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So Portland Brown Field App

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NARRATIVE PROPOSAL (RANKING CRITERIA FOR ASSESSMENT GRANTS)

EPA Brownfields Community-Wide Assessment Grant ProposalCity of South Portland, Maine

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Page 1 City of South Portland, Maine FY 2014 EPA Brownfields Assessment Grant

 NARRATIVE PROPOSAL (RANKING CRITERIA FOR ASSESSMENT GRANTS) 

1.  Community Needa.  Targeted Community and Brownfields

i.  Targeted Community DescriptionThe City of South Portland has a diverse working waterfront, commercial, and industrial history that

complements the rich diversity of the Greater Portland community. Dating back to the 1700s, theCity of South Portland was developed with various shipyards, canneries, and trade ports along theFore River and Casco Bay waterfront. During the 1800s and early 1900s, industrial and commercialdevelopment expanded across the City spurred by the construction of Rigby Yard, the largestrailyard in New England. During World War II, large shipbuilding complexes were constructed inthe Ferry Village neighborhood to manufacture Liberty Ships and large housing developments wereconstructed throughout the City for wartime workers and families. The City of South Portland is thesecond largest port on the eastern seaboard for marine oil terminals and bulk petroleum storagefacilities that were constructed during the latter half of the 1900s. Since the 1950s, South Portland became the retail capital of southern Maine upon construction of the Maine Mall and Mill Creekshopping centers.

After the end of World War II, the City of South Portland’s industrial prominence proved fleeting

and left the City of South Portland with numerous Brownfields sites throughout the community,including its waterfront and residential neighborhoods. The Knightville, Ferry Village, Pleasantdale,and Ligonia neighborhoods are at the core of former working waterfront, shipbuilding, boatyards, oilterminals, and various industrial and commercial businesses. Portions of these neighborhoods wererazed to make way for the industrial war effort only to be reconstructed when the war effort was nolonger needed. These neighborhoods are now densely populated by predominately low-incomeresidents (as high as 66% by US Department of HUD standards). The South Portland Greenbelt, anapproximately 5.7-mile pedestrian walkway and bike path, winds its way along numerous waterfrontBrownfield sites and through these residential neighborhoods in the City.

As various industries and commercial businesses have closed over the years, hundreds of large andsmall tracts of land and buildings have been abandoned and fallen into disrepair across SouthPortland. The City has been unable to reinvigorate industrial development of these vacant propertiessince a majority of them are located within or in close proximity to residential neighborhoods. Ifthese properties remain vacant, the buildings will continue to deteriorate, be subject to vandalism and blight, and will negatively impact the City of South Portland. Because they are currently unused,they are a drain on the City’s finances; the properties are bringing in no property tax revenues, butrequire policing and upkeep, and present significant potential liability risks. Delaying theredevelopment of these properties will lead to increasing community decline through deteriorationand vandalism, and increase the probability that the general public will be exposed to hazardousmaterials that may be present and uncontrolled at the properties.

ii.  Demographic InformationThe City of South Portland has experienced a significant growth in population (a 7% increase between 2000 and 2010), which has led to the saturation of the local real estate market and a

significant increase in housing density in potentially contaminated neighborhoods. The City has thesecond highest population density in Cumberland County, at 1,983.7 people per square mile (USCensus). As shown below, Cumberland County has a significantly higher percentage of racial andethnic minorities than other Maine counties, and the City’s minority population is almost twice aslarge as the State of Maine average. The increasing population, and influx of non-English speakingresidents, has placed a significant strain on the City’s schools and municipal finances.

South Portland has also become a regional retail service center, and draws residents from all over thestate and beyond.  This increased retail influence places a strain on the City’s infrastructure (roads,sewer, water, etc.). The result is a compromised ability of the City to invest in its local economy,

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Page 2 City of South Portland, Maine FY 2014 EPA Brownfields Assessment Grant

redevelop low-value or underutilized properties, and effectively manage sprawl along its outlyingstreets and roads. The role of service-center communities like South Portland, in a rural state likeMaine, is significant. These communities pay more into the municipal revenue sharing system thanthey receive, putting an additional strain on South Portland’s budget.1 In 2012, the State of Mainesuspended a portion of state revenue sharing, causing a significant budget shortfall ($651,585) forthe City. If the Maine State Legislature does not restore revenue sharing in 2014, the City is set to

lose over $900,000 for the fiscal year beginning July 1, 2014.A majority of low-income people, minorities, and families with young children live either in thedowntown Knightville or Ferry Village neighborhoods, where many Brownfield sites are thought toexist, or near properties that were once fuel depots or manufacturing facilities. The City views thisas a troubling issue of environmental justice, since target groups live in these locations because theytypically offer a lower cost of living. Typically, issues regarding environmental hazards and pollution disproportionately affect low-income people and their concerns are often not represented,with little or no advocacy for their interests.

iii.  BrownfieldsAs described in the introduction, Brownfields representing our industrial past are located throughoutmuch of our waterfront area which will be our target area for this Brownfield program. A primeexample is the dilapidated South Portland Shipyard and Marine Railways facility which is located at257 Front Street. This property encompasses approximately 7 acres of waterfront property in theFerry Village neighborhood. The long history of shipbuilding and other industrial uses have likelycontaminated the soils at the property with various petroleum products, volatile organic compounds(VOCs), polycyclic aromatic hydrocarbons (PAHs), metals (in particular from marine paints andcoatings), pesticides, and polychlorinated biphenyls (PCBs). This environmental contamination may be adversely impacting marine and coastal plants and animals along the waterfront and nearbyresidential properties, and has undoubtedly deterred redevelopment of the property. Another primeexample of a Brownfield in Ferry Village is the former General Electric plant which housed facilities

for boat and missile manufacturing. This property is currently a 30 acre vacant lot located directlyon Casco Bay that may be contaminated with petroleum products, VOCs, PAHs, metals and PCBs.Across the site are remnants of the former massive industrial facility including old foundations, slabsand piles of debris. Two years ago a developer approached the City with plans to construct a steelfabrication plant on the facility with the creation of 500 new jobs, but these plans have stalled dueenvironmental questions with the site.

