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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.







1601 California

Stanford University plans to build much-needed faculty housing on a former industrial parcel in the Stanford Research Park. Despite high levels of TCE in shallow soil gas, Stanford and the California Department of Toxic Substance Control have decided that standard vapor mitigation systems are not needed, and that there is no need to sample in the adjacent College Terrace neighborhood.

Download the 6-page 8.8 MB PDF.

City Place

In Santa Clara, California a developer is proposing a massive nine-million-square-foot commercial and residential project called City Place on 240 acres, most of which—183 acres—is a former landfill. The developer appears willing to spend what it takes to build a project that is not vulnerable either to vapor intrusion or land movement, but at least in this region there is no precedent to determine what it actually will take to make City Place safe.
Download the 19-page 15.4 MB PDF.

Rainbow Montessori
There are four schools and more than four hundred homes above the Triple Site trichloroethylene (TCE) plume in Sunnyvale, California. Unlike Winston-Salem, North Carolina, where news coverage triggered widespread anxiety, the Sunnyvale community did not panic when U.S. EPA’s expanded vapor intrusion investigation hit TV screens. EPA is addressing unacceptable TCE levels in five school buildings and five homes, and EPA-led sampling continues with community cooperation and support. I attribute the success of the Triple Site program to EPA Region 9’s proactive and transparent approach.

Download the 10-page, 21.1 MB PDF.

Huron CampusFar from the End in Endicott, New York
by Lenny Siegel
September, 2015

Endicott, New York is the birthplace of IBM. For decades “Big Blue” employed tens of thousands of people there. But over the same period IBM released large quantities of volatile organic compounds (VOCs) such as trichloroethylene (TCE) into the subsurface there. Since 1979, when it first reported the release, IBM has spent tens of millions of dollars addressing the contamination. Off-site groundwater remediation and vapor mitigation have been remarkably successful, but contamination in the source areas remains high. Employees of IBM’s successors at the site are still being exposed to low levels of TCE.

Download the 7-page, 1.7 MB PDF.

Hanes-LowranceVapor Anxiety at the Hanes-Lowrance Middle School Campus, Winston-Salem, North Carolina
by Lenny Siegel
June, 2015

On January 24, 2015 the Winston-Salem Journal reported that the Hanes-Lowrance Middle School Campus, in Winston-Salem, North Carolina, sat above groundwater plumes of toxic chlorinated volatile organic compounds. The company responsible for the contamination, situated immediately across Indiana Avenue from the front of the school, had been addressing the contamination source for more than a decade. The disclosure ignited a firestorm of anxiety among parents who had no idea, until the news report, that hazardous substances underlay the campus. On February 10 the school board voted to close the school, despite evidence that indoor air contamination remained below North Carolina’s exposure standard.

Download the 10-page, 610 KB PDF.

County Inn on Leong DriveMountain View, California’s Mystery TCE Hotspots
by Lenny Siegel
November, 2013

Four relatively recently discovered TCE hotspots in Mountain View, California’s North Whisman neighborhood appear separate from the massive Regional Plume associated with the MEW Superfund Study Area and Moffett Field, but studies suggest that contamination at all four sites may come from decades-old releases through sewer lines emanating from the MEW area, the birthplace of the commercial semiconductor area.

Download the 5-page, 6 MB PDF.

View from Alameda St.Jordan Downs Redevelopment, South Central Los Angeles:
Vapor Intrusion Should Not Be Ignored

by Lenny Siegel
October, 2013

The billion-dollar Jordan Downs Redevelopment Project, located in the heart of Watts in South Central Los Angeles, could end up as a model for neighborhood revitalization in low-to-medium density urban areas. The Housing Authority of the City of Los Angeles (HACLA) plans to replace a 700-unit public housing project with a sustainable urban village containing as many as 1800 mixed-income housing units, major retail stores, and recreational facilities. HACLA and its private partners plan to build several hundred new rental units on an adjacent 21-acre former steel factory site. To make it safe for housing, they plan to remove at least 33,600 cubic yards of soil contaminated with lead, arsenic, and PCBs, but they consider vapor-intrusion a non-issue, despite the presence of unacceptable concentrations of trichloroethylene (TCE) in groundwater and soil gas in the northeastern section of the property.

