26-0280 Attachment E- Environmental Site Assessment.pdf

Environmental Testing & Consulting, Inc.

PHASE I ENVIRONMENTAL SITE ASSESSMENT

Cooley High School

15055 Hubbell Street

Detroit, Michigan 48227

Ms. Alycsa Valentine, Administrations

Detroit Public Schools

5057 Woodward Avenue

Detroit, Michigan 48202

38900 West Huron River Drive

Romulus, Michigan 48174

Phone: (734) 955-6600

Fax: (734) 955-6604

ETC Project #: 285647

Date: January 26, 2026

Prepared By:

Prepared For:

TABLE OF CONTENTS

SECTION PAGE

1.0 EXECUTIVE SUMMARY

1.1 Current Use of the Subject Property

1.2 Findings and Opinions

1.3 Conclusions

2.0 INTRODUCTION

2.1 Location and Legal Description

2.2 Purpose of Assessment

2.3 Detailed Scope of Services

2.4 Significant Assumptions

2.5 Limitations and Exceptions

2.6 Special Terms and Conditions

2.7 Deviations

2.8 Identification of User

2.9 User Reliance

3.0 USER PROVIDED INFORMATION

3.1 Title Records/Current Ownership

3.2 Environmental Liens or Activity and Use Limitations

3.3 Specialized Knowledge or Experience of the User

3.4 Commonly Known or Reasonably Ascertainable Information

3.5 Valuation Reduction for Environmental Issues

3.6 Owner, Key Site Manager and Occupant Information

3.7 Future Intended Use of Subject Property

3.8 Reason for Performing the Phase I ESA

4.0 RECORDS REVIEW

4.1 Standard Federal and State Standard Environmental Record Sources

4.2 Michigan Department of Environment, Great Lakes, and Energy (EGLE)/Michigan Department of

Licensing and Regulatory Affairs (LARA)

4.3 County Records

4.4 Municipal Records

4.5 Historical Use/Site Information

5.0 SITE RECONNAISSANCE

5.1 Methodology and Limiting Conditions

5.2 General Site Setting

5.3 Current Use of the Subject Property

5.4 Physical Setting Sources

5.5 Exterior Observations

5.6 Public Utilities

5.7 General Description of Structures and Interior Observations

5.8 Additional Observations

6.0 INTERVIEWS

6.1 Interview with the Property Owner and/or Representative

6.2 Interview with the Key Site Manager

6.3 Interviews with Occupants

6.4 Interviews with Previous Owners/Operators

6.5 Interview with the User

6.6 Interviews with State and/or Local Government Officials

7.0 EVALUATION

7.1 Findings

7.2 Opinion

7.3 Conclusions

8.0 NON-SCOPE SERVICES

9.0 REFERENCES

10.0 ENVIRONMENTAL PROFESSIONALS STATEMENT

11.0 SIGNATURES OF ENVIRONMENTAL PROFESSIONALS

12.0 QUALIFICATIONS AND EXPERIENCE

13.0 ACRONYMS AND TERMS

APPENDICES

A. Topographic Map and Site Location Map

B. Site Reconnaissance Photographs

C. Environmental Lien Search Report

D. Owner and User Questionnaires

E. State and Federal Regulatory Database Reports

F. Certified Sanborn® Map Report

G. Topographic Maps

H. Aerial Photographs

I. City Directory Report

J. Governmental Records

K. Resume

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1.0 EXECUTIVE SUMMARY

Environmental Testing and Consulting, Inc. (ETC) was retained by Ms. Alycsa Valentine, a representative of Detroit Public Schools (client) to perform a Phase I Environmental Site

Assessment (ESA) of the Cooley High School property, located at 15055 Hubbell Street, in Detroit, Michigan (Wayne County), Parcel ID Number: 22040004 (hereafter referred to as the “subject property”). The subject property is 651 feet above sea level with coordinates Latitude (north) 42° 24’ 1.62” or 42.4004510 and Longitude (west) – (minus)

83° 11’ 28.42” or -83.19123; USGS Quadrangle, Royal Oak, Topographic Map, 2019.

This Phase I ESA was conducted in general accordance with the United States

Environmental Protection Agency (USEPA) Standards and Practices for All Appropriate

Inquiries (AAI), 40 CFR Part 312 and guidelines established by the American Society for

Testing and Materials (ASTM) in the Standard Practice for Environmental Site

Assessments: Phase I ESA Process E1527-21.

The scope of this Phase I ESA included a review of reasonably obtainable historical information from Sanborn maps, aerial photographs, topographic maps, regulatory databases, Wayne County and City of Flint records on the development and uses of the subject property and adjoining properties. A visual survey of the subject property and adjoining properties including interviews with knowledgeable site contacts was conducted. No subsurface investigation of the subject property was performed as a part of this Phase I ESA.

1.1 Current Use of the Subject Property

The subject property is located at 15055 Hubbell Street, Detroit, Michigan 48227, in an area containing single-family residential properties. The subject property consists of a

321,024 square feet school building on 18.12 acres. The subject property has not been in use, since, June 2010, and is unoccupied.

1.2 Findings and Opinions

ETC has performed this Phase I ESA in conformance with the scope and limitations of

ASTM E1527-21 for Ms. Alycsa Valentine, a representative of Detroit Public Schools.

