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Board Of Aldermen - Minutes - 2/23/2021 - P36

By dnadmin on Mon, 11/07/2022 - 06:58
Document Date
Tue, 02/23/2021 - 00:00
Meeting Description
Board Of Aldermen
Document Type
Minutes
Meeting Date
Tue, 02/23/2021 - 00:00
Page Number
36
Image URL
https://nashuameetingsstorage.blob.core.windows.net/nm-docs-pages/boa_m__022320…

Board of Aldermen 02-23-2021 Page 36

I've been there a couple of times. It is working like clockwork, they’ve got it down to a science. They have the
public health and hospital nurses giving the shots. They have the National Guard controlling — making sure that
people have appointments correctly and members of Nashua Fire Rescue that are there sort of directing traffic.
Starting this week in the evening hours there will also be a Police Officer there just to ensure that it keeps running
smoothly. So kudos to everybody involved in that activity and | think they are doing an outstanding job and |
hope that they continue that until as many people that would like to get a vaccine, get the vaccine. Thank you.

President Wilshire

Anyone else?

Alderman Caron

Madam Chair?

President Wilshire

One moment Alderman Caron.
Alderman Caron

Thank you.

President Wilshire

You're welcome.

Alderman Lopez

Yeah so | would just like to thank Director Bagley as much as she’s been working very hard on the COVID-19
situation and maintaining all of the other public health emergency responses that we traditionally deal with from
year to year. She also showed a lot of really good leadership in helping us make some major steps, | think, for
addressing the City’s deficit of warming stations. The Nashua Soup Kitchen is willing to start working and moving
forward with a weekend warming station which | know will be a great relief to people who are outside and
unsheltered and may have to be huddling in doorways. And it will also be some positive news for downtown
businesses who don’t know exactly what to do about people who are in distress on the weekends when there
isn’t anybody to call.

To those businesses, | would say support your local non-profits; the Soup Kitchen particularly is in the middle of
developing a large-scale project that is very, very sorely needed in the City. Its Spring Street Project will provide
decent and respectful shelter space for many single women and many single men that don’t have other
opportunities. It will also provide family shelter space which is extremely short in this community. And it includes
amenities that enhance the dignity and the ability to transition out of homelessness; things like childcare and
general resource space and classroom space. So they have really good plans for that site. They are kicking off
their capital campaign. | received a piece of mail a couple of days ago that | had very mixed feelings about. It
was in memory of Kristen Wolfe, a friend of mine who | had brought up in previous meetings having passed
away at the end of last year. She was one of the street artists who worked with me on the Veteran’s murals that
we have done around town with Positive Street Art. If anybody is interested she did the airplane on the eagle that
says “thank you”; you can see it from Water Street. She experienced homelessness and her family forwarded a
check to me and asked me to do whatever they thought would be most helpful to people who are homeless.
That is going to go to the Soup Kitchen and help with the warming station because | think that is something that
really would have helped her.

Page Image
Board Of Aldermen - Minutes - 2/23/2021 - P36

Board Of Aldermen - Minutes - 2/23/2021 - P37

By dnadmin on Mon, 11/07/2022 - 06:58
Document Date
Tue, 02/23/2021 - 00:00
Meeting Description
Board Of Aldermen
Document Type
Minutes
Meeting Date
Tue, 02/23/2021 - 00:00
Page Number
37
Image URL
https://nashuameetingsstorage.blob.core.windows.net/nm-docs-pages/boa_m__022320…

Board of Aldermen 02-23-2021 Page 37

Also, the Stepping Stones program a new program to Nashua located in Pine Street Extension, works with
adolescent homeless youth, another huge problem that we've finally started to make some headway on for
people who are experiencing homelessness ages 18 to 25. It gives them a day center to go to. It gives thema
place where they can search for jobs or even just take a crash from the pressure of the day, pursue education,
identify resources and case managers. It’s a really good program and they are also going to be working on
extending into Saturday. So again | want to thank Director Bagley for all of her help in managing that meeting. It
is a very good step | think and there was a lot of conversation about what we could do to better approach this in
future meetings so | think it was very encouraging.

And then finally | just wanted to let my constituents know that we have scheduled a Ward 4 Town Hall for March
18". So | will be posting about that on my page; it should be on the City’s website. Please plan to attend and
bring any issues that you have that are local to Ward 4 up. It'll be your chance to talk to the Mayor, find out about
City Projects that he’s working on and express your views. Thank you.

