MWRD has released its proposed 2015 User Charge fees, and it is generally good news for the industrial and tax-exempt communities. Due to the rate smoothing mechanism worked out between MWRD, industry representatives, and consultants including Gabriel at the Blue Ribbon Panel, the 2015 rate changes are equal to last year’s changes, with the exception of the OM&R factor which was not part of the rate smoothing agreement. As with the 2014 rates, the 2015 rates for industrial users and tax-exempt users are the same.
Volume rates will increase, while BOD and SS rates will be reduced. The OM&R factor will decrease by 10% – however, the decreased OM&R factor is actually an increase in the amount a User owes to MWRD since it is a decrease in the tax credit going towards User Charge.
- MG: million gallons
- Klbs: thousand pounds
- Operations, Maintenance & Replacement Factor: Tax credit applied to User Charge fees
We appreciate that MWRD has listened to the concerns of the User community to keep the User Charge rates steady, as well as decrease the burden of the User Charge fees in terms of the total MWRD budget. Overall, Users are responsible for a smaller percentage of MWRD’s Inflow & Infiltration (I&I) fees in 2014/15 than they had been prior to the Blue Ribbon Panel changes last year.
Dry cleaning machine from the 1960s
When conducting a Phase I Environmental Site Assessment, Gabriel’s Environmental Professionals (EP) know that when we find evidence of a current or past dry cleaner on site, we need to pay extra attention.
Dry cleaners raise a red flag for us due to the chemicals they use to clean the clothing (chlorinated and/or petroleum solvents) and historic poor housekeeping practices. It was not uncommon for used solvents to be dumped out the back door before there were stricter environmental regulations. Chemicals were often spilled around the machines, and rarely were the shops equipped with spill containment equipment as they are now required to have.
Contamination caused by dry cleaners can impact soil and groundwater, as well as cause vapor migration and intrusion issues. Studies have shown that approximately 75% of all dry cleaners have some level of contamination.
As a result of these factors, EPs often list the former or current presence of a dry cleaner as a Recognized Environmental Condition (REC) in a Phase I. While not every dry cleaner has serious contamination, it is generally prudent to investigate areas both inside and in the back of the building.
“‘Taken to the cleaners’ can have a particularly disturbing connotation for owners, sellers, and lessors of real estate,” says environmental attorney Lawrence Schnapf.
To learn more about the key risks posted by dry cleaners and strategies for managing these risks, download “Dry Cleaners: the Environmental Scourge of Commercial Real Property,” from Mr. Schnapf’s website.
If you have specific questions about dry cleaning contamination for a property you own or are considering purchasing, contact John Polich at jpolich[at]gabenv.com or 773-486-2123.
During the course of a Phase I Environmental Site Assessment (ASTM E1527-13), Gabriel reviews historical research from several sources to help determine the previous use of the subject property and neighboring properties. Some of the key historical documents we reference when conducting a Phase I are the city directory listings.
These city directories list all known occupants of each street address for a certain address range, searching back to when city directories were first produced in that particular community. By reviewing an address range that includes the subject property and adjoining properties, we can get a more complete picture of what businesses were previously located at the subject site itself and nearby sites. For corner properties, we review city directories along both roadways because historically the properties could be addressed as either street.
Some of the city directories that we review include R. L. Polk & Co., Illinois Bell Telephone, the Reuben H. Donnelley Corporation, Cole Information Services, and the Haines Company, Inc.
Recently, Gabriel was hired to conduct a Phase I on a strip mall with a known former dry cleaner. A previous Phase I, conducted by another firm, had discovered this former cleaning operation because it was listed as a Small Quantity Generator with the Illinois EPA. When reviewing the city directories, Gabriel learned that this dry cleaner had moved within the shopping center in the 1980s, which meant that there were two storefronts that could have been affected by the dry cleaning chemicals. A previous Phase II had shown contamination in the area of the known dry cleaner, so there is a good probability that the previous storefront with the dry cleaning operation also has contamination due to similar chemical usage and housekeeping practices.
If you have questions about how Gabriel uses city directories in our Phase I research, contact Natalie Neuman, Group Leader Assessment Services, at 773-486-2123 or nneuman[at]gabenv.com.