The subject property is located at 15055 Hubbell Street, Detroit, Michigan 48227. This assessment has revealed no evidence of Recognized Environmental Conditions in connection with the subject property except for the following:

• Gulf Station, 14545 Fenkell Ave (historic auto/gasoline station) - Plotted 158 feet north northeast (NNE) at a relative higher elevation to the subject property. This

Environmental Testing & Consulting, Inc. Page | 2 property was operating as a gasoline station business from 1935 to 1956. It appears that this site may not have adversely impacted the subject property based upon the regional clay geology, and the USTs on this site have been removed.

This site does not appear to be an environmental concern for the subject property.

• Ebel, 15045 Fenkell Ave (historic auto/gasoline station) - Plotted 97 feet north northwest (NNW) at a relative higher elevation to the subject property. This property was operating as a gasoline station business from 1935 to 1956. It appears that this site may not have adversely impacted the subject property based upon the regional clay geology, and the building on this site has been removed.

This site does not appear to be an environmental concern for the subject property.

• Lehnen Standard Service Station, 14600 Fenkell Ave (historic auto/gasoline station) - Plotted 225 feet north (N) at a relative higher elevation to the subject property. This property was operating as a gasoline station business in 1956. It appears that this site may not have adversely impacted the subject property based upon the regional clay geology, and the USTs on this site have been removed.

This site does not appear to be an environmental concern for the subject property.

• Associates Auto Service, 14645 Fenkell Ave (historic auto/gasoline station) -

Plotted 242 feet north (N) at a relative higher elevation to the subject property. This property was operating as a gasoline station business from 1956 to 2014, under different business names. It appears that this site may not have adversely impacted the subject property based upon the regional clay geology, and the USTs on this site have been removed. This site does not appear to be an environmental concern for the subject property.

• Quick Clean Center, 14521 Fenkell Ave (historic dry cleaner) - Plotted 216 feet north northeast (NNE) at a relative higher elevation to the subject property. This property was operating as a dry cleaner’s business in 1970. It appears that this site may not have adversely impacted the subject property based upon the regional clay geology. This site does not appear to be an environmental concern for the subject property.

• Shelby’s Extraordinaire, LLC Cleaners, 15050 Fenkell Ave, (historic dry cleaners) – Plotted 260 feet north northwest (NNW) at a relative higher elevation to the subject property. This property was operating as a dry cleaner’s business from 1987 to 2024 under different business names, and has several violations from

Michigan EGLE – Air Quality Division (AQD) from 2018 to 2024. It appears that this site may not have adversely impacted the subject property based upon the regional clay geology, and the building on this site is over 100 feet from the subject

Environmental Testing & Consulting, Inc. Page | 3 property. This site does not appear to be an environmental concern for the subject property.

No evidence of Controlled Recognized Environmental Conditions (RECs) or Historical

Recognized Environmental Conditions (HRECs) in connection with the subject property was discovered during the site reconnaissance, in available sources of historical and governmental information, or interviews.

The property is in a low Radon Zone 3 for the site and surrounding areas within a mile radius indication zone 3 and have 0 to 2 pCi/L (picocuries per liter of air).

1.3 Conclusions

ASTM Standard Practice E1527-21 of the former Cooley High School property, located at 15055 Hubbell Street, Detroit, Michigan 48227, in Wayne County. Any exceptions to, or deletions from this practice are described in Section 2.5 of this report. Based upon governmental and historical record reviews and the site reconnaissance, it appears that the subject property may have been adversely impacted by the adjoining properties.

ETC recommends drilling and soil sampling along the northeast and the northwest perimeters to determine potential impact from adjoining properties that operated as drycleaners and gas stations, historically.

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2.0 INTRODUCTION

Environmental Testing and Consulting, Inc. (ETC) was retained by Ms. Alycsa Valentine, a representative of Detroit Public Schools (client) to perform a Phase I Environmental Site

Assessment (ESA) of the Cooley High School property, located at 15055 Hubbell Street, in Detroit, Michigan (Wayne County), Parcel ID Number: 22040004 (hereafter referred to as the “subject property”). The subject property is 651 feet above sea level with coordinates Latitude (north) 42° 24’ 1.62” or 42.4004510 and Longitude (west) – (minus)

83° 11’ 28.42” or -83.19123; USGS Quadrangle, Royal Oak, Topographic Map, 2019.

This Phase I ESA was conducted in general accordance with the United States

Environmental Protection Agency (USEPA) Standards and Practices for All Appropriate

Inquiries (AAI), 40 CFR Part 312 and guidelines established by the American Society for

Testing and Materials (ASTM) in the Standard Practice for Environmental Site

Assessments: Phase I ESA Process E1527-21.

2.1 Location and Legal Description

The subject property (18.12 acres) is located at 15055 Hubbell Street, which is situated between commercial property, restaurants and churches with frontage on Fenkell Avenue

(north), a church and residential property across Hubbell Avenue (east), residential property across Chalfonte Street (south) and access to the school property from Ellsworth with residential property across Coyle Street (west) in Detroit, Michigan. A site location map is located in Appendix A of this report.

Legal Description: W HUBBELL 278 THRU 262 AND N 1/2 VAC ELLSWORTH ADJ

282 THRU 301 AND S 1/2 VAC, ELLSWORTH ADJ AND VAC LAUDER ADJ AVON

PARK SUB

2.2 Purpose of Assessment

This Phase I ESA report summarizes ETC’s evaluations and conclusions. The purpose of the Phase I ESA is to define good commercial and customary practice in the U.S.A. for conducting an ESA of a parcel of commercial real estate with respect to the range of contaminants within the scope of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) (42 U.S.C. §9601) and petroleum products.