President Wilshire

You're welcome. Anyone else? Alderman Klee?

Alderman Caron

Alderman Caron?

President Wilshire

Oh I’m sorry.

Alderman Klee

| will defer to Alderman Caron.

President Wilshire

Alderman Caron, | am sorry about that.

Alderman Caron

That’s ok — when you can’t see someone. Thank you Alderman Klee. On a happy note I'd like to take the time to
thank Ruth Raswyk Deputy City Treasurer for her 45 years of service to the City of Nashua. She beat me out by
a couple of years. Her dedication to her job and the citizens of the City should not go unnoticed. | want to wish
her many happy years in her retirement and know that she will be missed by all who worked with her over the
years. Because of COVID and everything she really didn’t have a huge retirement party, but hopefully down the
road the Board of Aldermen will be able to recognize her in person before the year is out. And thank you for that,
Alderman Klee.

President Wilshire

Thank you Alderman Caron. Alderman Klee?

Alderman Klee

Thank you, Madam President. | have a couple of comments to make. One is I'd like to thank the Mayor for his
Ward 3 Town Hall Meeting. | have gotten a lot of really good feedback for it. The residents of Ward 3 that were
able to attend truly appreciated it and because it is videoed, | was able to send that out to other constituents who

were unable to make it that day. It brought up conversation and | think that was a great thing. The same with the
Parking Study Meeting for Ward 3 that Director Cummings had. That too brought up conversation and | was able

Page Image
Board Of Aldermen - Minutes - 2/23/2021 - P37

Board Of Aldermen - Minutes - 2/23/2021 - P38

By dnadmin on Mon, 11/07/2022 - 06:58
Document Date
Tue, 02/23/2021 - 00:00
Meeting Description
Board Of Aldermen
Document Type
Minutes
Meeting Date
Tue, 02/23/2021 - 00:00
Page Number
38
Image URL
https://nashuameetingsstorage.blob.core.windows.net/nm-docs-pages/boa_m__022320…

Board of Aldermen 02-23-2021 Page 38

to continue with my constituents afterwards explaining kind of the parking rules and bringing them to the
regulations and so on. And so many of them did not even realize not being able to park within so many feet of an
intersection or near someone’s driveway or across from someone’s driveway which might render what they think
is possible parking as nonexistent parking. Again both of these meetings opened up conversation which | think is
terrific.

I'd also like to comment that | think the City is doing a great job with the vaccines in areas that cannot get to the
High School or to something like that. Director Bagley has been doing a phenomenal job. That brings me to
Alderman Lopez and Alderman Clemons. Alderman Clemons | would like to thank you for making a point to
state that Alderman Lopez was unduly criticized for his wanting to do the right thing. | think he always tries to do
the right thing and we are lucky to have him. And I'd also like to make a side comment that we on the Board
oftentimes are criticized, we are elected officials, it kind of goes with the duty. But | don’t know of any Board
member that does anything, any vote for selfish reasons or for anything like that. We may disagree but | know
everybody is doing the right thing by their heart and so on. For the public, rather than doing an angry social
media blitz, | think perhaps contacting us and you doing your homework, finding out why we feel the way we do.
We don't always agree and we don’t always agree with the Mayor but we have civil dialogue. | think that we
need a little bit more of that in the country. So thank you so much for letting me be heard.

President Wilshire

Anybody else. Alderman Lu?

Alderwoman Lu

| just wanted to say Alderman Klee that was so nice. Thank you.

President Wilshire

Anyone else? OK Committee Announcements? Alderman O’Brien.

Committee announcements:

Alderman O’Brien

Thank you Madam President. Tomorrow night Wednesday the 24" at 7:00 p.m. will be Infrastructure via
Zoom.

President Wilshire
Alderman Tencza?
Alderman Tencza

Just a reminder next Thursday, March 4" PEDC we have our Public Hearing on some piece of Legislation that
are before us and then followed by a regular meeting. Thank you.

President Wilshire

OK anyone else. Alderwoman Lu?

Alderwoman Lu

Tomorrow from 9:00 to 10:00 is the Cultural Connections Committee Meeting. Ms. Schena will be presenting

some of the COVID Relief Programs available. And also Camille Pattison will be presenting on the changes to
the transit system. Thank you.