1 The Economic Role of Service Centers in Maine; Maine State Planning Office. February 2010.

City of SouthPortland

CumberlandCounty

State of Maine National

Population: 25,088 (1)  283,921 (1)  1,328,501 (1)  313,873,685 (1) 

Unemployment: 4.7% (2)  4.8% (2)  6.1% (2)  6.6% (2) Poverty Rate: 11.3% (3)  11.1% (3)  13.3% (3)  14.9% (3) 

Percent Minority: 10.0% (4)  8.6% (4)  5.9% (4)  37.0% (4) 

Median HouseholdIncome:

$53,394 (3)  $57,159 (3)  $48,219 (3)  $53,046 (3) 

Other:

1.  U.S. Census Bureau, 2012 Estimate, State & County QuickFacts, Data Obtained January 20142.  U.S. Bureau of Labor Statistics, Local Area Unemployment Statistics (LAUS), November 1, 20133.  U.S. Census Bureau, 2008 – 2012, State & County QuickFacts, Data Obtained January 20144.  U.S. Census Bureau, 2010 Census Profile of General Population

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Page 4 City of South Portland, Maine FY 2014 EPA Brownfields Assessment Grant

b.  Impacts on Targeted CommunityThe high number of potential Brownfield sites in the City of South Portland and their occurrence indensely-populated residential neighborhoods, suggests that people are likely living in close proximity tocontaminated properties. More than half of the Brownfields sites we have preliminarily identified withinour community are located within our target area of our waterfront area with the majority of our minorityand low income population living within this target area. This suggests that these groups are

disproportionally impacted by these Brownfields sites.Many of the Brownfield sites located along or near to our Greenbelt Walkway and Eastern Trailrepresent an exposure risk to our residents, workers, and visitors to a variety of contaminants asmentioned previously. These Brownfield sites may be potential ongoing sources of impacts to thenearby Casco Bay, and these abandoned and often hazardous properties visibly detract from our beautifulwaterfront and neighborhood appeal. Extreme weather conditions threaten to accelerate the impact ofthese Brownfields to the Casco Bay. South Portland, and more importantly our waterfront target area,was recently impacted by a FEMA designated blizzard in February 2013, as well as Superstorm Sandy inOctober 2012, Hurricane Irene in August 2011 rainfall and the Halloween Nor’easter in October 2011.

In addition to the obvious environmental hazards, the presence of Brownfields in the City of SouthPortland has helped promote the migration of businesses to previously undeveloped sites where existing pollution risks are marginal or non-existent. In addition to the creation of urban sprawl, thisretail/commercial development outside the downtown center competes for consumer spending, making itmore difficult to sustain our valued in-town facilities.

Health monitoring data specifically for South Portland was not available but Cumberland County data(which South Portland is part), indicates a higher rate of many health factors as compared to nationwideaverages. Notable indicators are presented below:

Statistic Cumberland County Maine U.S.

Adults with Asthma 9.3 % 10.3 % 8.8 %

Cancer Incidence (per100,000 people)

513.2 533 456.2

Cancer Mortality (per100,000 people)

194.9 198.5 180.7

Source: 2010 Maine State Profile of Selected Public Health Indicators

The City is deeply troubled by the malignant cancer rates, which are significantly higher than thenational average. The City of South Portland would like to identify and remediate any Brownfield sitesin order to reduce the possibility that contamination is contributing to deaths from malignant cancers(such as lung, myeloma, and colorectal cancers). Historically, the mortality rate for cancers inCumberland County and the State of Maine has consistently outpaced the US average (1969-2010),indicating a dire need for research into all local, potentially contributing factors for cancer in the State. 3 

c. Financial Needi.  Economic Conditions

With seven of 21 Census Block Groups having low and moderate income (LMI) populations

exceeding 45%, and 39.5% of the population qualifying as LMI city-wide, South Portland’s level ofdistress is quite alarming when a comparison is made of its underprivileged and sensitive populationsto state and federal figures, and when the municipal costs of caring for these populations areconsidered.

As shown in the demographics table presented previously, South Portland’s percentage ofindividuals living below the poverty line is more than 1 in 10. According to the 2008-2012American Community Survey estimates, a staggering 5% of South Portland families reported annualincomes of less than $10,000. An estimated 28.4% of South Portland households rely on Social

3 Maine Annual Cancer Report 2013, ME Department of Health and Human Services

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Page 5 City of South Portland, Maine FY 2014 EPA Brownfields Assessment Grant

Security income, 3.5% on Supplemental Security Income, 4.4% on cash public assistance, and 11.3%relied on Food Stamp/SNAP benefits. The City of South Portland also has a higher percentage ofsingle-mother households (7.0%) than the Cumberland County average (6.0%).

In 2012, City of South Portland General Assistance expenses increased by $15,302 to $208,668.99.This City program provides aid to residents who are unable to provide for their basic needs. A totalof 743 individuals received emergency assistance, a number which included 138 children. Theincrease in numbers served and assistance given to local residents occurred despite substantial cuts to both state and federal aid programs.

All of the above clearly shows that despite efforts in the City to improve the economy, SouthPortland remains an area of low income with a significant level of underprivileged and sensitive populations who rely upon the City for basic services. Addressing the potentially hazardous sites inthe community, encouraging sustainable and responsible growth and promoting economic justice forall its residents, are efforts which would greatly benefit from the South Portland BrownfieldsProgram.

ii.  Economic Effects of BrownfieldsThe economic impact of Brownfields sites on the City of South Portland is significant for a numberof reasons. For one, many of the potential Brownfield sites are located in densely-populated

residential neighborhoods and along the waterfront, which would normally be greatly desired, high-value real estate. However, because of known or alleged contamination, these locations are eitherunoccupied or underutilized, resulting in a significant loss of tax revenue and no jobs being created.Additionally, these properties lessen the property values of the adjacent properties, and in some cases preclude development (i.e., people do not want to purchase a waterfront condo that overlooks adilapidated oil terminal or falling down shipyard facility).

Another issue which is particularly important to the City is tourism, particularly during the summermonths when tourists from all over the world visit the Portland Breakwater (Bug Light) and SpringPoint lighthouses and historic Fort Preble in South Portland. Brownfield sites located along thewaterfront and neighboring commercial centers have a detrimental effect on the tourism industry.Marinas, restaurants and other service industries do not realize their full potential as long as there aresites such as the run-down South Portland Shipyard and Marine Railways facility and vacant

 boatyards along the waterfront. Brownfield sites result in a larger tax burden on the local citizens,who are already feeling the strain of economic hardship as a result of vanishing industries and thenation-wide economic downturn.

