• Major Parks Needs
• Neighborhood Parks Needs
• Recreation Centers Needs
• Recreation Outpost Sites Needs

Each of these topics is addressed in the Needs and Challenges portion of this section.

The St. Louis Department of Parks, Recreation & Forestry provides amenities that make the City a good place to live, work, and play. The Department consists of three divisions: Parks Division, Recreation Division, and Forestry Division. The Parks Division maintains 105 parks throughout the City, totaling approximately 2,846 acres. Forest Park is by far the dominant park, at 1,293 acres. Tower Grove Park, with 289 acres, is operated by the Tower Grove Park Board of Commissioners, and is not part of the Parks Division. The table that follows lists the names and acreage associated with the City’s 106 parks.

Table III-D-7

Italics indicates major parks

** = Tower Grove Park is not part of the Parks Division

Source: Department of Parks, Recreation & Forestry, 1999.

The Recreation Division provides a multitude of leisure activities for all age groups throughout the City. The division fully utilizes these centers by offering a variety of programs that reflect the needs and desires of the community in proximity to the centers, thereby allowing them to function as part of the neighborhood fabric. Programs are targeted to all age groups, levels of fitness, and economic backgrounds; however, the majority of participants are low- to middle-income. Current operations include:

• 9 Recreation Centers
• 1 Neighborhood Center
• 5 Indoor Swimming Pools
• 3 Outdoor Swimming Pools
• 25 Summer Day Camps (at various parks and recreation centers)
• Tiny Tot Summer Day Camp programs at selected sites
• 7 Boxing Program sites
• 5 to 15 Recreation Outposts at St. Louis Public Schools*
• Several Recreation Outreach sites at community churches*
• Expanded League year-round sports program*

• Recreation Arts Program*

* Asterisk indicates a Community Development Block Grant-funded program.

In addition to on-going year-round programs offered at the above sites, the Recreation Division administers more than 300 adult softball teams engaged in league play, a myriad of youth softball teams co-sponsored by the Metro ASA, seven boxing sites, park concerts, plays and sporting events, the annual Games for the Physically Disabled, and various special events. During 1997-98, participation exceeded 656,000.

Major Parks. The City of St. Louis has six major parks – Forest Park, Tower Grove Park, Carondelet Park, O’Fallon Park, Willmore Park, and Fairground Park. Each is a jewel in the crown of the City; Forest Park is the most substantial of the six in size and popularity. Over the past five years, the Forest Park Master Plan process has made substantial improvements to the infrastructure of the park. These improvements are scheduled to be complete by 2004. Tower Grove Park has also made significant improvements in the past five years, under the leadership of its Board of Commissioners and with support from capital improvements sales tax funds. The remaining four major parks have many challenges, which are being addressed gradually.

Neighborhood Parks. The many neighborhood parks scattered throughout the City are very important to overall quality-of-life. However, many suffer from decades of decay and disinvestment. The Parks Division does not have adequate resources available to it to meet all neighborhood park needs. Sometimes aldermen choose to spend their capital improvement allocations on neighborhood parks, but some do not. Neighborhood involvement can help improve many of these parks. When the surrounding community or an institution "adopts" a park, more funds are likely to be secured for improving the park.

Meanwhile, some communities have expressed an interest in creating new neighborhood parks on currently vacant parcels. However, liability insurance and maintenance can be quite problematic and expensive on such sites. Each site is examined on a case-by-case basis to determine its viability as a park. In most cases, the Parks Division does not establish and maintain new parks created on vacant parcels, but instead a private neighborhood group is responsible for the maintenance and liability. Other parks, such as those in the Laclede Town area of Midtown St. Louis, have been divested from the parks system because their neighborhoods have no population. The Parks Division has, during the past five years, sold off several such parks to other institutions.

Recreation Centers. The needs of City Recreation Centers for the next five years are as varied as they are great. The recreation centers are all in need of capital upgrades. Some are more in need than others. Capital needs include central air conditioning, painting, ADA-compliance modifications, and indoor lighting. Also needed is additional equipment such as soccer nets, weight training equipment, tiny tot furniture, tutoring desks, tables, chairs, and sewing machines. In 1999, for the first time, four of the centers will provide children and youth up to age 18 with a free evening snack and full hot nutritious dinner through a federally funded grant. This program, called RENT, is administered by the Department of Social Services.