As such, this practice is intended to permit a User to satisfy one of the requirements to qualify for the innocent landowner, contiguous property owner, or bona fide prospective purchaser limitations on CERCLA liability (hereinafter, the landowner liability protections, or LLPs): that is, the practice that constitutes all appropriate inquiries into the previous

Environmental Testing & Consulting, Inc. Page | 5 ownership and uses of the property consistent with good commercial and customary practice as defined at 42 U.S.C §9601(35) (B).

The goal of the ESA of a parcel of property is to identify “Recognized Environmental

Conditions” (RECs), as defined by ASTM Standard E1527-21: “the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: (1) due to release to the environment; (2) under conditions indicative of a release to the environment; or (3) under conditions that pose a material threat of a future release to the environment.” De minimis conditions are not Recognized Environmental Conditions. De minimis Conditions are conditions that generally do not present a threat to human health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies.

42 U.S.C. §9601(22) defines a release as any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment (including the abandonment or discharging of barrels, containers, and other closed receptacles containing any hazardous substances or pollutant of contaminant.

2.3 Detailed Scope of Services

ETC completed this Phase I ESA in general accordance with ASTM standards and ETC’s general terms and conditions. The assessor performed a review of available federal and state environmental databases, using distances specified in ASTM E1527-21, to identify sites that are a potential risk to impact the study property. Historical aerial photographs, municipal department files, and additional historical documentation, as needed, were evaluated to identify prior land usage and the potential for soil and/or water sources of contamination. A visual survey of the subject property was conducted to identify potential indicators of environmental concerns and to identify areas of potentially impacted soil and/or groundwater. This survey also included a visual assessment of the subject property and the adjacent public roads and adjoining properties, to the extent possible, for the presence of environmental concerns.

2.4 Significant Assumptions

Per the ASTM Standard Practice E1527-21, ETC assumes that the information provided by all sources and parties, including the User, is accurate and complete, except where obvious inconsistencies or inaccuracies were identified.

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2.5 Limitations and Exceptions

ETC has performed these professional services in accordance with customary principles and practices in environmental services and with ASTM E1527-21 for conducting Phase

I ESA. The conclusions of this report are based solely upon observations made and information obtained during this evaluation. ETC’s opinions should not be construed as relating to health and safety issues, directly. Should additional information become available, this information should be reviewed by ETC, and the conclusions herein modified, as appropriate. In addition, this report should not be construed as verification of compliance by the present owners or operators of the site with federal, state, or local laws and regulations.

Information provided by others was used in assessing the site conditions. The accuracy of the conclusions made from this information is inherently based on the accuracy of the information provided. This evaluation did not include subsurface investigations or laboratory analysis, unless otherwise noted. Similarly, no testing or analysis to determine the presence of asbestos, lead, mold, polychlorinated biphenyls (PCBs) or polyfluoroalkyl substances (PFAs) was performed, unless noted.

It must be recognized that the limited scope of services may have precluded recognition of contamination at the site. Negative findings in this report cannot be interpreted as a warranty, expressed, or implied, that no contamination exists at the study property, and

ETC cannot be held liable for damages if contamination of some type is discovered in the future. The findings and conclusions in this document present our professional opinions and are based upon information reasonably ascertainable during the course of this investigation. ETC does not provide legal advice. No other warranty, expressed or implied, is made.

2.6 Special Terms and Conditions

There are no special terms or conditions that apply to the preparation of this Phase I ESA.

2.7 Deviations

There are no deviations from the ASTM Standard Practices E1527-21.

2.8 Identification of User

As defined by ASTM terminology, the User of this report is Ms. Alycsa Valentine, a representative of Detroit Public Schools.

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2.9 User Reliance

This report should not be considered as a recommendation to purchase, sell, occupy, or develop the subject property, and the opinions contained herein are not legal opinions.

To evaluate the information contained in this report, the reader must understand the limitations associated with this assessment. Specifically, the services included in this project have been performed in accordance with the Scope of Services. Reliance on this report by a party other than Alycsa Valentine, or Detroit Public Schools and its agents, shall be at the party’s sole risk unless that party has written authorization from ETC to use this document. The purpose of this restriction is to attempt to protect the interest of the parties for whom the report may not be appropriately directed.

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3.0 USER PROVIDED INFORMATION

The ASTM Standard 1527-21 defines a “User” as “the party seeking to use Practice

E1527 to complete an environmental site assessment of the property. A User may include, without limitation, a potential purchaser of property, a potential tenant of property, an owner of property, a lender, or a property manager. The User has specific obligations for completing a successful application of this practice as outlined in Section 6 of the

ASTM Standard E1527-21.

3.1 Title Records/Current Ownership

The City identifies the current owner of the subject property (parcel identification number

22040004) as Detroit Public Schools, located at 5057 Woodward Avenue, Detroit, Michigan 48202, since 1928.

The EDR Environmental Lien Search Report with supporting documentation is included

Appendix C of this report.

3.2 Environmental Liens or Activity and Use Limitations

No environmental liens or Activity and Use Limitations (AULs) were noted for the subject property with parcel identification number of 22040004 in the EDR Environmental Lien

Search Report, Radius Map Report, or listed on Michigan Department of Great Lakes and

Energy Remediation and Redevelopment Division, or City files for the subject property.

