield Redevelopment in Wisconsin: A Survey of the Field," the authors report on a survey of some 250 brownfield stakeholders, including elected officials, staff from economic and community development agencies, attorneys, developers, and representatives from non- profit organizations. The paper analyzes how different groups perceive the environmental and economic benefits of brownfields as well as the principal barriers to more effective brownfields redevelopment.


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