Recreation Outposts and Outreach. The City of St. Louis offers Outpost programs at various St. Louis Public Schools, and Outreach programs at selected religious institutions. Both programs have varying degrees of success. The Outpost program suffers because some school principals are unable to provide access to facilities during evening hours because of overtime charges for custodial services and because of the lack of security guards. As a result, some of the outposts have shut down after relatively brief periods of operation. These problems are not as pronounced in the Outreach program, but the schools are preferred sites for these services because many are already open in the early evening as Community Education Centers (CECs). The Recreation Outpost program extends those hours into the later evening.

Continue improving the quality of parks and recreation facilities in the City of St. Louis.

1. Continue to support the City recreation centers, outposts and programs.

In meeting the recreational needs of its citizens, the City should continue to provide the programs and services that have been effective. The current expanded recreation program has been effective in delivering recreational opportunities to youth in low- and moderate-income areas.

 

 

 

2. Expand opportunities for girls in Recreation Division programs.

The emphasis on men’s sports and activities is pronounced at some recreational complexes. A balanced offering of activities must be offered for girls and young women.

3. Work with the public schools to deliver services.

Currently, some of the public schools serve as Outpost Sites for the Recreation Division. An expansion of this partnership will allow recreational and educational uses. This would connect with the City-funded Community Education Center programs already offered at many City schools.

4. Continue to network and share information with non-profit organizations.

To prevent duplication of services and maximize synergy, the Recreation Division should continue to coordinate with organizations such as the YMCA, YWCA, Herbert Hoover, Mathews-Dickey, and the Boys’ Club of St. Louis to provide recreational services.

5. Consider dedicated funding sources for neighborhood parks.

While each of the six major parks has dedicated funding, the local neighborhood parks are also essential parts of the community but do not receive such funding. They need thorough infrastructure and programmatic maintenance to adequately serve the community.

6. Complete implementation of the Forest Park Master Plan and major park improvements.

The revitalization of Forest Park is important to the strength of the whole region. However, the other five major parks also have important assets that need to be updated and maintained.

7. Consider coordinating City Parks Division improvements with the Confluence Greenway and Gateway Parks & Trails 2004 initiatives.

The August 1993 voter approval of a sales tax for capital improvements has provided a substantial revenue source for capital improvement needs. These funds are broken down as follows:

• Major Parks Improvements: 17%
• Recreation Center Improvements: 3%
• Ward Improvements (may include neighborhood parks at discretion of alderman): 50%, split 28 ways evenly, so that each ward receives about 1.8% of the total sales tax revenues.
• Citywide Improvements (primarily major streets and City facilities): 20%
• Police Department Improvements: 10%.

Revenues from the capital improvements sales tax should be supplemented with other funds, including CDBG where applicable, State of Missouri conservation funds, and the Missouri Landmark Park Grant program so that the park and recreation system may be maintained and upgraded as necessary. If the Metropolitan Park and Recreation District proposed by Gateway Parks and Trails 2004 and authorized by legislation passed by the State of Missouri in July 1999, is approved in a future referendum by City voters, it will also have a great impact. Thirty (30) percent of the revenues generated from the proposed tax would go to each "county" in the district, and 20 percent would go to municipalities and local park agencies to benefit parks. Because the City of St. Louis operates both as a municipality and as a county in the State of Missouri, the City of St. Louis would receive 50 percent of the revenues generated from the sales tax levied for the Metropolitan Park and Recreation District in the City of St. Louis. Further, since many regional parks are already located in City limits, these parks may benefit from the 50 percent of the remaining sales tax proceeds, which are earmarked for regional parks and trails.

Much has changed over the last five years as the City has struggled to provide more parking, especially parking required to support development projects. Recently, partially attributable to the Downtown Now planning initiative, there has been increased recognition of the critical role parking plays in development.

The City continues to own or control approximately 5,000 parking garage spaces and around 10,000 on-street metered spaces. Many of the parking facilities, however, are privately owned. The City Treasurer’s Office and Land Clearance for Redevelopment Authority (LCRA) are the two local government entities involved in the management of City-owned parking facilities.