Ms. Valentine completed the Owner Questionnaire dated January 16, 2026. The Owner

Questionnaire is located in Appendix D of this report. Ms. Valentine stated that they are not aware of any environmental cleanup liens or AULs, such as engineering controls, land use restrictions or institutional controls that are in place on the subject property and/or have been filed or recorded in a registry under federal, tribal, state, or local law.

3.3 Specialized Knowledge or Experience of the User

In order to qualify for one of the Landowner Liability Protections (LLPs), the User must provide certain information (if available) included on the User Questionnaire to the environmental professional. Failure to provide this information could result in a determination that “all appropriate inquiry” is not complete.

ETC provided DPS with a copy of the User Questionnaire, which was completed and returned to ETC on January 16, 2026. None of the questions were answered in the

Environmental Testing & Consulting, Inc. Page | 9 affirmative or in a manner that would suggest the potential for RECs by DPS. No other specialized knowledge or experience of the subject property was provided to ETC by the

User. A copy of the User Questionnaire is included in Appendix D.

3.4 Commonly Known or Reasonably Ascertainable Information

Ms. Valentine reported that they have no knowledge of specific chemicals or petroleum products that are present or once were present at the property. Also, they do not know whether spills, chemical releases, or environmental cleanups have occurred at the

3.5 Valuation Reduction for Environmental Issues

Ms. Valentine reported that the purchase price being paid for the subject property reflects the fair market value of the property.

3.6 Owner, Key Site Manager and Occupant Information

Ms. Valentine stated that based on the knowledge and experience related to the property;

there were no obvious indicators that point to the presence or likely presence of contamination at the subject property.

3.7 Future Intended Use of Subject Property

The future use is to transform the former historic school building (321,024 SF) into a sports facility for both the school district and for the community. The structure will need to be demolished, according to reports by leaders in the community. The plan is to build a locker room, a museum, and a meeting/conference venue for the community, by the end of 2026.

3.8 Reason for Performing the Phase I ESA

This Phase I ESA was performed to provide Ms. Valentine and the DPS with an independent evaluation of the potential environmental risks that may be associated with the subject property.

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4.0 RECORDS REVIEW

ETC reviewed the EDR Radius Map, dated December 9, 2025. This report presents the findings of a computerized environmental database search for the subject property and surrounding area based on standard ASTM minimum search distances. Please see the attached report in Appendix E for a detailed listing and descriptions. The following table lists the Standard Environmental Records for the Federal and State databases within the indicated approximate minimum search distances.

Type Regulatory Agency Database

Approximate

Minimum Search

Distance (AMSD)

Sites

Within

The AMSD

Federal

National Priority List (NPL) Sites - Identifies the nation's most hazardous sites that warrant further investigation. Sites are first identified as a CERCLIS Site and the degree of contamination determines whether the site will be included on the NPL. Also known as Superfund.

1 Mile 0

Federal Delisted National Priority List (DNPL) Sites - Sites deleted from the NPL where no further response is appropriate.

1 Mile 0

Federal

Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) Sites -

Compilation of properties that the EPA has identified as that the

EPA has identified as having actual or suspected releases of contamination. The sites are reported to the EPA through states, municipalities, and private companies/citizens. Each site undergoes a series of reviews that determine the severity of the contamination from the discovery and preliminary assessment to the site inspection and the hazard ranking system, which will determine whether the site will be included on the NPL.

0.5 Mile 0

Federal

CERCLIS No Further Remediation Action Planned (NFRAP)

Sites - CERCLIS Sites where no further remedial action is planned at the federal level.

0.5 Mile 0

Federal

Resource Conservation and Recovery Act (RCRA)

Corrective Action Report (CORRACTS) Sites - Includes hazardous waste handlers with RCRA corrective action activities.

1 Mile 1

Federal

RCRA non-CORRACTS Treatment, Storage or Disposal

(TSD) Sites - RCRA provides for the cradle to grave management of hazardous wastes by regulating the operations of those who operate treatment, storage or disposal facilities.

0.5 Mile 0

Federal

RCRA Large Quantity Generators (LQG) Sites - RCRA provides for the management of properties that generate more than 1,000 kilograms of hazardous waste or over one (1) kilogram of acutely hazardous waste per month.

Subject Property and Adjoining

Property

Federal

RCRA Small Quantity Generators (SQG) Sites - RCRA provides for the management of properties that generate more than 100 kilograms and less than 1,000 kilograms of hazardous waste.

Subject Property and Adjoining

Property

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Type Regulatory Agency Database

Approximate

Minimum Search

Distance (AMSD)

Sites

Within

The AMSD

Federal

RCRA Conditionally Exempt Small Quantity Generators

(CESQG) Sites - RCRA provides for the management of properties that generate less than 100 kilograms of hazardous waste or less than one (1) kilogram of acutely hazardous waste per month.

Subject Property and Adjoining

Property

Federal

Institutional Control / Engineering Control Registries - Sites where federal implemented institutional control and/or engineering control.

Subject Property 0

Federal

Environmental Response and Notification System (ERNS) -

Records of information about reported releases of hazardous substances and/or petroleum products. These sites are maintained by the EPA and the EGLE.