2.  Project Description and Feasibility of Successa. Project Description 

i.  Describe the ProjectThe City of South Portland will utilize Brownfields funding to develop and implement acomprehensive community-wide Brownfields Assessment Program that will update the preliminaryinventory; prioritize and select sites for the program; conduct community involvement activities;characterize, assess, and plan for remediation (cleanup) and reuse at Brownfields sites in thewaterfront areas and adjoining neighborhoods of the City in order to assist in the redevelopment ofthese distressed, blighted, and otherwise underutilized properties.

South Portland will develop the Brownfields Steering Committee and select a qualifiedenvironmental professional (QEP) to perform the assessment and cleanup planning work, general program management, outreach, and reporting. The City will work with the selected QEP and theSteering Committee to perform community outreach and education, develop a thorough inventory of potential Brownfields sites in the target areas, and develop site ranking and priority criteria to selectBrownfields sites for assessment. Once a site has been incorporated into the program and its finaleligibility approved by the EPA and/or Maine Department of Environmental Protection (MEDEP),we will conduct Phase I and Phase II assessments, and plan subsequent reuse and remediation.

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Page 6 City of South Portland, Maine FY 2014 EPA Brownfields Assessment Grant

The City of South Portland and its QEP will also work closely with MEDEP, who will provideenvironmental regulatory oversight and act as Brownfields advisors. Identified threats to eitherhuman health or the environment will be evaluated by the QEP and MEDEP to help determine ifimmediate mitigation actions are necessary. Remediation planning will be completed for sites thathave identified contamination. All sites which are entered into our Brownfields program will participate in MEDEP’s Voluntary Response Action Program (VRAP), Maine’s voluntary cleanup

 program (VCP). The completion of this process will allow us to identify potential contaminationissues at Brownfield sites, evaluate remediation/reuse strategies, and ultimately return otherwisedistressed, abandoned, or environmentally stigmatized sites in our waterfront target area back toviable and sustainable reuse.

The South Portland Brownfields Steering Committee and municipal staff will effectivelycommunicate with the City’s citizens and businesses on a regular basis to ensure that the program benefits from maximum participation and input. South Portland Brownfields Steering Committeewill develop a website, conduct door to door interviews and utilize all technologies to inform localresidents, property owners and businesses. Our expected outcomes are to return the selectedBrownfield sites back to economic vitality or for the public’s use and enjoyment (e.g., green space).This is not only expected for our selected sites but also for nearby properties that have been impacted by the stigma of being proximate to these Brownfield sites. The eventual remediation of Brownfield

sites will be to minimize exposure both at the site and adjacent properties, but just as importantly tonumerous natural areas and water bodies, such as streams, ponds, and the Fore River and Casco Baywaterfront of South Portland. Additional expected outcomes of completing remedial activities ofselect Brownfields sites will be the creation of new jobs as well as the increased tax baseaccompanying the revitalization and redevelopment within the downtown and waterfront region.Where our sites have not yet been identified, it is difficult to fully quantify the impact.

The completion of the various prepared environmental reports (i.e., nine Phase I ESAs, nine QualityAssurance Project Plans, nine Phase II Investigations, and nine Analysis of Brownfield CleanupAlternatives, etc.) will track the progress of each site and will also be outputs of our program. Wewill track the reports internally and make sure each is distributed to our stakeholders for comments before finalizing. Sites selected to participate in the Brownfield Assessment Program will be enteredinto the MEDEP Voluntary Remedial Action Program. Outputs of the assessment work will betracked and measured through milestones associated with this Program. These outputs includeobtaining “No Action Assurance” letters and “Certificates of Completion” from the MEDEP.Successful Voluntary Remedial Action Program completion will ensure necessary remedial actionswere conducted to eliminate contamination and protect human health and the environment. EPAQuarterly reports as well as the EPA ACRES online database will be used to track the number ofsites assessed and the particulars of the assessed sites (i.e., acres of site, contaminants founds,assessment money spent, leveraged money, etc.).

ii.  Project Management Approach The City of South Portland and our Economic Development Director will develop this programthrough community engagement and education, development of a Brownfields Steering Committee,and selection of a qualified environmental professional (QEP) to perform the assessment and reuse

 planning work, general program management, and reporting. Activities for this program willinclude, selecting and maintaining the Brownfields Steering Committee, and providing staff supportto the Committee. The Committee will include local elected officials, as well as members of the business community, economic and community development committees, and residents with interestin the environment and community. A member of the MEDEP Brownfields staff will also be invitedand encouraged to sit on the Steering Committee.

We intend to hire a QEP immediately upon notification of award so that we are able to begin this program as soon as funds are made available. We have had discussions with some of our higher

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Page 7 City of South Portland, Maine FY 2014 EPA Brownfields Assessment Grant

 priority Brownfield sites and believe that we will be in a position to start assessing select sites rightaway.

iii.  Site Selection The City of South Portland will work with the selected QEP and the Brownfields SteeringCommittee to perform community engagement and education, develop a thorough inventory of potential Brownfield sites in the region, and develop site ranking and prioritization criteria to selectBrownfield sites for assessment. In preparation for applying for this grant and initiating SouthPortland’s program, we have already conducted a preliminary inventory of Brownfield sites,identifying more than 17 properties (12 hazardous substance properties and 5 petroleum properties)within the targeted waterfront areas and adjoining neighborhoods of the City, where they possesshigh redevelopment potential.

Once a list of potential Brownfield sites has been developed, City staff and our QEP will determineif a site meets eligible to participate in the program. We will then rank sites using criteria such asenvironmental conditions, redevelopment potential, site location, conformance with our 2012Comprehensive Plan Update, leveraging, public benefit, reuse of existing infrastructure, and potential job creation to determine the order in which sites are entered into the program. Once a sitehas been entered into the program, we will request eligibility approval by the EPA (for hazardoussubstance sites) and MEDEP (for petroleum sites).

b.  Task Description & Budget TableTask Description:Task 1 – Program and Steering Committee Development – The City of South Portland will organize theBrownfields program, conduct activities for this program, and staff a Brownfields Steering Committee oflocal elected officials, members of the business community, economic and community developmentcommittee members, residents affected by the Brownfields, and those interested in the environment andcommunity. A MEDEP Brownfields staff will be invited and encouraged to sit on the SteeringCommittee.

The City of South Portland will develop a public Request for Proposal to contract the services of a QEPto perform the assessment work. The City will review the submitted proposals, conduct interviews and perform final QEP selection. City staff with assistance from the QEP will conduct community outreach

activities, advertisement and selection, interactions with property owners and abutters, and the requiredEPA reporting (quarterly reports, ACRES, etc.). City staff will also perform general programmanagement and communication with regulatory personnel, community officials and the public. TheBrownfields Steering Committee will meet monthly to ensure that the priorities and direction of theBrownfields Program are being met. These monthly meetings will be open to the public and will be heldin locations around targeted neighborhoods.