The Treasurer’s Office has had a major role in the provision of new parking spaces. Since the mid 1990s, the Treasurer’s Office has contributed about $800,000 annually to the General Revenue fund, after expenses. As a result, the Treasurer has been able to undertake some major projects, including:

• The Kiel Garage, which after substantial redesign efforts by the Kiel Partners was developed with $25 million in revenue bonds that have since been refinanced. The garage provides 1,200 spaces in support of the Kiel Center.

• City Hall Parking lot, which was reconfigured with a $1.2 million revenue bond into an efficient, aesthetically pleasing lot. The capacity was raised from around 270 to 400 spaces, a number that will increase by more than 100 when the new jail is completed and the old jail is no longer required.

• The Marquette Garage, which replaces the 11–story Marquette Annex with a 360-space garage, will support 140 upscale residential apartments in the old Marquette Building. Built with a $8.5 million revenue bond, this garage was purchased by the Treasurer’s Office for $500,000. It will have retail shops on the ground floor and basement levels. Formal dedication is scheduled for November 1999.

• Schlafly Library in the Central West End, which will combine a new modern library facility with a 460-space garage on the site of the old Argyle Apartments at Euclid and Lindell. Funded with a $12 million revenue bond, this building will house a library, its major tenant; a bank; and street-level retail shops. A TIF provides a guarantee, if necessary, to pay off the bond. The project allows replacement of the small Lashly library, while resolving a long-time parking problem.

LCRA has also been active in the parking business, but to a lesser degree. The St. Louis Centre East Garage has been renovated and expanded by about one hundred spaces. It will be refinanced with a transaction that will allow for the demolition of the old Stix Garage in Spring 2000. When the garage was purchased, the intent was to build a hotel at the site. The building is very deteriorated and many believe it is a suitable development site. In the meantime, it will be replaced with an attractive surface lot. Other lots owned by LCRA that are included in current development plans are the lot at 8th and Washington, which is the site of the new Convention Center Hotel Tower to be built across from America’s Center and the City Block 426 lot, which will be integrated into the Cupples Station renovation. This development promises a hotel, office space, and perhaps housing. LCRA sold its leasehold interest in the New Stix Garage to AFI investments.

After years of resisting parking, at least in the core of downtown, there is new appreciation that nearby, if not adjacent parking is often the difference between a development project that works or does not. Fortunately, the Treasurer’s Office is building a track record that will allow it to support many anticipated development projects in the future. Among the potential parking complexes under consideration for the future are:

• Garage just south of the new Justice Center, with between 500 and 700 spaces that could also support those in the Thomas Eagleton Court House and 1010 Market Building.
• Garage to support the new convention center hotel on Washington Avenue.
• Garage to support renovation of buildings in the Old Post Office core of downtown.
• Garage to support businesses along Market, including employees in the Wainwright building.
• Garage to support re-occupancy of major office buildings on North Tucker.

These and other options will be analyzed to determine if they are financially justifiable. Metered parking must also be examined. Free parking on a short-term basis (perhaps two hours on weekends) may also help downtown retailers compete with their suburban counterparts. The policy should be structured so that customers, not downtown employees, benefit from the availability of free spaces.

1. Explore a more formal arrangement between the St. Louis Development Corporation, the Planning and Urban Design Agency, and the Treasurer’s Office.

The last five years have evidenced the ability to stimulate development in downtown and City neighborhoods through careful development of parking structures. The City’s development agencies and the Treasurer’s Office should develop a cooperative relationship that will lend to the City’s resurgence.

2. Continue to adopt new technology that speeds the auditing, cash collection, and processing of revenue from meters.

3. Continue to analyze parking opportunities that can support retail activity in both downtown and neighborhood commercial areas.

In addition to downtown garages, surface parking lots support neighborhood commercial districts in areas such as Cherokee, South Grand, and Bevo. When considering additional facilities, evaluate cost relative to expected revenue.

4. Remove parking meters that are not necessary. Sections of the City are characterized by parking meters that hardly seem necessary.