Download the 5-page, 5.1 MB PDF.

Building19Inside Baseball: Vapor Intrusion at the Navy Yard Mill, Dracut, Massachusetts
by Lenny Siegel
February, 2013

For several years, children who practiced baseball indoors and the adults who coached and watched them were exposed to unacceptable levels of trichloroethylene (TCE) and tetrachloroethylene (PCE) vapors at the Former Navy Yard Mill site in Dracut, Massachusetts. Not only was the property owner’s effort to reduce contamination inadequate, but building occupants (ballplayers, parents, etc.) were unaware of any contamination until the facility was closed in 2012.

Download the 4-page, 1 MB PDF.

Highway 17Rejuvenating DeLeon Springs, Florida
by Lenny Siegel
January, 2013

Some people believe that DeLeon Springs, Florida, is the Fountain of Youth that Spanish explorer Juan Ponce de Leon supposedly sought in the 16th Century, but today it’s the surrounding unincorporated community that is in need of rejuvenation. At first glance, a plume of underground petroleum contamination appears to be preventing redevelopment. However, the challenge faced by the DeLeon Springs Community Association, Inc. is complicated by issues associated with the widening of U.S. Highway 17, which serves as the community’s main thoroughfare, and the lack of modern water and sewer utility services.

Download the 4-page, 1.2 MB PDF.

Buncombe School BuildingBuncombe County Schools Property, North Carolina
by Lenny Siegel
January, 2013

In January 2012, as the Buncombe County, North Carolina Board of Education considered adding a $4 million high school to its administrative office building, Board Member Lisa Baldwin discovered that the school property was on the edge of the Square D hazardous waste site. In March the North Carolina Department of Environment and Natural Resources (DENR) asked Square D to conduct additional testing on the site to determine the potential for vapor intrusion. Thus far, groundwater and soil gas sampling have not demonstrated a risk to building occupants, but much more testing is necessary to ensure that vapor intrusion is not and will not be a problem.

Download the 5-page, 1.4 MB PDF.

Waugh Chapel constructionJersey City’s Morris Canal CDC: Persistence Pays Off
by Lenny Siegel
September, 2012

Today, more than a dozen years after its formation, Jersey City’s Morris Canal Community Development Corporation is on the verge of verifiable success. Its Pacific Landing project, containing eight affordable housing units plus a new office for the CDC, is almost completed. The new building is a testament to the persistence of MCCDC President June Jones, its board and staff, and their financial, development, and legal advisers. The tortuous process of designing, funding, and winning approvals for the project has prepared the group for larger projects that are on its horizon. It also stands as a warning to other communities: One has to be prepared for a continuing barrage of unforeseen obstacles to build one’s own project.

Download the 5-page, 3.7 MB PDF.

Waugh Chapel constructionHarlem: Learning about Vapor Exposures the Hard Way and Doing Something about It
by Lenny Siegel
August, 2012

In the Spring of 2012 tenants of the 2350 Fifth Ave. State Superfund site in Harlem, New York City, discovered that they had been exposed to unacceptable levels of volatile organic compounds in the building, and that remediation was underway in their workplaces without their knowledge. They organized, bringing press coverage and an August 17, 2012 Forum sponsored by State Sen. Bill Perkins. As a result, Sen. Perkins has proposed legislation to expand notification and disclosure requirements and state agencies have agreed to expand their investigation both in the building and in nearby apartment complexes.

Download the 5-page, 2 MB PDF.

Waugh Chapel construction“Development Cap” at Coal Ash Landfill: Village South at Waugh Chapel, Gambrills, Maryland
by Lenny Siegel
December, 2011

In Gambrills, Maryland homes and stores are being built above a former coal combustion waste disposal site, covering up the problem and possibly preventing the cleanup necessary to protect the area’s groundwater resources. To a large degree, the root of the issue lies in a regulatory loophole literally large enough to drive thousands of ash-laded trucks through.

Download the 6-page, 1.2 MB PDF.