Subject Property 0

State &

Tribal

State Hazardous Waste Sites (SHWS) (equivalents to NPL and CERCLIS) - Known as Part 201 Sites in Michigan. SHWS are

Michigan's equivalent to CERCLIS. The sites are reported to the

State through municipalities, private companies/citizens. The

State has developed a numerical ranking model for determining the present and potential hazard that each site poses to public health, safety, welfare and/or the environment. Each site is scored using this model once identified and annually thereafter.

1 Mile 0

State &

Tribal

Solid Waste Facilities/Landfill Sites (SWF/LF) - Part 115 of

Act 451, as amended, regulates and maintains an inventory of solid waste disposal facilities or landfills.

0.5 Mile 0

State &

Tribal

Leaking Underground Storage Tank (LUST) Sites - Part 213 of Act 451, as amended, regulates and details the corrective action required due to releases from leaking USTs. Part 213 also prescribes the powers and duties of certain State agencies and officials, and provides penalties and remedies.

0.5 Mile 7

State &

Tribal

Registered Underground Storage Tank (UST) - Part 211 of

Act 451, as amended, regulates certain UST systems, requires the registration of certain UST systems, prescribes the powers and duties of certain state and local agencies and officials, imposes fees, and prescribes penalties and remedies.

Subject Property and Adjoining

Property

State &

Tribal

Registered Above Storage Tank (AST) Sites - Listing of registered ASTs

Subject Property and Adjoining

Property

State &

Tribal

Institutional Control / Engineering Control Registries:

Activity and Land Use Limitations (AUL) - Sites with institutional control and/or engineering control in place.

Subject Property and Adjoining

Property

State &

Tribal

Brownfield Sites - BEA or LUST sites which have been redeveloped by private entities using the BEA process.

0.5 Mile 2

State &

Tribal

Baseline Environmental Assessment (BEA) Sites - Sites which have been identified as a facility and have submitted a BEA to EGLE.

0.5 Mile 4

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Type Historical Database

SEARCH RADIUS

(miles)

NUMBER

OF SITES

IN REPORT

Historical Historical Manufactured Gas Plant (MGP) Sites - Former manufactured gas plants.

1 Mile 0

Historical

Historical Automotive Related Businesses - Former automotive stations (i.e., gas stations, repair shops) identified in historical street address directories.

0.125 Mile 9

Historical

Historical Cleaner Sites - Former cleaners (i.e., dry cleaners, laundries, Laundromats, etc.) identified in historical street address directories.

0.125 Mile 5

PFAs/

PFOs

Historical Landfills, Active Landfills, Biosolids, Part 139

Airport, and Aqueous Foam NRC sites, per- and polyfluoroalkyl substances (PFAs) are man-made chemicals, are resistant to heat, water, and oil, and persist in the environment.

0.5 Mile 0

The EDR Report identified twenty-nine (29) sites that are plotted on the standard list of sites and ninety-five (95) extended list sites on the radius maps. No sites were non-geocoded on the radius map. A non-geocoded site is unable to be plotted by on the radius maps due to the lack of proper address or other pertinent information required for the precise computer plotting, and as such could only be located within the city, county or zip code area of the property.

4.1 Standard Federal and State Standard Environmental Record Sources

ETC’s review of the referenced databases was to evaluate potential environmental risks associated with the subject property, adjoining sites, and other sites. To evaluate the potential environmental risks identified in the EDR Report, ETC considered the following criteria:

• Type of database on which the site was identified;

• Topographic position of the identified site relative to the subject property;

• Distance and bearing of the identified site from the subject property;

• Local soil conditions on the subject property;

• Known or inferred groundwater depth and flow direction on the subject property and adjoining property areas;

• The status of the respective regulatory agency-required investigation(s) of the identified site, if any;

• Surface and subsurface obstructions and diversions (e.g., buildings, roads, sewer systems, utility service lines, rivers, lakes, and ditches) located between the identified site and the subject property.

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Only those sites that are judged to present a potential environmental risk to the subject property and/or warrant additional clarification are further evaluated. Using the referenced criteria, and based upon a review of readily available information contained within the

EDR Regulatory Database Report, ETC did not identify adjoining (i.e. bordering) or nearby sites (e.g., properties within a quarter mile radius) listed in the regulatory database report that were judged to present a potential environmental risk to the subject property, with the exception of the following:

property was operating as a gasoline station business from 1935 to 1956. It appears that this site may not have adversely impacted the subject property based upon the regional clay geology, and the USTs on this site have been removed.

This site does not appear to be an environmental concern for the subject property.

• Ebel, 15045 Fenkell Ave (historic auto/gasoline station) - Plotted 97 feet north northwest (NNW) at a relative higher elevation to the subject property. This property was operating as a gasoline station business from 1935 to 1956. It appears that this site may not have adversely impacted the subject property based upon the regional clay geology, and the building on this site has been removed.

This site does not appear to be an environmental concern for the subject property.

• Lehnen Standard Service Station, 14600 Fenkell Ave (historic auto/gasoline station) - Plotted 225 feet north (N) at a relative higher elevation to the subject property. This property was operating as a gasoline station business in 1956. It appears that this site may not have adversely impacted the subject property based upon the regional clay geology, and the USTs on this site have been removed.

This site does not appear to be an environmental concern for the subject property.