The ability to construct parking facilities using revenue bonds has been successfully demonstrated in recent years. The goal of such projects should not necessarily be to generate a profit, but to at minimum break even, while contributing to the success of the nearby development. Modern approaches are allowing the Treasurer’s Office to offset its costs, while at the same time contributing to the City’s General Revenue Fund.

In the past five years, the Refuse Division has maintained its trash collection services while acting to reduce waste through aggressive recycling programs. Total cost for refuse collection and disposal during FY98–99 was $14,069,952 or $41.47 per capita (339,316 population). In FY98, a new municipal solid-waste and yard-waste disposal contract began with Waste Management, Inc., resulting in a 28 percent reduction in cost for disposal of solid waste. The Refuse Division is aided in its role by the City Forestry Department, the St. Louis Jefferson Solid Waste Management District, and by Operation Brightside, a private nonprofit organization.

Five years ago, the Refuse Division suggested several recommendations for improving its services. The suggestions included improved maintenance of equipment; exploration of curbside recycling; efforts that encourage recycling; educational programs targeted to different segments of the community; and a reviewing ordinances related to illegal dumping and misuse of dumpsters. As a result of those recommendations, curbside recycling is in place; the volume and variety of recyclables collected by the City has greatly increased; and there has been a serious crackdown on illegal dumping.

Waste Collection. The Refuse Division employed 159 full-time employees in FY98, along with 19 part-time employees and 5 interns. These employees collect and dispose of all solid waste created the City of St. Louis. 60 trucks that operate daily offer collection twice weekly. The trucks are dumped at one of the City’s two Transfer Stations. These stations, located at 201 North Humboldt and 4100 S. First Street, are operated by Waste Management Incorporated, a private firm contracted by the City. Waste Management is also responsible for hauling the refuse to a landfill for final disposal.

The Refuse Division picks up the waste from 30,000 metal dumpsters and 20,000 plastic roll carts. Roughly 167,484 tons of refuse were hauled from Downtown and residential containers in 1998. The Division also offers City residents a bulk item collection once a month, collecting items that are too large to fit in containers provided. Residents simply put items to be removed in the alley or in front of their homes. Bulk item collection is an increasingly popular service: 8,258 tons were collected in FY98.

The Forestry Division assists the Refuse Division by removing debris from alleys, vacant lots, and vacant building sites throughout the entire City. The Forestry Division also cuts the grass and removes the weeds from these lots every four weeks and from building sites every six to eight weeks. Debris removal is done as preventive maintenance or on a complaint basis. Fifteen thousand truckloads of debris were hauled from these sites in 1998. This work costs the Forestry Division $3 million, but because a large percentage of the lots/buildings are public, only $750,000 of the $3 million is collectible.

Recycling and Recycling Education. The City has launched several recycling initiatives to continue preserving the environment. The total tonnage recycled by the Refuse Division in FY97–98 was 4,225 tons, a 14 percent increase over FY96–97. Household recyclables, yard waste, and B.O.A.T. (Batteries, Oil, Appliances, and Tires) items were collected.

Between 1995 and 1999, the number of drop sites increased from 11 to 26 and expanded from mostly newsprint collection to include collections including aluminum cans, steel food cans, glass and plastic bottles, and jugs. Drop-sites are scattered throughout the City at convenient locations, such as firehouses, parks, and libraries. The increase in drop sites resulted in a 39 percent increase in total household products recycled in FY 1997–1998, compared to the previous year. Newsprint recycling alone increased from 94,240 pounds in 1995 to 2,904,000 pounds in FY 1997–1998, netting the following savings:

• Energy equivalent of 667,920 gallons of oil.
• Approximately 24,684 trees.
• About 11,616 cubic feet of landfill space.
• Elimination of about 87,120 pounds of air pollutants.

Recycling efforts made by the Refuse Division are supplemented by those of Operation Brightside, a private nonprofit organization. Operation Brightside runs the City’s largest recycling center at Kingshighway and Highway 44, and organizes several volunteer programs that supplement the work of the Refuse Division. The organization has five full-time employees and an annual operating budget of $500,000 to $600,000. Funding for Operation Brightside comes from Federal block grants as well as donations from individuals and corporations. The largest of its volunteer programs is "Project Blitz." It occurs every year in the Spring, combining the efforts of the Street Department, the Forestry Division, the Parks Division, the Traffic Division, the Water Division, the Refuse Division, and approximately 75,000 neighborhood volunteers to remove trash from vacant lots, gutters, and alleyways. Volunteers are organized by block captains who obtain trash bags, rakes, brooms, shovels, and even flowers from Operation Brightside. Other Brightside programs include cleaning and maintaining vacant lots and graffiti eradication.