Amherst LandfilAmherst, Massachusetts: Impediments to Solar Installations on Closed Landfills
by Robert Hersh
December, 2011

The proposed installation of solar photovoltaic arrays on the closed Amherst, Massachusetts municipal landfill illustrates why municipalities are marketing their landfills, why developers are targeting them for solar power, and how impacted neighbors can delay or prevent such installations.

Download the 6-page, 1.9 MB PDF.

MCSM SideLong-Term Management of the Manhattan Center for Science and Mathematics, New York, New York (Interim Community Guide)
by Peter Strauss and Lenny Siegel
November, 2011

At MCSM, the need for a robust, transparent long-term remedy and management plan is particularly important. Contaminated groundwater is only five to six feet below the basement, where the school cafeteria and classrooms are located. The school was built over the remnants of a Manufactured Gas Plant (MGP) facility. These facilities were known to produce several toxic byproducts, some of which remain under the school. Public health and environmental protection, as well as New York law, require the preparation of a Site Management Plan (SMP) at the same time remedies are being selected, any time contamination is expected to remain on site at the completion of remedial construction. Site management includes the operation and maintenance of engineering controls, long-term monitoring, and public notification.

Download the 12-page, 2.8 MB PDF.

Jerome Ave.Vapor Intrusion at the Old and New Bronx New School Campuses
by Lenny Siegel
November, 2011

In August 2011 the New York City Department of Education (DOE) announced that it was relocating the Bronx New School elementary school, also known as PS 51x, from its two-decade home in a leased former factory building at 3200 Jerome Avenue in the northern Bronx to a closed Catholic School two miles away. It explained that sampling conducted earlier in the year had found indoor trichloroethylene (TCE) concentrations ten times New York State Department of Health’s (DOH’s) exposure standard. Because students and teachers had been exposed to this cancer-causing chemical for months after the initial test results—and probably for years—the announcement ignited a political firestorm. Then indoor testing at the new campus showed tetrachloroethylene (PCE) levels above both EPA guidelines and ambient (outdoor) air. Based upon DOH’s outdated, unprotective PCE standard, DOE declared the new New School safe, and despite requests from parents it has announced no plans to conduct another round of sampling in the heating season, as required by DOH guidance.

Download the 11-page, 2.8 MB PDF.

Sugar MillBrownfields in “Paradise”: Kekaha’s Legacy of Industrial Agriculture
by Lenny Siegel
November, 2011

After 100 years of operations, the Kekaha Sugar Mill has for a decade stood as a contaminated blight in the heart of the southwestern Kaua'i community of Kekaha. Residents are questioning plans to conduct a “remediation,” near a Native Hawai'ian charter school, that calls for no excavation or treatment of the arsenic and dioxins in the soil. They are organizing to promote cleanup of the area to residential standards, listing of the mill complex on the “Superfund” National Priorities List, and rezoning to promote neighborhood-compatible reuses.

Download the 9-page, 6.6 MB PDF.

Lawrence GardenAddressing Food Security through Area-Wide Brownfields Redevelopment in Lawrence, Massachusetts
by Robert Hersh
June, 2011

In the spring of 2010, the City of Lawrence launched a program called the “Neighborhood Community Garden Initiative” to utilize strategically situated, city-owned brownfields for food production in poor neighborhoods. The initiative was the city’s response to what was happening on the ground. Residents in low-income neighborhoods, particularly many recent Latino immigrants, who have a tradition of gardening and running local farm stands, were developing garden plots on Lawrence’s vacant lots and brownfields without city authority or soil testing.

Download the 6-page, 2.5 MB PDF.

141st St. @ 5th Ave.PCE Vapors in the Heart of Harlem, New York
by Lenny Siegel
March, 2011

The 2350 Fifth Avenue site, between 141st Street and 142nd Street in the heart of Harlem, was an ice cream factory, an industrial dry cleaners, a school, and then a storage facility. It made headlines in 1997 when the school was evacuated due to PCE vapors inside. New York State’s Proposed Remedial Action Plan ignores the potential for vapor intrusion at the densely populated Savoy Park apartment complex (just across 141st) proposes half a cleanup for the building, and downplays vapor intrusion in the Armory across 142nd.

