Approved by the Board of Directors November 12, 2016
Preservation of clean water, air and soil are among the most basic and important conservation objectives. Thus, for a wide variety of environmental and legal reasons, it will be in the best interests of the Geneva Lake Conservancy (“GLC”) to avoid any easement or other ownership interest in, or other involvement with, any property that may require environmental remediation or otherwise present risks to human health or the environment. The GLC therefore has adopted this policy with respect to its land acquisition and stewardship activities, with the objective of evaluating potential environmental issues on a property before deciding whether to obtain and easement or other ownership interest in that property, and to integrate an awareness of potential environmental problems into the GLC’s stewardship efforts.
ENVIRONMENTAL SCREENING ASSESSMENT REQUIREMENT
An environmental screening assessment shall be conducted for every tract of land in which the GLC is proposing to acquire any interest. . Each step of the assessment, including the results, shall be documented in the project files prior to a final GLC Board vote on acquisition.
The results of the screening assessment shall be considered in determining whether to proceed with the project.
This policy applies to all acquisitions of land, including gifts, purchase, pre-acquisitions, land value transfers, as well as acquisitions of fee title, conservation easements, and or any other interests of land from the date of the GLC board of director’s approval of this policy.
SCREENING ASSESSMENT PROCEDURES
Every environmental screening assessment will include four components that will be documented in the land project file:
- Contact the Wisconsin Department of Natural Resources Contaminated Land Environmental Action Network (CLEAN) or other appropriate source to determine if the property is on or near any federal, state, county, city or town list of contaminated sites.
- Conduct a visual inspection of the property and surrounding property. This inspection should be done by a GLC staff member. If any concerns about environmental hazards are noted, the staff person should report them to the Land Protection Committee who will make a recommendation to the board on whether a qualified environmental contractor should be hired to survey the property.
- Review the history of the site and surrounding property. At a minimum, a GLC representative should talk to someone knowledgeable about current and past uses of this tract of land and surrounding property. This component also should include a review of government records, maps, aerial photographs or other materials obtained in response to Freedom of Information Act Requests that the GLC will issue to all relevant and appropriate agencies. A list of sources, their contact information and a summary of the discussion will be included in the project file.
- Complete the attached Evaluation Form.
POTENTIAL FOLLOW-UP INVESTIGATION
If the preliminary screening investigation reveals a potential environmental problem, the Board may request a much more detailed investigation of the land. The GLC may hire a consultant to do a more detailed investigation, including water or soil sampling and testing. Any decision to do additional work will be made on a case-by-case basis in consultation with the GLC’s environmental attorney and Land Protection Committee.
Each step of an environmental screening assessment, including the results, must be documented in the project files.
Essentially, the written documentation should note “who did what, when and where.” It should address what was seen or learned about the site (facts) and what was concluded (opinion).
The Environmental Screening Checklist (attached) must be completed and included in each project file. It should be signed by the GLC staff person responsible for the project.
GENEVA LAKE CONSERVANCY
CHECKLIST FOR PRELIMINARY ENVIRONMENTAL SCREENING
Name of Property Owner: ___________________________________
Type of Property:
- _____Potential Permanent Ownership
- _____Land Value Transfer
- _____Pre-acquisition for government agency
- _____Conservation Easement
Sources of Information:
- _____Inspection of documents (attach copies)
- _____Interview with landowner (attach notes)
- _____Interview with abuttors (specify whom, attach notes)
- _____Interview with government officials (specify whom, attach notes)
- _____Survey and/or site plan showing any current or former locations of:
- _____Above ground or underground storage tanks
- _____Electrical transformers
- _____Chemical storage locations
- _____On-site hazardous waste and nonhazardous waste storage or disposal sites.
- _____Known or suspected locations of asbestos
- _____Motor vehicle garage or service site
- _____Drainage systems
- _____Groundwater production or monitoring wells
- _____Septic systems and leach fields
- _____Water bodies, including streams, wetlands, lakeshore
- _____Land features
- _____Aerial photographs
- _____Copies of reports, permits, etc.
- _____Conditional or special use permits
- _____Easement agreements
- _____Land use restrictions
- _____Title reports
- _____Documents from federal, state or local agencies regarding property use.
- _____Environmental impact reports
- _____Environmental audits or assessments
- _____Technical reports or studies of the geology and hydrology of the area.
- _____Chemicals (a list of chemicals, fuels or pesticides known to have been used or stored on the property, including the location and estimated amount of each substance used or stored.)
- _____Waste (a list of types, amounts and locations of any wastes known to have been generated, stored, treated, recycled or disposed of on-site).
- _____Correspondence copy of letter and any response from DNR or EPA
Site Information and History:
- What types of crops were grown?
- Was the property irrigated?
- Were drain tiles used?
- What types of pesticides, herbicides and fertilizers were used?
- Were any chemicals used in processing on the site? What were they?
- _____What was manufactured and what chemicals were used?
- _____Do any chemicals, raw materials, finished products, fuel or machinery remain on property?
- _____Were any industrial waste, sewage, or waste water disposed or discharged to land or water that may have left deposits of hazardous substances on the land or in groundwater? Describe
- _____Was asbestos use on the siding or roof of the house?
- _____Is there a well and has it recently been tested? What were the results?
- _____Mining or non-metallic mining
- What was mined?
- What methods or processes were used?
- How and where were tailings and waste disposed of?
- What chemicals were used in mining and processing?
- _____Surrounding properties
- What are the current and past uses of the surrounding properties?
- Could the activities on these properties pose potential environmental risks?
- ______Other potential hazardous waste
Physical Inspection of property:
Performed by: ________________________________________________
Check applicable property features
- _____Stained soil or concrete
- _____Vegetation damage
- _____Foul or unusual odors
- _____Oily sheens or discoloration of surface water
- _____Storage tank – above or below ground?
- _____Surface pond or impoundment
- _____Waste dump, junk pile, storage pit
- _____Disposal well or bed
- _____Storage drums or other containers waste water outlet or pipe
- _____Emission stack, chimney or vent
- _____Railroad tracks
- _____Truck parking
- _____Soil disturbance
- _____Signs of waste dumping
- _____Stream or other flowing surface water
Prepared by: ________________________________________________
Reviewed by Legal Counsel: ________________________________________________
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