The City has reduced its waste stream by approximately 15 to 20 percent as a result of yard waste and B.O.A.T. collection programs. Yard waste is gathered once a week and taken to two transfer stations. Residents are also able to bring one standard size pick-up truckload to either transfer station once a month. Yard waste has consistently accounted for 25,000 tons of material to be composted since 1995. In the past year, the Forestry Division was also responsible for the collection of 14,000 Christmas trees. The trees can either be dropped off at three area parks between December 26^th and the third week of January or set out for bulk item collection. The trees are then turned into reusable mulch. This mulch is used throughout the City in public spaces and given away in the Spring to citizens for personal use.

The B.O.A.T. Program. This recycling initiative collects batteries, oil, appliances, and tires once a month in the same manner as bulk items. Residents of the City can bring these items to the North transfer station. In FY 97–98, residents recycled a total of 1,210 B.O.A.T. items. In conjunction with the major efforts to collect recyclables throughout the City, the Refuse Division has targeted specific institutions and types of recyclable waste through various programs listed below. Funding for these programs came largely from grant funds made available by the St. Louis–Jefferson Solid Waste Management District. Data from these projects allow the Refuse Division to learn what types of recycling options provide the best results in terms of participation and cost.

St. Louis Recycles. An ongoing education program funded by a grant from the Jefferson Solid Waste Management District. This program provides each resident with information on private and public recyclers and what items are accepted. In the months following the mailing on the "St. Louis Recycles" brochures, there was a dramatic increase in the amount of materials recycled at the drop-off locations.

School Recycling. In 1997, the Refuse Division helped 32 schools start permanent paper recycling programs serviced by their trash haulers. The Division provided technical assistance, educational materials, classroom presentations, and bins. By March 1999, school recycling had expanded to 53 schools with seven additional schools to be added in September 1999. Between October 1997 and March 1999, 269.75 tons of paper were recycled in schools.

City Government Recycling. In FY 1997–1998, employees at City Hall, Refuse Division, Streets Department, Municipal Courts, Juvenile Courts, Civil Courts, Facilities Management, the Health Department, and the Communications Division recycled 72.7 tons of mixed office paper.

Curbside Recycling. A pilot project is underway that gives citizens in a limited area of the City the option of curbside recycling. The citizens and City share the cost of curbside recycling. The service costs citizens $24 a year, paid directly to the contractor, and the City picks up the remaining $48.00. Each participant is issued a plastic container for recyclables, which are picked up weekly.

As recycling has become a priority to the citizens of St. Louis, the Refuse Division, along with Operation Brightside and the Forestry Division, have developed educational programs and incentives to make City youth aware of the importance of recycling. Service providers hope that as children become more informed, they will inform and influence their parents to recycle. Seven programs are now in place to teach the benefits of proper recycling:

• Introduction to Recycling (Grades 1–5)
• Recycle Rangers (Grades K–5)
• Trash Detectives (Grades K–3)
• My First Million (Grades 4–8)
• The Paper Trail (4–Adult)
• The House That Trash Built (Grades 3–7)
• The Rotting Truth (Grades 7–12)

Materials supporting these programs are available to public and private school teachers free of charge through the Refuse Division.

Punishable Illegal Dumping. Illegal dumping was costing the City of St. Louis over $1 million a year in clean-up costs. In March 1996, the Trash Task Force was created to stop this costly damage. The effort has been very successful. Since the development of the Task Force, 460 arrests have been made, each resulting in a fine up to $500.00 and/or 90 days in jail. Complaints about and incidents of illegal dumping have decreased. The Trash Task Force has received national recognition for its work and has advised other cities on how to establish systems for monitoring illegal dumping. Funding for the Trash Task Force comes from the City’s Neighborhood Stabilization Budget; $104,000 was allocated in FY98–99 and, $129,000 is allocated for FY99–2000.