Download the 5-page, 2.4 MB PDF.

See also Lenny Siegel’s 2-page, April 2011 analysis of New York’s Record of Decision.

Hartford LandfillHartford Solar Landfill Project, Connecticut
by Mark Mitchell and Norbert Kovacs
March, 2011

The Connecticut Resources Recovery Authority landfill in Hartford ceased operations at the end of 2008. Now the Connecticut Coalition for Environmental Justice is organizing to have solar panels placed on the capped landfill.

Download the 3-page, 748 KB PDF.

Speonk WoodsBuilding above the Speonk Solvent Plume in Southampton, New York
by Lenny Siegel
February, 2011

The two-mile long Speonk Solvent Plume on southeastern Long Island, was discovered in 2001, but remedial action is not likely soon.  Some agencies believe that new residential developments above the plume should incorporate vapor mitigation, but the Town of Southampton chose not to impose such requirements.

Download the 4-page, 1.2 MB PDF.

Birch PlazaBuilding above the “COE” Plume in Palo Alto, California
by Lenny Siegel
December, 2010

The Birch Plaza mixed-use development in Palo Alto, California was proposed to be built above a plume of chlorinated volatile organic compounds emanating from the Stanford Research Park, but there has been no vapor intrusion investigation. Despite high soil gas readings on the property, the Palo Alto City Council approved the project, requiring only some form of notice to project tenants and owners. 

Download the 4-page, 1.2 MB PDF.

BrocktonPromoting Solar Power in Brockton, Massachusetts
by Robert Hersh
October, 2010

The construction of photovoltaic arrays on a contaminated land in Brockton, Massachusetts, illustrates that the availability of suitable land and local willingness to go solar are not enough. To build solar arrays on contaminated lands, the finances have to work. The Brockton case shows how difficult this was, but the passage of new state legislation should make similar projects in Massachusetts easier to consummate.

Download the 9-page, 3.4 MB PDF.

SCLT City FarmTaking Root: Land Tenure and Community Gardens in Providence, Rhode Island
by Robert Hersh
July, 2010

For three decades, the Southside Community Land Trust (SCLT) in Providence Rhode Island has carried on the long, but under-recognized tradition of community gardening in the United States. It has employed multiple strategies: the outright purchase of brownfields and other vacant properties, partnerships with affordable housing organizations and watershed groups, education and outreach to promote community gardening beyond individual garden plot holders, and organizing politically for more secure land tenure.

Download the 11-page, 6.6 MB PDF.

Mott HavenMott Haven Campus, Bronx, New York—Community Guide and Report Card
by Peter Strauss and Lenny Siegel
June, 2010

In preparation for the opening this fall of the new Mott Haven school campus in The Bronx, New York, CPEO has prepared this Community Guide to provide background on the site, as well as information for any community member who wishes to consult the primary documents. The Guide is accompanied by a “Report Card” for keeping track of the commitments made to the community while the school was being constructed, as well as additional tasks recommended by CPEO but not agreed to by the agencies.

Download the 18-page, 2.9 MB PDF.

Lindon ParkA Tale of Two Semiconductor Cities: Why It Took So Long to Invetigate Vapor Intrusion in Phoenix
by Lenny Siegel
March, 2010

Nearly thirty years ago a TCE plume, at least seven miles long, was discovered emanating from a Motorola semiconductor plant in Phoenix, Arizona. While U.S. EPA Region 9 undertook vapor intrusion investigations at similar sites in Mountain View, California starting 2002, the neighborhood nearest the Motorola plant was left under the jurisdiction of the Arizona Department of Environmental Quality. No vapor intrusion studies were initiated at the Phoenix site until 2010, when EPA Region 9 stepped in.

Download the 5-page, 1.9 MB PDF.

AHES CafeteriaMitigating Vapor Intrusion at the Atlantic Highlands Elementary School, New Jersey
by Lenny Siegel
October, 2009

On Columbus Day, 2009 workers at the Atlantic Highlands Elementary School, in Atlantic Highlands, New Jersey put the finishing touches on 19 subslab depressurization systems to prevent toxic vapors from entering the school building from below. The installation culminates several months of discussion, and it demonstrates how an engaged, persistent community can get health-protective results.