We have budgeted a total of 160 staff hours at an average rate of $50/hour to this task, being equallydivided between petroleum and hazardous substance assessments. Our program manager will attend twoEPA Brownfield conventions (i.e., attending two conventions at an estimated $2,000 each conference forairfare, hotel and per diem, and miscellaneous expenses such as parking and taxi) divided between thetwo grants. The contractual expenses are for QEP assistance in developing outreach materials andassistance with EPA reporting. Outputs will be outreach materials and our successful program.

Task 2 – Brownfields Site Selection and Evaluation – This task will build on the preliminary inventorycompleted by South Portland in 2013. City staff and the QEP will identify potential Brownfield sites inthe community by reviewing available historic information and conducting interviews with propertyowners and project stakeholders. The City will hold a series of public meetings (minimum of two) tosolicit sites and educate local stakeholders and citizens about the Brownfields process.

Once a list of potential Brownfield Sites has been developed, City staff and the QEP will develop thethreshold and ranking criteria which will be used to determine if the site meets the established EPAdefinition of a Brownfield and is eligible to participate in the EPA program. Other considerations, suchas the potential for redevelopment, site location, reuse of existing infrastructure, and the potential for job

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Page 8 City of South Portland, Maine FY 2014 EPA Brownfields Assessment Grant

creation will be considered for ranking criteria, and will be used to determine the order in which sites areentered into the program. These sites will be prioritized based upon the criteria set forth by theCommittee. South Portland is applying for both hazardous materials and petroleum contamination in thisapplication, and sites will be categorized separately. We have budgeted a total of 80 staff hours at anaverage rate of $50/hour to this task, which we expect will be equally divided between the twoassessment programs.

Work items include preparation and distribution of site nomination forms, meeting with membercommunity officials to obtain site nominations, meeting with our QEP to discuss the preliminary sitesinventory and develop threshold and ranking criteria, assistance with property owner outreach andeducation, and site eligibility requests.

Task 3 – Phase I Site Assessments – Our QEP will conduct Phase I Environmental Site Assessments foreach selected site in accordance with the ASTM International Designation: E 1527-13 as well as the EPA“All Appropriate Inquiry” standards. This process will consist of at least one site visit, contact withregulatory agencies and review of their files, interviews with knowledgeable people regarding the site,review of available historical files and a written report for each site. These reports will consist of asummary of “recognized environmental conditions” identified for each site, and a list of opinionsregarding the site along with recommended follow-up investigations and activities. We anticipate ourQEP completing four Phase I ESAs as part of the Hazardous Substance grant (four Phase I ESAs at$4,000, and six Phase I ESA as part of the Petroleum grant (six Phase I ESAs at $3,000 each). Staff timefor each grant is budgeted as 80 hours at an average rate of $50/hr to review reports and interfacing withthe MEDEP and property owners.

Task 4 – Phase II Assessments – If the results from the Phase I ESA indicate “recognized environmentalconditions” are present at a site, additional investigations will be completed to confirm or dismiss theenvironmental conditions and to determine the nature and extent of contamination. A Quality AssuranceProject Plan (QAPP) as well as site specific QAPPs will be prepared and submitted to the EPA as part ofthis task prior to undertaking Phase II activities. The Phase II Investigation may entail monitoring welland test boring installations; test pit excavations; groundwater, soils and soil gas sampling; etc. As withall project tasks, we will continue to work with each property owner, provide public information, andreceive citizen input.

We anticipate our QEP completing four Phase II Investigations as part of the Hazardous Substance grant(four Phase II Investigations at $29,000 each), and six Phase II Investigations as part of the Petroleumgrant (six Phase II Investigations at $19,000 each). Staff time for each grant is budgeted as 80 hours atan average rate of $50/hr to review reports and interfacing with the MEDEP and property owners.

Task 5 – Remediation/Reuse Planning & Community Involvement – The Phase II Investigation data,along with available landowner or perspective purchaser and community reuse proposals will beanalyzed to develop a Remediation Feasibility Plan with integrated Analysis of Brownfield CleanupAlternatives (ABCA) for each site based on the specific or potential reuse scenario(s) for that site. TheRemediation Feasibility Plan will include remedial actions for each identified contaminant that exceedsapplicable Maine regulatory guidelines. Remedial actions will be evaluated based on cost, feasibility, andeffectiveness in protecting human health and the environment. Based on this analysis, a proposedremediation plan will be developed, taking into account the specific or potential reuse scenario(s) for that

site. Concurrently, reuse alternatives may be developed on select sites utilizing planning techniquesincluding community design charettes, potential redeveloper input, and the community’s goals for sitereuse. Public meetings are anticipated being completed for each site through our Brownfield program.Depending on the site logistics, we anticipate holding the meeting prior initiating the remediation andreuse planning to discuss the results of the assessments or after completing our remediation planning toinform and solicit feedback from the public on the selected alternative. We will continue to maintaincommunication with the public, abutters, and owners during the program.

We anticipate our QEP completing four Remediation Feasibility Plans as part of the HazardousSubstance grant (four Remediation Plans at $7,000 each plus coordination of each hazardous substance

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Page 9 City of South Portland, Maine FY 2014 EPA Brownfields Assessment Grant

site’s public meetings at $2,000 per site) and five Remediation Feasibility Plans as part of the PetroleumSubstance grant (six Remediation Plans at $4,000 each plus coordination of each petroleum site’s publicmeetings at $2,000 per site). Staff time for each grant is budgeted as 80 hours at an average rate of$50/hr to review reports; coordinate, attend and prepare for public meetings; and interfacing with theMEDEP and property owners.