The Refuse Division has an ongoing need to replace outdated equipment. Money allocated in the FY00 Capital Budget will assist in this effort but more needs to be done. In FY00, $235,000 is allocated to do repairs at the facilities and through a lease/purchase will provide funding for 21 side-load refuse trucks and 8 dump trucks for bulk pickup.

Another area in need of improvement is the collection of hazardous waste. Hazardous waste includes items such as household chemicals, insecticides, and paint. Currently, the Metropolitan Sewer District collects these items once a year, but there should be more frequent collection. A program made possible by a one-time grant in 1995 set aside specific days for City residents to dispose of outdated hazardous chemicals. Approximately 1,500 vehicles made drop-offs at the City-sponsored event.

On March 9,1999, Operation Brightside launched "Stop It, Don’t Drop It," a new antilitter campaign. The cornerstone of the "Stop It, Don’t Drop It" campaign is its adopt-a-can initiative, whereby City residents and business owners can purchase heavy-duty trashcans directly from Operation Brightside. Operation Brightside will provide a new trash can bearing the campaign theme and Brightside logos and the City Refuse Division will empty all the cans on a regular basis, free of charge. The "Stop It, Don’t Drop It" campaign’s focus on education and awareness will be just as important as adding more trash cans in solving St. Louis’s litter-control problem.

1. Provide more information to the public on recycling services available, such as bulk collection, B.O.A.T., recycling, yard waste collection, and drop-off sites. The City offers a diverse array of refuse programs.

 

Traditional media (newsletters, flyers, newspapers, etc. ) and new media (Internet, Cable Television, etc.) provide new opportunities to advise about the benefits of recycling.

 

2. Continue introducing education programs in the schools and at neighborhood meetings.

 

Youth can help educate parents and other adults about the benefits of recycling.

 

3. Expand the Trash Task Force to reduce illegal dumping and to instruct residents.

 

Right now there are six Task Force members and the City intends to hire more.

 

4. Encourage the Supply Division to encourage the purchase of recyclable goods.

Resources are limited due to the City’s policy of not charging for collection. The increasing cost of collection will affect the general revenue fund. An ambitious grant writing effort might offset negative cash flows. The best long-term method, however, is to teach consumers how to recycle.

An additional, but limited, source of revenue to offset the clean up of vacant property relates to the absentee owners of such property. When ownership can be determined, the owner is billed for clean-up services provided by the Forestry Division. Collecting for such services is difficult.

The City struggles to maintain air quality standards set by the EPA and at the same time, facilitate industrial and commercial growth and the restabilization of City neighborhoods. Air pollution in St. Louis diminished 37 percent between 1991 and 1996, according to the most recent Environmental Protection Agency (EPA) report. The dramatic decrease is attributed to new regulations and stricter enforcement, the departure of several big polluters, and to upgraded equipment in facilities. The regulated community is concerned, however, that despite these gains new regulations will be put in place that make the process of doing business and buying property in the City more cumbersome and expensive.

Currently, the St. Louis area is classified by the EPA as having "moderate" air pollution. Efforts established over the past five years along with future goals will bring the St. Louis area closer to the standards set by the EPA. Air Pollution Control (APC) serves as the environmental regulatory body in the City, enforcing all State and Federal air pollution regulations. Activities include permit issuance, compliance inspections, and air quality monitoring in the region.

APC enforces Federal asbestos regulations. APC handles all asbestos complaints throughout the City. It receives and reviews the Clean Air Act’s National Emission Standards for Hazardous Air Pollutants (NESHAP) Asbestos Notifications. In FY99, approximately $50,000 was spent on asbestos regulation. The federal government in some instances conducts asbestos reviews on residential or commercial properties. For the most part it has passed responsibilities on to the state that, in turn, works with the Air Pollution Control Division. While APC’s responsibility is enforcement of the air pollution laws for stationary industrial sources, with secondary responsibility for monitoring of vapor recovery in service stations, they do asbestos inspections triggered by NESHAP requirements. APC is responsible for enforcing Federal NESHAP asbestos regulations in regard to renovation or demolition of all buildings.