Download the 5-page, 1.8 MB PDF.

Felege HiywotEdible Cities: Urban Farming in Indianapolis
by Bob  Hersh
October, 2009

Faced with surplus land and weak markets for real estate development, cities such as Indianapolis have begun to consider a strategy of “re-localization,” where developing local food systems can help extract value from the city’s portfolio of vacant and abandoned properties. This policy brief considers why urban agriculture can be a means to build community assets, particular in poorer, inner-city neighborhoods. It describes how and why in Indianapolis this strategy has begun to emerge, how urban farming policies attempt to build on the city’s community garden efforts, and what challenges community groups, advocates for urban farming, and local government officials have encountered.

Download the 8-page, 2.5 MB PDF.

Behr buildingMcCook Field Neighborhood Vapor Intrusion, Dayton, Ohio
by Lenny Siegel
August, 2009

The 500-home McCook Field neighborhood in Dayton, Ohio is a major vapor intrusion site, where TCE sampling inside some homes has actually exceeded the emergency action level. U.S. EPA initiated a emergency response in 2006, and it added the site to the National Priorities List in 2009. Continuing activity is threatened by the bankruptcy of auto-manufacturer Chrysler, the responsible party to take action first, but EPA recently issued an order to Behr Thermal Systems, the current plant operator. Site neighbors, organized into BVOCAL, are insisting on a comprehensive response and perodic sampling to ensure that their homes are safe.

Download the 6-page, 1.8 MB PDF.

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 ( 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 960 KB PDF

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.


CPEO’s comments on U.S. EPA’s Draft Best Practices for Siting Solar Photovoltaics on Municipal Solid Waste Landfills
Robert Hersh and Lenny Siegel
August 29, 2012

Based upon its field studies, the Center for Public Environmental Oversight (CPEO) submitted comments on U.S. EPA’s Draft Best Practices for Siting Solar Photovoltaics on Municipal Solid Waste Landfills. We believe the Best Practices document would benefit from an added emphasis on community engagement, and the document should be written to help communities be on the same page as companies and agencies. Communities should not be seen as obstacles to solar power on landfills. Just as with remediation, projects are likely to end up better and have an easier time winning approval if communities are engaged from the start.

Using Historical Records to Assess Environmental Conditions at Community Gardens
Robert Hersh
June 2012

Despite the health and community benefits of urban gardening—fresh and nutritious food, physical activity, more attractive neighborhoods—growing food in urban soils poses potential risks. In older urban neighborhoods, before zoning segregated different land uses, housing for workers was often built within walking distance of chrome plating shops, leather tanners, mills, and so on. For decades, toxic emissions from these factories, such as cancer-causing hexavalent chromium, were carried in the air and deposited on urban surfaces and in the soil. However, to develop safe gardening strategies, prospective community gardeners can assess environmental conditions on their plots by consulting historical records, maps, and enviromental data bases, as well as interviewing neighbors.

New Schools, New Sites—in Older Cities: School Siting Practices in New Jersey
Robert Hersh
November 2009

New Jersey’s school building program and its efforts to improve public education for poor children has been one of the most ambitious in the nation. It has dealt head on with the lack of coordination between school districts and municipalities, school funding for impoverished communities, aligning economic development concerns with community centered schools, identifying sites and building schools in densely populated neighborhoods, and addressing school site contamination. With such an ambitious and large-scale program, it is not surprising that New Jersey has had it share of successes and failures.

Edible Cities: Urban Farming in Indianapolis
Robert Hersh
October 2009

Faced with surplus land and weak markets for real estate development, cities such as Indianapolis have begun to consider a strategy of “re-localization,” where developing local food systems can help extract value from the city’s portfolio of vacant and abandoned properties. This policy brief considers why urban agriculture can be a means to build community assets, particular in poorer, inner-city neighborhoods. It describes how and why in Indianapolis this strategy has begun to emerge, how urban farming policies attempt to build on the city’s community garden efforts, and what challenges community groups, advocates for urban farming, and local government officials have encountered.

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.


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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