• Associates Auto Service, 14645 Fenkell Ave (historic auto/gasoline station) -

Plotted 242 feet north (N) at a relative higher elevation to the subject property. This property was operating as a gasoline station business from 1956 to 2014, under different business names. It appears that this site may not have adversely impacted the subject property based upon the regional clay geology, and the USTs on this site have been removed. This site does not appear to be an environmental concern for the subject property.

• Quick Clean Center, 14521 Fenkell Ave (historic dry cleaner) - Plotted 216 feet north northeast (NNE) at a relative higher elevation to the subject property. This property was operating as a dry cleaner’s business in 1970. It appears that this site may not have adversely impacted the subject property based upon the regional

Environmental Testing & Consulting, Inc. Page | 14 clay geology. This site does not appear to be an environmental concern for the subject property.

• Shelby’s Extraordinaire, LLC Cleaners, 15050 Fenkell Ave, (historic dry cleaners) – Plotted 260 feet north northwest (NNW) at a relative higher elevation to the subject property. This property was operating as a dry cleaner’s business from 1987 to 2024 under different business names, and has several violations from

Michigan EGLE – Air Quality Division (AQD) from 2018 to 2024. It appears that this site may not have adversely impacted the subject property based upon the regional clay geology, and the building on this site is over 100 feet from the subject

None of the above-listed sites are adjacent to the subject property. The remaining identified sites are located more than one-eighth of a mile from the property. However, based on the distance of these properties from the subject property, the removal of the source, the delineation of contaminants in the direction of the subject property, the regional clay geology, and/or the lack of sufficient groundwater to act as a transportation mechanism, ETC has not identified these nearby properties as RECs.

4.2 Michigan Department of Environment, Great Lakes, and Energy (EGLE)/Michigan

Department of Licensing and Regulatory Affairs (LARA)

To determine whether the EGLE maintains records of environmental concerns for the subject property, ETC submitted Freedom of Information Act (FOIA) requests to the EGLE and to the Michigan Department of Licensing and Regulatory Affairs (LARA), to review environmental files that pertain to the subject property. The FOIA responses are located in Appendix J of this report.

The EGLE FOIA Coordinator, forwarded the request for information to the: Air Quality

Division; Drinking Water and Municipal Assistance Division; Oil, Gas, and Minerals

Division; Remediation and Redevelopment Division; Waste Management and

Radiological Protection Division, and the Water Resources Division. No significant records existed for the subject property; prior to 1990, the school was an Exempt

Generator of Hazardous Waste (CESQG) status to handle incidental cleaning of unused chemicals, such as paint, and maintenance materials.

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4.2.1 Regulatory File Review for Subject Property and Adjoining Properties

The EGLE Drinking Water and Municipal Assistance Division, Oil, Gas and Minerals

Division, Air Quality Division, Remediation and Redevelopment Division, Waste

Management and Radiological Protection Division and Water Resources Division reported that no records were found for the subject property.

The Michigan Department of Licensing and Regulatory Affairs (LARA) reported that no records were found for the subject property.

4.2.2 Vapor Migration Consideration

Vapor migration refers to the movement of hazardous substances or petroleum products in any form, including solid and liquid at the surface or subsurface, and vapor in the subsurface. This does not appear to be a recognized environmental condition (REC) for the subject property, since all potential surrounding properties have removed sources, and no indication of migration has occurred for the subject property.

The property is in a low Radon Zone 3 for the site and surrounding areas within a mile radius indication zone 3 and have 0 to 2 pCi/L (picocuries per liter of air).

4.3 County Records

Wayne County Department of Public Services, Land Resource Management Division, Freedom of Information Act Coordinator, stated that the Department of Public Services

Land Resource Management Division did not have any records for the subject property.

4.4 Municipal Records

4.4.1 City of Detroit Assessing Department

City of Detroit Assessing Department identifies the owner of the subject property with parcel identification number 22040004, as Detroit Public Schools, of 5057 Woodward

Avenue, Detroit, Michigan 48202, Wayne County. The subject property consists of a school structure that is 321,024 square feet, built on 18.12 acres, in 1928 original structure and 1970 with an addition.

4.4.2 City of Detroit Planning and Development Services

City of Detroit zoning for the subject property indicates that the subject property is listed as Zone – R1, Single-Family Residential property.

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4.4.3 City of Detroit Building, Safety Engineering, and Environmental Department

(BSEE)

ETC was unable to obtain the City of Detroit Building, Safety Engineering, and

Environmental Department for records pertaining to the subject property. The EDR database shows twenty-nine (29) building permits for adjacent residential properties and recorded none (0) for the subject property. The surrounding property’s permits do not indicate any impact to the subject property.

4.4.4 City of Detroit Fire Department/ Emergency Records

City of Detroit Fire Department was unable to receive a FOIA request concerning Fire

Marshal records of storage tanks, hazardous material spills, and environmental concerns at the subject property.

The EDR database reports thirty-four (34) fires for the subject property, and a total of 225 fires/emergency records for combined subject property and surrounding properties. The fires on the subject property were mostly small, and from 1988 to 2017, that were confined to the subject property; some fires began by trash (refuse) burning, and was extinguished with a portable fire extinguisher.

The Historic Detroit reported that on October 1, 2017, a fire occurred in the auditorium of the abandoned school building. Copies of these reports are located in Appendix J of this report.

4.4.5 Adjoining Properties Records Review

No records were found for surrounding properties filed in Michigan EGLE’s Remediation

Information and Data Exchange (RIDE) database to indicate underground storage tanks or inventory of contamination.