Individual residential (four-family or less) homes may currently be demolished without prior asbestos inspection as long as no more than one structure per owner on an individual city block is demolished within a 12-month period. If more than one residence per owner on a block is demolished in a 12-month period, the Federal NESHAP rule would apply. All four-family or greater residential structures and all commercial and industrial facilities are subject to the Federal NESHAP requirements. Those cases require at least an on site inspection by a state certified asbestos inspector to determine if asbestos is present and in what amounts and types. Under Federal NESHAP requirements Asbestos Containing Material (ACM) in amounts greater than 160 square feet or 260 linear feet must be abated according to the rules. There is a $100 fee for notifications to APC for asbestos removal in amounts greater than those listed above. A recent Missouri Supreme Court ruling determined the state asbestos rule to be invalid. As a result, the EPA standard prescribed by NESHAP is used as the standard in Missouri. Current revenue from notification fees totals less than $20,000 annually, which does not cover the total cost to APC of this program. There is an average of ten or fewer new NESHAP level jobs on a monthly basis in the City of St. Louis.

Inspections. APC conducts inspections under the Clean Air Act Amendment National Emissions Standards for Hazardous Air Pollutants (NESHAP). In addition to asbestos related inspections, Air Pollution Control inspected 525 industrial and commercial facilities and more than 160 semi-annual inspections of gasoline dispensing facilities in 1998. Approximately 30 percent of the gasoline dispensing facilities demanded repeat inspections due to some type of violation, causing the total number of gas dispensing facilities inspections to rise to over 425 annually. These inspections are performed semi-annually and include compliance inspections and/or system testing for permit issuance. Importantly, the APC is participating in the State of Missouri’s Reformulated Gasoline Program. This program will substantially reduce ozone levels by dispensing fuel with higher oxygen content.

Permitting. Air Pollution Control requires a permit for construction or modification that may cause:

• Creation of air contaminants;
• Emission of air contaminants;
• Elimination or reduction of emissions and air contaminants.

These permits take from one to six months to obtain depending on the situation. There is an application review fee of $100.00. An additional fee of $30 is charged for each emission source. There is no fee for source registrations. Permits are not needed for residential buildings unless there are five or more units or the structure is being demolished and replaced with a site intended for public or commercial use. The table below summarizes permitting activity from 1994-1999.

Table III-D-8

*Air Pollution Control approves these permits but does not issue them; building permits are issued by the Building Commission.

Source: Air Pollution Control

Monitoring Air Quality. Air quality in St. Louis is improving, as evidenced by fewer violations against two federal air pollution categories: ground level ozone and dust/smoke/exhaust fume. Both have decreased steadily over the past five years. In 1995, there were 20 violations, while in 1998 there were only three violations. An important task of the Air Pollution Control Division is to continue to monitor air quality in the area. The City has a network of 8 air pollution monitoring stations (1999) that are maintained by Air Pollution Control. They monitor sulfur dioxide, nitrogen dioxide, ozone, carbon monoxide, and inhalable particulate matter. These stations monitor air quality 24 hours a day. One new station will be installed and begin operating in 1999.

As a result of recent studies that suggest smaller particles of particulate matter are more harmful to one’s health than larger particulate matter, the APC is now measuring for particulate matter 2.5 (P.M. 2.5) microns and also P.M. 10 microns. APC has received a grant from the EPA through the MDNR to monitor these particles. Plans are underway to add additional monitoring sites for P.M. 2.5 later in 1999. These stations will collect data, which will go ultimately to the EPA to develop better P.M. 2.5 standards. Currently there is no standard as a result of a recent court decision, which determined that more data is necessary before current EPA standards are actually enforceable.

Costs Of Cleaning Removing Asbestos Containing Material. Increased regulations on hazardous material and the cost of mitigating those hazards decrease the desirability of owning property in the City. A building owner can never be legally free of the liability for hazardous waste associated with that property. If a contractor is hired to mitigate the problem and the State finds fault with the removal process, the owner as well as the contractor can be fined. Once the ACM is placed in a landfill, should the material be dug up at some later date for any reason, the owner is responsible for its re-removal. When facing the costs associated with clean-up, owners of smaller buildings often opt to let the property go into tax foreclosure. The cost of attempting to secure clean-up funds from owners could exceed clean-up costs. Moreover, in many cases, the owners do not have the funds necessary to clean a site. On larger buildings, the City has pursued action, but asbestos is not covered under Superfund Liability by the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), making enforcement difficult.