Budget Table

Budget 1 – Hazardous Materials AssessmentsBudgetScenarios

Project Tasks

(programmaticcosts only)

Task 1Program

Development

Task 2Site

Selection

Task 3Phase I

Assessments

Task 4Phase II

Assessments

Task 5RemediationPlanning &Outreach Total

Personnel $6,000 $2,000 $4,000 $4,000 $4,000 $20,000

Fringe Benefits $1,500 $500 $500 $500 $2,000 $5,000

Travel $2,000 $2,000

Equipment

SuppliesContractual $2,000 $3,000 $16,000 $116,000 $36,000 $173,000

Other

Total $11,500 $5,500 $20,500 $120,500 $42,000 $200,000

Budget 2 – Petroleum AssessmentsBudgetScenarios

Project Tasks

(programmaticcosts only)

Task 1Program

Development

Task 2Site

Selection

Task 3Phase I

Assessments

Task 4 PhaseII

Assessments

Task 5RemediationPlanning &Outreach Total

Personnel $6,000 $2,000 $4,000 $4,000 $4,000 $20,000Fringe Benefits $1,500 $500 $500 $500 $2,000 $5,000

Travel $2,000 $2,000

Equipment

Supplies

Contractual $2,000 $3,000 $18,000 $114,000 $36,000 $173,000

Other

Total $11,500 $5,500 $22,500 $118,500 $42,000 $200,000

c.  Ability to LeverageEvery effort will be made in order to financially supplement the EPA Brownfield Assessment Grants andexpand the program. South Portland has extensive experience leveraging both private and governmental

monies to get properties developed and redeveloped.

South Portland is familiar with the Maine DEP 128a Brownfield assessment program that completesBrownfield assessments for municipalities across Maine as well as Maine’s newly establishedBrownfield Revolving Loan Fund (RLF). Additionally, Greater Portland Council of Governments (withwhom we are a member community) was successfully awarded a Brownfield RLF Grant in 2013 and isin the process of establishing a Brownfield RLF program. If additional assessment is necessary beyondour funding or if clean-up is required, we or the site developer, as appropriate, will apply to these Stateand Regional Government administered Brownfield programs.

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Page 10 City of South Portland, Maine FY 2014 EPA Brownfields Assessment Grant

Once a site has been assessed through our Brownfield program, we are committed to seeing the sitethrough to successful redevelopment. To facilitate necessary site remediation and redevelopment, SouthPortland will look into several avenues, including direct EPA Brownfields Cleanup Grants, Maine DEPPetroleum Insurance Cleanup Funds, Economic Development Administration (EDA) loans and grants,and other monies provided through the Maine DEP such as Petroleum or Groundwater remediationfunds. We are familiar with the funding provided by the Maine Rural Development Authority, the

Department of Conservation, and the Department of Transportation. We will look into obtaining any andall available funding to leverage the redevelopment of site assessed through the South PortlandBrownfields Program.

Additionally, we will also look into local Tax Increment Finance (TIF) funding and the utilization oflocal Community Development Block Grants. The City of South Portland has five Tax IncrementFinancing districts representing approximately $1,000,000 dollars in annual revenue that can beleveraged for redevelopment of our target areas. These TIFs have available resources that can be used forsupport of economic and environmental studies of waterfront properties, improvements to green spaceand trails, professional services and administrative costs, and associated transportation improvements.Additionally, the City is proposing a new Growth TIF that will encompass some of the target areasincentivizing private investment for redevelopment. The City does have competing interests for TIFfunding, but this funding could be potentially available for redevelopment in our target areas. The City of

South Portland has a long-running and successful Community Development Block Grant program, andwill actively use funds to assist with site redevelopment. By assessing City Brownfields, the City can better budget and use CDBG funds to strategically target and clean up blighted and contaminated areas,and prepare them for positive redevelopment. South Portland has already used CDBG to supportredevelopment efforts in the proposed waterfront Brownfields target areas. Recently, CDBG was beenused for a large-scale, two-phased streetscape improvement project ($285,435 in 2010 for sewerseparation, and $125,000 in 2012 for sidewalk reconstruction) in the Knightville target area (66.2% low-income), and for the extensive remediation of a blighted property ($138,000) in the Ferry Village targetneighborhood (45.8% low-income), to name just a few successful projects.

South Portland has pre-existing relationships with local and regional developers, and we intend toleverage these positive working relationships into results. At all stages of the project, from site selection,to remedial action planning, we will involve interested site developers. Their involvement in the projectwill ensure the work completed meets the needs and requests of potential site developers. For example, aremedial action plan can be based around potential site redevelopment plans (i.e. proposed paved parkingareas doubling as contaminated soil caps). Our goal is to transfer the sites assessed as part of ourBrownfields Program seamlessly into redevelopment.

In order to ensure the successful completion of Site Assessments through the South Portland BrownfieldsProgram, city personnel and community partners are willing to contribute manpower and resources toefficiently and effectively complete the tasks in the Brownfields Program. This may involve a widevariety of tasks, from providing site nomination forms or access to local databases, to more involvedassistance, such as participating in public outreach and education, or direct communication with propertyowners or abutters. Our City Planners, Code Enforcement Officers, Assessor and City Manager willassist with local data collection, historical records, public participation process, redevelopment and

design initiatives and overall programmatic direction. The time of these people, which is estimated atover 200 hours or $10,000 over the three year timeframe of this grant), can be seen as an in-kindcontribution to the project.

3.  Community Engagement and Partnershipsa.  Plan for Involving Targeted Community & Other Stakeholders

In order to keep the community adequately informed South Portland will provide clear and easilyaccessible information about the program itself and each proposed Brownfield site. Information will betargeted at both the broader community and businesses and households located in the immediate area

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surrounding the Brownfield site. Activities that will be undertaken to keep the community informedinclude:

•  Developing and distributing a brochure (both printed and electronic) to let stakeholders know of theBrownfield program and accompanying application/nomination forms.

•  Developing a portal on South Portland’s website where stakeholders can view updates and

information on the program in addition to notices, fact sheets and past project outputs.•  Working with municipal staff to ensure updates to the program are provided to City Council

meetings.

•  Developing a social media presence for our Brownfield program to keep connect residents informed.

•  Advertising opportunities for the public to be involved.

•  Developing a mailing list of interested parties.

City officials will engage our community organizations as well as other local business groups, healthagencies, neighborhood associations (e.g., Ferry Village Neighborhood Conservation Association) andland trusts (e.g., South Portland Land Trust) that can help energize and direct our outreach efforts as wellas raise awareness of the project’s goals. Local newspapers will be invited to cover each of the publicmeetings. We will also strive to have news articles on the planned Brownfields program printed in local

newspapers, including the Portland Press Herald, South Portland Sentry and The Forecaster, as well aslocal public access television (SPTV-Channel 2) and local radio stations. The City will also provideupdates to other organizations listed above to distribute to its members. 