EDR historical documents indicate former gasoline stations and dry cleaners. The nearest is a former auto repair shop (15045 Fenkell Ave) that is 97 feet from the northwest (NW) corner of the subject property, and a former dry cleaner that is 260 feet from the NW corner of the subject property across Fenkell Ave (15050 Fenkell Ave). ETC requested historical documents from MI EGLE – Air Quality Division for the dry cleaners; the violations appear to be paperwork and licensing. A filling station (gas station) operated at

14545 Fenkell Ave, that is adjacent to the east from 1935 to 1961, and has been listed as a pizza restaurant in 2017.

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4.5 Historical Use/Site Information

To assess past use of the subject property and adjacent areas, ETC researched records of historical fire insurance maps, topographic maps, aerial photographs, and city directories.

4.5.1 Previous Environmental Reports

Ms. Valentine stated that there are no previous environmental reports for the subject

4.5.2 Historical Sanborn Maps

Historical fire insurance maps (Sanborn Maps®) provided by EDR for the subject property was reviewed. A copy of this EDR report is located in Appendix F of this report.

Date Description of Subject Property and Surrounding Properties

The subject property, Thomas M. Cooley High School, is shown with the current structure (original structure and the 1971 addition on the north of the original structure).

The surrounding properties includes a diner, church, a bank, and retail services with frontage along Fenkell Avenue to the north, and single-family residences (SFR) to the east, west and south. One property to the NE across Hubbell, 14545 Hubbell Ave, is shown and may have been a former gas station, but only indicates a building and is listed as a pizza restaurant in 2017.

1996 Same as 2002.

1992 Same as 2002.

1990 Same as 2002.

1986 Same as 2002.

1983 Same as 2002, except more store structures are north across Fenkell Ave.

1978 Same as 1983.

The subject property is shown with the original structure, only, and instead of the later school add’n, Ellsworth Avenue extends east along the northern subject property boundary with SFR north across Ellsworth Ave. The building has a Heating Plant that is labeled as a Coal Burner with a Coal Room underground.

- (east) 14545 Fenkell Ave, shows a Used Auto Sales, and a Filling Station.

1956 Same as 1961.

1951 Same as 1961.

1950 Same as 1951.

1946 Same as 1951.

4.5.3 Historical Topographic Maps

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To assess past use of the subject property and adjacent areas, historical topographic maps provided by EDR were reviewed for the subject property and surrounding area. A copy of this EDR report is located in Appendix G of this report. The following table provides a summary of the findings for the subject property and adjoining area using the

U.S.G.S. Royal Oak Michigan Quadrangle.

Date Description of Subject Property and Surrounding Properties

The subject property is located within a well-developed single-family residential subdivision, called, Avon Park Subdivision. Contour lines indicate the subject property is on the edge of an incline with gradient to the southwest (SW) with elevation at 651 feet above sea level. No structures are depicted on this Topo map.

2017 Same as 2019.

2014 Same as 2019.

The subject property is depicted with the current high school structure; the original structure is shown in grey and the addition is shown as pink. The outdoor high school oval track is also depicted in this Topo map.

1981 Same as 1996.

1973 Same as 1996.

The subject property is depicted with the original structure, only, with the adjacent property to the north as residential lots, and a high school oval track is on the subject property.

1952 Same as 1968.

1941 Same as 1968.

1936 Same as 1936.

1934 The subject property is shown as vacant land.

1924 Same as 1934.

1918 Same as 1934.

1905 Same as 1934.

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4.5.4 Historical Aerial Photographs

Historical aerial photographs provided by EDR were reviewed to assess past use of the subject property area. A copy of this EDR report is located in Appendix H of this report.

The following table provides a summary of the findings for the subject property and adjoining area using the USDA, USDA/NAIP, DTE, USGS/DOQQ flight data.

Date Description of Subject Property and Adjoining Properties

The subject property is shown with the current school building and oval track with a grassy lawn.

Surrounding property:

- East is single family residences across Hubbell Street

- South is single family residences across Chalfonte Street

- West is single family residences across Coyle Street and Ellsworth Street dead ends into the subject property from Coyle Street.

- North is adjacent commercial restaurants and churches with frontage on

Fenkell Avenue.

In general, commercial properties have frontage along Fenkell Avenue with residential property beyond the frontage property.

2018 Same as 2022.

2014 Same as 2022.

2010 Same as 2022.

2005 Same as 2022.

1999 Same as 2022.

1997 Same as 2022.

1983 Same as 2022.

1981 Same as 2022.

1976 Same as 2022.

1972 Same as 2022.

The subject property is shown with the original structure, only, and the oval track.

In general, residential properties are surrounding the subject property, except to the north that shows commercial structures with frontage on Fenkell Avenue.

1961 Same as 1967.

Same as 1967, except residential structures and vacant lots are adjacent to the north with frontage along Fenkell Avenue.

1949 Same as 1952.

The subject property is shown with the original structure and residential properties surrounding the subject property, except adjacent properties to the north are vacant lots with no structure along Fenkell Avenue.

1937 Same as 1940.

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4.5.5 City Directory Records

Historical Bresser’s Cross-Index Directory Company, Polk's City Directory and EDR

Digital Archive provided the City Directory Image Report that was reviewed to assess past use of the subject property area from 1926 to 2022. Directories were researched in at least five (5) year intervals. An address that is not listed typically indicates that the property was vacant at the time, a previously existing address was different than the current address, the building was not represented in the directory because of a “lag time” between building the structure and compiling the list, or occupant information was not available for inclusion into the directory.