On the residential front, the City’s Land Reutilization Authority (LRA) currently owns approximately 11,075 properties, of which 2,956 are under option or in the process of being sold. Of the remaining 8,119 properties, 6,533 are lots and 1,586 have improvements. As a result of tax foreclosures and donations, the City receives another 500 to 1,000 buildings per year. Approximately 200 buildings are demolished per year. The funds for those demolitions come from Community Development Block Grant, and the proceeds from inventory sales, and from the General Revenue Budget. Eighty to 90 percent of these properties are routine demolition costing $3,000 to $4,000. The remaining 10 percent may push that cost up four to 10 times if asbestos is present. The increased cost can be attributed to the testing (i.e., 5 to 15 samples per building at $20-30 for each sample) required to confirm the presence of and condition of any hazardous material, as well as the clean-up. If buildings with ACM are vandalized or collapse while awaiting disposal, the entire building may be considered a health or safety risk generating hazardous waste. The cost can climb to $10,000 to $20,000 for each building. A study recently undertaken by LRA shows that the City loses $2 to $70 per sq. ft. on resale of property it owns due to the cost associated with hazardous clean-up. LRA has been declining donations of commercial structures for this reason.

New Comprehensive Permits Required Under the Clean Air Act. APC and the regulation community are currently adapting to a new EPA regulatory requirement, Title V of the Clean Air Act dealing with operating permits. As of May 1999, every large emitter (defined as anyone with the potential to emit 100 tons per year) must now obtain a special detailed operating permit. The permits are labor intensive for industry and for APC staff, taking up to a year for the City alone to process. Two additional staff members were hired to keep up with the work. Seventy companies in the City are affected and have begun filing the necessary paperwork. The EPA requires that all large emitters acquire the new permit by the end of 2000. Once the permits are in place, APC will have to monitor them.

Potential For New Regulations. An issue is developing that may impact quite heavily on APC and on economic development in the City. A recent court decision could change the unit of measure for ozone that would reclassify St. Louis’ air quality status from moderate non-attainment to serious non-attainment. According to this ruling, ozone exceedence would be based on an eight-hour average rather than the current hourly average. The airshed in St. Louis fairs poorer under the eight-hour average. To illustrate, in the first three months of the 1999 ozone season, there were no ozone exceedences under the hourly average, but there were 10 exceedences under the 8-hour average. If the eight-hour average becomes the new standard, permitting requirements from the EPA would increase dramatically. Currently a facility must be a 40-ton/year emitter before a construction/operating permit is required but under a serious non-attainment classification, the criteria would lower to ten tons each year. Staff at APC would have to be doubled to handle the new rule and many facilities currently not under regulation would have to be regulated. APC does not know from year to year what regulations will be added and/or revised by the State and the Environmental Protection Agency.

1. Make administration of APC "zero-cost" to the City by fiscal year 2004.

APC has drafted an ordinance for consideration by the Board of Aldermen in Fall 1999. If implemented, fees could triple to a total of $150,000; the theme of the ordinance is to be fair to the regulated community—not to require permits when they aren’t necessary but to collect more from the big polluters. Other cost savings are anticipated through billing for indirect costs and maximizing available grant dollars.

2. Design and send a mailer informing residents of the causes and solutions of air pollution.

Asbestos Abatement. Currently LRA demolition activity is funded with Community Development Block Grant support. While the smaller buildings are of concern, one or two large commercial sites could use the entire budget. Additional funding sources are highly desirable.

Regulation (Air Pollution Control Division). Funding has been stable over the past five years from both MODNR and from the City but in real dollar terms; that means the budget has not been adjusted for inflation. Still, no major programs are jeopardized. APC will continue to aggressively seek grant funds from the EPA to finance its operations. In addition, subject to approval from the Board of Aldermen, polluter fees will increase, bringing in an estimated $150,000 annually, or $100,000 more than is currently collected.