In addition to the program outreach, we have proposed hosting at least one public meeting for eachBrownfield site. The public meeting is anticipated to be held after completion of the Phase IIAssessments. The purpose of this public meeting will be to educate the public on the Brownfields process and the potential benefits of Brownfield site redevelopment, inform the local stakeholders of theresults of the assessments, and provide guidance on what the remediation and reuse process entails. Ourexperience is that this type of meeting format has been particularly effective at providing reuse optionsfor greenspace, recreational activities, and architectural options for the reuse of existing buildings.

Our community is predominantly English speaking (greater than 90%)4 and thus meetings andinformation brochures will be prepared in English to reach the greatest number of people. However,upon request, we will translate outreach materials to the appropriate language.

b.  Partnerships with Government Agenciesi)  Local/State/Tribal Environmental & Health Agencies

Along with our partnership with the EPA, the two primary partnerships established as part of SouthPortland’s Brownfields Program will be with the MEDEP and the City itself. The City hascommitted funds and resources to establish and enhance this partnership. Municipal officials will fill primary implementation roles throughout the entire Brownfields Program, and several will be activemembers of the Brownfields Steering Committee. MEDEP’s Project Officers have experienceconducting and managing EPA Brownfields Grants and will also provide critical input into SouthPortland’s program. They will be partners for the successful completion of the Phase I and Phase IIAssessments and the Cleanup and Reuse planning portions of the program. They will provide input

and guidance throughout the duration of the program, including risks from potential imminenthazards identified during the assessment program, liability protections offered as part of MEDEP’sVRAP. MEDEP staff will review all technical submittals and provide guidance on remedial actionsand long-term sustainable cleanup measures for each site.

Our QEP will also ensure that the assessment work is conducted in accordance with the requirementsof the EPA Brownfields and MEDEP VRAP program. The City’s Economic Development Director,Code Enforcement Officers, Assessors, and City Manager will assist with local data collection,

4 US Census Bureau American Factfinder

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historical records, the public participation process, redevelopment, design initiatives, and overall programmatic direction in the form of participation on a Brownfields Steering Committee.

The Brownfields Steering Committee members and the City have connections to multiple agencies,including federal agencies such as HUD and the EPA; state agencies including the MEDEP; local,state, and federal elected officials; and other public entities.

ii) 

Other Relevant Federal, State, & Local Governmental Agencies The City of South Portland does not have a local health agency; however, we anticipate theinvolvement of our local hospitals (Mercy Hospital and Maine Medical Center) to assist indetermining health-based concerns. City staff will work with the Maine Health Inspector and onhealth inspections as needed. In addition, we will also work with the State Department of HealthServices (DHS) who was instrumental in the revision of Maine risk-based clean-up standards whichour QEP will be utilizing in their evaluations. We expect to work with the DHS if contaminants thatdo not have standards are found at our Brownfield sites.

c.  Partnerships with Community OrganizationsThe following organizations have submitted letters of support, affirming their commitment to the program and the ways in which they will assist the effort.

South Portland/Cape Elizabeth Community Chamber of Commerce – The Chamber of Commerce

 promote business development in our region and will assist in the promotion of the program,dissemination of materials, and in the education of the public about the program. They will also workwith the City and businesses looking to potentially locate on redeveloped properties.

The South Portland Land Trust – An organization committed to the preservation of open space, trailexpansion and community involvement projects that support a livable South Portland. They will assist insite solicitation and prioritization, and serving on the City's Brownfields Advisory Committee.

South Portland Housing Authority – The mission of the South Portland Housing Authority is to providequality housing for low to moderate income, elderly, individuals with disabilities and families inneed . The Housing Authority will offer information on affordable housing as an option for redevelopedsites, and serve as advisor to the City's Brownfields Advisory Committee.

4.  Project Benefits

a. 

Health and/or Welfare and EnvironmentA significant benefit to assessing Brownfields sites is identifying threats to public health and theenvironment that exist from out of sight contamination due to the past historic uses of these properties.Past historic uses of Brownfields sites in our community are often industrial in nature and associatedwith uses involving petroleum or hazardous substances. The majority of our Brownfield sites are locatedin our target area along the South Portland waterfront. Impacts of the Brownfields sites from historicindustrial uses are unknown until an assessment can be completed on the site, but undoubtedly theseimpacts can be far reaching whether it is from runoff of contaminants or migration of contaminant plumes into Fore River and Casco Bay.

The water bodies throughout and surrounding South Portland are not only used for recreation, but also asa means of employment. A significant number of our population make their living in a marine-relatedindustry and businesses surrounding the waterfront, whether boat maintenance, lobstering, fishing,

marinas, restaurants, and stores. Once potential human health impacts associated with our Brownfieldssites are identified and quantified during assessments, the contaminants of concern can be effectivelyremediated, reducing threats to public health and welfare.

Ultimately the redevelopment and reuse of Brownfields sites will have positive social benefits along withthe obvious public health benefits associated with assessment and cleanup of these sites. Our identifiedBrownfields sites are generally located in the waterfront and neighboring business locations. Residents,workers, and visitors to South Portland have negative perceptions of the abandoned sites, which in turnimpact their opinions of our community. Assessment and redevelopment of prominent Brownfields siteswill improve our waterfront, adjoining neighborhoods, and support sustainable business development

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within the community. Redevelopment and reuse of these underutilized properties as mixed-usedevelopments will provide much-needed affordable housing and added businesses and job opportunities.Affordable housing is seen as a particular issue for young people, workers, people with disabilities, and people of modest incomes.

South Portland is a popular vacation destination due its marinas, historic lighthouses and forts, its proximity to Portland, and beaches along the coastline. We rely on tourism-related activities for much ofour local economy. Open space, parks, recreation areas, and pedestrian walkways will be incorporatedinto the redevelopment of our Brownfields sites, enhancing the attraction of our community.