Date Description of Subject Property and Adjoining Properties

The subject property is not listed.

- (north) 14641 Fenkell Ave is listed as retail cash market and boutique.

- (east) 15050 Hubbell St is listed as a church.

In general, commercial properties have frontage along Fenkell Avenue with residential property beyond the frontage property.

2017 Same as 2022.

2014 Same as 2022.

The subject property is listed as Cooley High School, and surrounding properties are the same as 2022.

2005 Same as 2010.

2000 Same as 2010, except 14641 Fenkell Ave is not listed.

1995 Same as 2000.

1992 Same as 2000.

1987 Same as 2000.

Same as 2000, except at 15111 Fenkell Ave is listed as Wal, JS Cleaners (NE across Hubbell Street).

1977 Same as 1982.

1972 Same as 1982.

1967 Same as 1982, except 14641 Fenkell Ave is listed as a bank.

1962 Same as 1962, except 14641 Fenkell Ave is not listed.

1957 Same as 1962.

Same as 1962, except 15111 Fenkell Ave is listed as an electric contractor’s firm.

- (NE corner) 14545 Fenkell Ave is listed as Richard’s Service Station

Same as 1953, except 15111 Fenkell Ave is not listed.

- (east) 14545 Fenkell Ave is listed as Rantanen & Bicknell Oil Co Filling Station

1935 Same as 1940, except 14545 Fenkell is listed as Cooley Super Filling Station.

1931 Same as 1935, except 14545 Fenkell is not listed.

The subject property is not listed, and adjacent properties are not listed, with surrounding properties mainly individual residents.

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Review of the City Directories indicates the subject property was, historically, Cooley High

School, from 1928 to present. A copy of the EDR City Directory report is located in

Appendix I of this report.

4.5.6 Summary of Available Historical Subject Property Information

Sanborn Maps, aerial photographs, topographic maps, city directories, Wayne County and City of Detroit records, and interviews provided historical information on the development and uses of the subject property and adjoining properties.

Historical Records Summary for the Subject Property

Time Period

Description Owner / Occupant

1928 to present

Cooley High School Detroit Public Schools

Prior to

Vacant land unknown

Historical Summary - Adjoining Properties

North: The northern adjoining property has consisted of residential property along Fenkell

Avenue, until 1940, then commercial property with retail and churches, since 1940. A filling station operated across Hubbell Ave at 14545 Fenkell Ave from 1935 to 1953, and is listed as a pizza restaurant in 2017.

East: The eastern adjoining property has consisted of residential and church property across Hubbell Street, since 1934.

South: The southern adjoining property has consisted of residential property across

Chalfonte Street, since 1940.

West: The western adjoining property has consisted of residential property across Coyle

Street, since 1940.

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5.0 SITE RECONNAISSANCE

ETC conducted a site reconnaissance of the subject property January 5, 2026. ETC was granted access to the subject property by DPS. Site reconnaissance photographs are included in Appendix B.

5.1 Methodology and Limiting Conditions

ETC followed ASTM standards for site reconnaissance. Visual and physical observations of the subject property and adjoining properties were conducted. No limiting conditions were encountered during the assessment.

5.2 General Site Setting

The subject property is located in an area containing residential and commercial properties. The subject property includes unoccupied school building that is a 2-story structure, approximately 321,024 square feet on 18.12 acres. The building was expanded in 1971 to the north of the original structure. A boiler structure (with a stack) is separate from the main school structure, and connected with tunnels from staircases. The property is assessed as public-school property in Zone-R1, residential. A map showing the location of the subject property is located in Appendix A of this report.

Direction from

Subject Property Surrounding Properties

North Commercial property with frontage along Fenkell Avenue; a bank, a church, a diner, and retail.

East Single-family residences and a church.

South Single-family residences and dual townhouse (multi-family).

West Single-family residences and a church.

5.3 Current Use of the Subject Property

At the time of the site reconnaissance, the school building was unoccupied, and has not been used, since 2010.

5.4 Physical Setting Sources

In order to determine the physical setting sources for the subject property, ETC reviewed readily available information and made visual observations during the site reconnaissance. The results of this information are presented below. The U.S.G.S. 2019

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Royal Oak, Michigan 7.5-Minute Topographic Map for the subject property area is located in Appendix A of this report.

5.4.1 Topographic Conditions

EDR Radius Map reported the elevation of the subject property as 651 feet above sea level based upon the 2019 Michigan U.S.G.S. 7.5 Minute Topographic Map. The subject property appears to have a topographic general gradient in a southwest (SW) direction.

The closest surface water body, is the Rouge River, that is located 3.8 miles west (W) of

5.4.2 Soils and Hydrogeologic Conditions

Based upon U.S. Department of Agriculture’s Soil Conservation Service data, the dominant soil composition in the general area of the subject property is Urbanland complex with 0-4% slope. Soil types in the area are stratified by clay loam, loamy fine sand, loamy sand and silty clay.

Beneath the soil at unknown depth is the Upper Devonian Series, Antrim Shale (Ellsworth

Series of organic carbonate) of the Paleozoic Era, 358.9 to 382.7 million years ago.

ETC did not observe any surface water on the subject property. ETC did not obtain or review reports that document actual groundwater…