PAXTON — The Paxton-Buckley-Loda school district is refuting allegations that it reduced the scope of its planned excavation work on the PBL Eastlawn School property to avoid needing to obtain a state permit — and, subsequently, evaluate ways to eliminate or minimize the adverse effect on historic resources that tearing down the 94-year-old former school building could have.
Mike Ewald, an architect and project designer for the district’s demolition consultant — Collinsville-based Environmental Consultants LLC — wrote a letter on Oct. 18 to the Illinois Environmental Protection Agency in response to the allegations made by Landmarks Illinois, a nonprofit that advocates for the preservation of historic structures.
In the letter, obtained by the Ford County Record through a Freedom of Information Act request, Ewald referenced a story published by the newspaper a day earlier. In the story, Frank Butterfield, director of Landmarks Illinois’ Springfield office, said he was “very surprised to see the project area altered to be one one-hundredth of an acre below the required threshold for a permit.”
Butterfield was referring to a boundary survey commissioned in July by Environmental Consultants LLC and school district, which showed the land to be disturbed by excavation totals 0.99 acres, just under the 1-acre threshold at which a stormwater permit from the IEPA is required.
If no IEPA permit is required, the district will not need to consult the State Historic Preservation Office (SHPO) to evaluate ways to eliminate or minimize the project’s adverse effect on historic resources — a process that could stall demolition or even lead to an alternative outcome.
According to Ewald, Butterfield’s assertion that the excavation work’s scope had been reduced was based on a “misguided comparison” of the original bid specifications produced in February by Environmental Consultants LLC and the boundary survey that followed.
“The two are being incorrectly identified as indicating a reduced scope of work, when, in fact, the survey was undertaken to validate existing information and assist in managing the scope of work,” Ewald wrote in his letter to the IEPA.
Ewald also pointed out that the Record’s story incorrectly stated that the original bid specifications had indicated “a manhole and septic system” on the property’s southwest side were to be removed, yet the survey completed in July indicates that no land is to be disturbed in that area. Ewald said the survey clearly shows “the long-abandoned septic tank and manhole” in that area will indeed be removed.
The Record took responsibility for the error Thursday, apologizing in an email to both Ewald and PBL Superintendent Cliff McClure. In the email, the Record said it had instead meant to reference “an existing manhole with foundation drain” and “storm piping” that were to be removed from an area on the southwest side of the property, as indicated in the original bid specifications.
Neither McClure nor Ewald immediately responded Thursday to the Record’s request to clarify why that work appears to have been included in the original bid specifications but now appears to be within the “do not disturb” zone in the more recent survey.
Ewald’s letter to the IEPA, meanwhile, stressed that at no point was it anticipated to excavate or disturb all of the 1.18-acre property — but only the 0.99 acres that comprise “the footprint of the building,” “associated site concrete” and “the abandoned septic system tank (and manholes).”
“It was EC’s (Environmental Consultants’) belief from the onset of the project that a stormwater permit was not required,” Ewald wrote. “After (a Landmarks Illinois) letter accused PBL of not seeking required permits, EC sought the professional advice of an Illinois licensed civil engineer to confirm. The consulting civil engineer communicated with (IEPA officials) via email to confirm that if the disturbed area was less than one acre, there was no requirement to file a notice of intent or to apply for a stormwater permit. In (the IEPA’s) email correspondence, it was further indicated that in cases where no permit is required, the owner or contractor were simply responsible for adhering to disturbing less than one acre in area.
“In a proactive measure, EC recommended and PBL agreed that performing a boundary survey and having the ‘work area’ delineated by an Illinois civil engineer/registered land surveyor would be a prudent measure to validate that accurate data was being used, to insure compliance with IEPA rules and to refute any later accusations that more than one acre in area was disturbed during the project. Furthermore, EC emailed a courtesy letter to (officials) at IEPA (on July 31) outlining the project and welcoming your review. ...
“PBL and EC maintain that this project is being performed in accordance with the applicable rules and regulations. Going forward, we intend to continue to comply with the applicable rules and regulations.”
Butterfield, meanwhile, is standing by his assertion that the scope of excavation appears to have been reduced from the original plans.
“From our understanding of the February demolition plans, there were site elements indicated for removal that are now in an area marked ‘do not disturb,’ according to the latest site survey,” Butterfield said in an email to the Record.
Added Butterfield: “It would be helpful for the school district to discuss the questions surrounding this process proactively and publicly, instead of information only being released following Freedom of Information Act requests.”
IEPA spokesman Kim Biggs said last week that the agency was “working to determine if a stormwater permit will be necessary for the project.”
On Oct. 21, the demolition/asbestos abatement contractors for the project submitted a revised notification form to the IEPA, indicating demolition of the 70,000-square-foot building at 341 E. Center St. in Paxton would begin Nov. 4 following the completion of asbestos abatement — instead of Nov. 18 as previously planned. The demolition’s completion date of Jan. 24 remained unchanged.
In March, the school board accepted a joint bid of $1.15 million from Lee Farms Excavating and General Waste Services to complete the demolition and asbestos abatement work, respectively.
The SHPO determined in May that the Eastlawn building — which was designed by Joseph W. Royer, a prominent early 20th century architect who has a historical district in Urbana devoted to him — is eligible for listing in the National Register of Historic Places.
Such eligibility means that “it is established that Eastlawn is a historic resource,” Butterfield noted in a letter to the school district this spring, and “demolition, as the indicated course of action by the school district, is clearly an adverse effect.”