Another associated benefit to Brownfield site assessment and redevelopment involves reuse andimprovements to existing infrastructure, including roadways, intersections, and sewer, water, and stormwater systems, which will be an additive benefit to redevelopment of these unused or underutilized areas. 

b.  Environmental Benefits from Infrastructure Reuse/Sustainable Reusei.  Sustainable Redevelopment Planning, Polices, Ordinances, or Other Tools

An area of primary focus for our program has been incorporating principles of sustainability into our program goals. ABCAs and Requests for Proposals for redevelopments issued by South Portland willrequire respondents to consider “green” alternatives in their responses. The South PortlandBrownfield Steering Committee, in their September meeting discussed the need to include guidelines

that will:•  Reduce the amount of material and waste generated

•  Utilize recycled materials wherever possible

•  Minimize the disturbance or destruction of habitat or soil

•  Minimize noise disturbance

The City of South Portland desires to promote the sustainable reuse of our Brownfields sites with thegoal of reducing both housing and industrial sprawl at the outskirts of our community. PotentialBrownfield projects will focus on redevelopment plans utilizing existing infrastructures wherever possible. Revitalizing many of the existing structures on South Portland’s Brownfield sites will alsoserve as a reminder of the City’s marine and industrial heritage. In addition, nearly all of SouthPortland’s identified Brownfield sites are located in areas already serviced by public water andsewer, and are accessible to adequate parking and public transportation, all of which could andshould be used by the future redeveloped site occupant. South Portland has made a considerableinvestment in the past few years for improving our infrastructure, including expanding the areas ofour City covered by public transportation (buses); sewer, roadways, and sidewalk improvements; and plans to make substantial additional improvements. Our 2012 Master Plan Update identified thistype of infill and development as critical for the City. Redevelopment plans for new or existingstructures on sites assessed through our Brownfield program will be encouraged to implement green building designs and energy efficient standards.

Encouraging growth in urban areas and utilizing existing infrastructure/buildings for Brownfieldsredevelopment is an important part of basic Smart Growth principles and is in keeping with thequality of place initiative. Sustainable reuse of Brownfields sites, including mixed-usedevelopments, will benefit and revitalize these waterfront areas with the addition of businesses, jobs,

and affordable housing. In mixed-use redevelopment scenarios, there are numerous options forsustainable businesses that could locate to these facilities.

ii.  One Example of Equitable Development or  Livability PrinciplesBy effectively redeveloping and utilizing these sites (“infill development”) and creating employmentopportunities and housing, the need for sprawling development of new residential, commercial andindustrial centers in order to create employment opportunities within our community will be greatlyreduced.

Thus, by concentrating development to our areas with existing infrastructure, there will besignificantly less pressure to develop existing green space. Opportunities also exist for Brownfields

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Page 14 City of South Portland, Maine FY 2014 EPA Brownfields Assessment Grant

sites in the City’s downtown to be redeveloped as parks, environmental buffers or other greenspaces. An excellent example of just such a project is the Greenbelt Walkway and Eastern Trail, a public path, which showcases and helps to preserve the unique aspects of South Portland'swaterfront, including historical, cultural, archeological, marine and natural history sites, as well as to provide public access for recreational enjoyment despite its pathway going through or adjacent toeight of our preliminarily identified Brownfields. This provides an excellent opportunity for our

 program to directly impact open and green space in South Portland.

c.  Economic or non-Economic Benefits (long-term benefits)i.  Economic Benefits or Other Non-Economic Benefits

The redevelopment of Brownfield properties comes at a crucial time for the community. The regionis still recovering from the recent economic downturn, and has recovered at a significantly slowerrate than the rest of New England and the U.S. According to the New England Council’s “MaineEconomic Outlook”, while the U.S. has recovered almost two/thirds of the jobs lost in the lastrecession, Maine has recovered only 10%. The key sectors driving the recovery -education, health,construction, business, and professional services- are growing at a significantly slower rate in Mainethan elsewhere.

This program represents just such an opportunity to address the economic hindrances andenvironmental hazards that Brownfields pose, and create opportunities for economic growth, jobcreation, and improved communities and natural environment. South Portland hopes to successfullyidentify and eventually redevelop these vacant and underutilized sites, thereby responding to ademand for commercial properties from new, expanding or relocating businesses, expanding our tax base, and creating job opportunities for its citizens.

These efforts will also be consistent with best practices in respect to Smart Growth, as well theState’s Quality of Place initiative. This initiative seeks to preserve and promote that which is seen asMaine’s most vital assets; arts & cultural and heritage, environmental conservation and discouragingsprawl, and focusing development efforts in existing locations and downtown areas. It is theintention of the State to use the economic development districts as the delivery mechanism for theobjective outlined in the Quality of Place report.

The economic development district for South Portland, Greater Portland Council of Governments

(GPCOG) is required to develop and implement a Comprehensive Economic Development Strategy(CEDS) for the region, updated annually. This serves as a blueprint for economic and communitydevelopment initiatives, as well as for education, infrastructure/transportation, and the environment.Many of the objectives in GPCOG’s CEDS would be greatly aided by the Brownfields program.

ii.  Local Hiring & Procurement Plans and Partnering with Local Workforce EntitiesThere are no EPA Brownfields job training programs in our region or the state. However, when jobopportunities are created for Brownfields assessments, we will work with our local organizations inworkforce development to post job opportunities. These partners which we will utilize are GoodwillWorkforce Solutions, Coastal Counties Workforce Investment Board and the Maine Department ofLabor’s local Southern Career Center location. We will have our QEP contact these partners and participate in local job fairs as appropriate.

5.  Programmatic Capability and Past Performance

a.  Programmatic Capability The City of South Portland will manage this grant through the Executive Office. Jon Jennings, theAssistant City Manager and Economic Development Director, has prior experience identifying andassisting in the redevelopment of contaminated waterfront sites, having been involved in theredevelopment of Thompson’s Point, a $100 million redevelopment of a Brownfield site on Portland’swaterfront. Over the last year he has worked with various property owners to identify contaminated sitesin need of assessment. Mr. Jennings will be assisted by Emily Freedman, the City’s CommunityDevelopment Coordinator, whom has extensive experience in grant management, redevelopment of blighted properties, as well as working on projects that impact low to moderate income populations.

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ATTACHMENT 1 

Threshold Documentation (Threshold Criteria for Assessment Grants)

EPA Brownfields Community-Wide Assessment Grant ProposalCity of South Portland, Maine

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  Page 1

Attachment 1 - Threshold Documentation (Threshold Criteria for Assessment Grants)

1.  APPLICANT ELIGIBILITY

The City of South Portland is a General Purpose Unit of Local Government eligible to apply for

Brownfields Assessment funding from the U.S. Environmental Protection Agency (EPA)

Brownfields Grant Program.

2.  LETTER FROM STATE ENVIRONMENTAL AUTHORITY

A letter from Nicholas Hodgkins, the Director of the Maine Department of Environmental

Protection (Maine DEP) Brownfields Program, is included as Attachment 2.

3.  SITE ELIGIBILITY AND PROPERTY OWNERSHIP ELIGIBILITY

This criterion is Not Applicable to this grant application. This application is for community-

wide assessment funding; therefore, information regarding specific site eligibility will not beincluded in this application. The specific sites included in the Assessment Program will be

finalized through the inventory and site selection process.

