Letters to the editor

City on right track I would like to add some comments to the debate regarding the proposed City Park along the Blanchard River. I have over 40 years of experience practicing environmental law, often working closely with the best environmental engineers and consultants. I was a member of the city of Toledo's first brownfield team. With an experienced remedial project manager, I have reviewed some of the data and recommendations for this site. First, a residential remedial standard is not the appropriate standard for a park. As recommended by the city's consultant, the appropriate standard is "Commercial Land Use with High Frequency Child Exposure." USEPA and OEPA have adopted these risk-based remedial standards with varied future uses in mind. The City's consultant has been designated as a "Certified Professional" who is authorized by OEPA to recommend appropriate remedies and to certify completion of them under the Ohio Voluntary Action Plan, for which I helped draft the regulations. I would recommend what is being proposed, were I the city's attorney, as I have in the past for zoos, museums, numerous purchasers, and banks. Second, in areas that exceed the standard, the remediation needs only to go down 2-4 feet to achieve the standard. This is common practice by USEPA and OEPA, for example, when there is the possibility of exposure to lead. Typically, the remediation is documented and enforced with a "deed restriction," i.e., a land use restriction, to ensure that any future proposed activity won't create an exposure exceeding the standard. In summary, this kind of problem and the approaches to it are commonplace in areas much worse than this. Thus, in my opinion, the city's approach and its consultant's recommendations are appropriate. Jeffrey Fort Findlay