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ATTACHMENT 2 

Letter from State or Tribal Environmental Authority

EPA Brownfields Community-Wide Assessment Grant ProposalCity of South Portland, Maine

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ATTACHMENT 3 – NOT APPLICABLE

Documentation of Applicant Eligibility if other than City, County, State of Tribe 

EPA Brownfields Community-Wide Assessment Grant ProposalCity of South Portland, Maine

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ATTACHMENT 4 

Letters of Support from all Community-Based Organizations Identified in the CommunityEngagement and Partnerships Ranking Criteria

EPA Brownfields Community-Wide Assessment Grant ProposalCity of South Portland, Maine

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 P.O. Box 2312

South Portland, ME 04116

[email protected]

www.southportlandlandtrust.org

SOUTH PORTLAND LAND TRUST 

January 10, 2014

Mr. Jon Jennings,Assistant City Manager

City of South Portland

25 Cottage RoadSouth Portland, ME 04106

Dear Mr. Jennings:

The South Portland Land Trust (SPLT) is an urban land trust focused on open space

 preservation, trail expansion and community involvement projects that support a livable SouthPortland. For twenty five years, the SPLT has helped create a fifteen mile trail system, including

the City’s keystone trail project, the Greenbelt Walkway, which runs for six miles along thelength of the City.

As an urban land trust, it is natural that many of our park and trail opportunities are located near

or along former industrial sites and a Brownfield’s assessment grant may open up new project

opportunities and provide much needed assistance. The SPLT is particularly interested inreclaiming some of these sites as many are along our high potential waterfront and new projects

 providing public access to these areas would be of great benefit to the community. This potential

value is exemplified in case of Bug Light Park, which was once a shipyard, but is now one of themost popular parks in the region and the northern terminus of the Greenbelt Walkway and the

Eastern Trail.

The SPLT supports South Portland’s Brownfield's assessment grant application and, if funded,we look forward to providing assistance in the evaluation and design phases for the Brownfield’s

assessment in the future, and serving on the City’s Brownfield Advisory Committee.

Sincerely,

Carter Scott

SPLT President

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ATTACHMENT 5 

Documentation Indicating Leveraged Funds Committed to the Project

EPA Brownfields Community-Wide Assessment Grant Proposal

City of South Portland, Maine

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25 Cottage Road • P.O. Box 9422South Portland, Maine 04116-9422

Telephone (207) 767- 7612 • Fax (207) 767-7620Monday through Friday 8:00 A.M. - 4:30 P.M. • Thursday 8:00 A.M. - 6:30 P.M.

www.southportland.org  

 FINANCE DEPARTMENT

GREGORY N. L’HEUREUX Finance Director(207) 767-7613

January 21, 2014

Mr. Jon JenningsAssistant City ManagerCity of South Portland25 Cottage RoadSouth Portland, ME 04106

Dear Jon,

I am responding to your request for information pertaining to Tax Increment Financing(TIF) districts in the City of South Portland for possible use for redevelopment if the city issuccessful with a Brownfield’s grant.

After a quick review of the City’s current TIF districts, there are five TIF districts thathave received City Council and State approval allowing expenditure relating to environmentalstudies that support economic development. These funds have annual revenues in excess of $1million dollars and presently have available resources which could be used to support Brownfield projects. Please remember there are competing projects within the City, but the TIF's arespecifically approved to assist with economic and environmental studies of waterfront propertiesas well as redevelopment of blighted areas.

Please let me know if you need any additional information.

Sincerely,

Gregory L'HeureuxFinance Director

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ATTACHMENT 6 – NOT APPLICABLE

Justification for Requested Waiver of the $200,000 Limit for a Site-Specific Assessment, ifapplicable

EPA Brownfields Community-Wide Assessment Grant ProposalCity of South Portland, Maine

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ATTACHMENT 7 – NOT APPLICABLE 

Property-Specific Determination Request, if applicable

EPA Brownfields Community-Wide Assessment Grant ProposalCity of South Portland, Maine

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ATTACHMENT 8 – NOT APPLICABLE 

Letters of Commitment from Assessment Coalition Members, if applicable

EPA Brownfields Community-Wide Assessment Grant ProposalCity of South Portland, Maine

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ATTACHMENT 9 – NOT APPLICABLE 

Petroleum Eligibility Determination Information, if applicable

EPA Brownfields Community-Wide Assessment Grant ProposalCity of South Portland, Maine

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ATTACHMENT 10 

“Other Factors” Checklist

EPA Brownfields Community-Wide Assessment Grant ProposalCity of South Portland, Maine

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Appendix 3

Other Factors Checklist

 Name of Applicant: City of South Portland, Maine 

Please identify (with an x) which, if any of the below items apply to your community or your project as described

in your proposal. To be considered for an Other Factor, you must include the page number where each applicablefactor is discussed in your proposal. EPA will verify these disclosures prior to selection and may consider thisinformation during the evaluation process. If this information is not clearly discussed in your narrative proposal

or in any other attachments, it will not be considered during the selection process.

Other Factor Page #

Community population is 10,000 or less.

Federally recognized Indian tribe.

United States territory.

Applicant will assist a Tribe or territory.

Targeted brownfield sites are impacted by mine-scarred land.Targeted brownfield sites are contaminated with controlled substances

X Recent natural disaster(s) (2006 or later) occurred within community, causing significantcommunity economic and environmental distress.

4

X Project is primarily focusing on Phase II assessments. 8 & 9

X Applicant demonstrates firm leveraging commitments for facilitating brownfield projectcompletion by identifying amounts and contributors of funding in the proposal and haveincluded documentation.

10

Community experienced manufacturing plant closure(s) (2008 or later) tied to the targeted brownfield sites or project area, including communities experiencing auto plant closures due

to bankruptcy or economic disruptions.

Recent (2008 or later) significant economic disruption (unrelated to a natural disaster or

manufacturing/auto plant closure) has occurred within community, resulting in a significant percentage loss of community jobs and tax base.

Applicant is a recipient or a core partner of a HUD-DOT-EPA Partnership for SustainableCommunities (PSC) grant that is directly tied to the project area, and can demonstrate that

funding from a PSC grant has or will benefit the project area. To be considered, applicantmust attach documentation which demonstrates this connection to a HUD-DOT-EPA PSCgrant.

Applicant is a recipient of an EPA Brownfields Area-Wide Planning grant

Community is implementing green remediation plans.

Climate Change.