Page Image
Board Of Aldermen - Minutes - 2/23/2021 - P38

Board Of Aldermen - Minutes - 2/23/2021 - P39

By dnadmin on Mon, 11/07/2022 - 06:58
Document Date
Tue, 02/23/2021 - 00:00
Meeting Description
Board Of Aldermen
Document Type
Minutes
Meeting Date
Tue, 02/23/2021 - 00:00
Page Number
39
Image URL
https://nashuameetingsstorage.blob.core.windows.net/nm-docs-pages/boa_m__022320…

Board of Aldermen 02-23-2021 Page 39

President Wilshire
Thank you. | don’t see anyone else?
ADJOURNMENT

MOTION BY ALDERMAN O’BRIEN THAT THE FEBRUARY 23, 2021, MEETING OF THE BOARD OF
ALDERMEN BE ADJOURNED, BY ROLL CALL

A viva voce roll call was taken to adjourn the Board of Aldermen meeting which resulted as follows:
Yea: Alderman O’Brien, Alderman Klee, Alderman Dowd,

Alderman Caron, Alderman Clemons, Alderman Lopez, Alderman Tencza,

Alderwoman Lu, Alderman Jette, Alderman Schmidt, Alderman Laws,

Alderman Cleaver, Alderwoman Harriott-Gathright, Alderman Wilshire 14
Nay: 0
MOTION CARRIED

The meeting was declared adjourned at 9:55 p.m.

Attest: Susan K. Lovering, City Clerk

Page Image
Board Of Aldermen - Minutes - 2/23/2021 - P39

Board Of Aldermen - Minutes - 2/23/2021 - P40

By dnadmin on Mon, 11/07/2022 - 06:58
Document Date
Tue, 02/23/2021 - 00:00
Meeting Description
Board Of Aldermen
Document Type
Minutes
Meeting Date
Tue, 02/23/2021 - 00:00
Page Number
40
Image URL
https://nashuameetingsstorage.blob.core.windows.net/nm-docs-pages/boa_m__022320…

SCOPE OF DOCUMENT
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DESIGN CONCEPT IN TERMS OF THE
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Page Image
Board Of Aldermen - Minutes - 2/23/2021 - P40

Board Of Aldermen - Minutes - 3/15/2021 - P1

By dnadmin on Mon, 11/07/2022 - 06:58
Document Date
Mon, 03/15/2021 - 00:00
Meeting Description
Board Of Aldermen
Document Type
Minutes
Meeting Date
Mon, 03/15/2021 - 00:00
Page Number
1
Image URL
https://nashuameetingsstorage.blob.core.windows.net/nm-docs-pages/boa_m__031520…

A special meeting of the Board of Aldermen was held Monday, March 15, 2021, at 7:00 p.m. via Zoom
teleconference.

President Lori Wilshire presided; City Clerk Susan K. Lovering recorded.

Prayer was offered by City Clerk Susan K. Lovering; Alderwoman Elizabeth Lu led in the Pledge to the
Flag.

President Wilshire

As President of the Board of Aldermen, | find that due to the State of Emergency declared by the
Governor as a result of the COVID-19 pandemic and in accordance with the Governor's Emergency
Order #12 pursuant to Executive Order 2020-04, this public body is authorized to meet electronically.

Please note that there is no physical location to observe and listen contemporaneously to this meeting,
which was authorized pursuant to the Governor's Emergency Order. However, in accordance with the
Emergency Order, | am confirming that we are:

Providing public access to the meeting by telephone, with additional access possibilities by video or
other electronic means:

To access Zoom, please refer to the agenda or the City’s website for the meeting link.

To join by phone dial: 1-929-205-6099 Meeting ID: 818 83180777 Passcode: 603177

The public may also view the meeting via Channel 16.

We previously gave notice to the public of the necessary information for accessing the meeting, through
public postings. Instructions have also been provided on the City of Nashua’s website at www.nashuanh.gov
and publicly noticed at City Hall and the Nashua Public Library.

lf anyone has a problem accessing the meeting via phone or Channel 16, please call 603-821-2049 and they
will help you connect.

In the event the public is unable to access the meeting via the methods mentioned above, the meeting will
be adjourned and rescheduled. Please note that all votes that are taken during this meeting shall be done
by roll call vote.

Let’s start the meeting by taking a roll call attendance. When each member states their presence, please
also state whether there is anyone in the room with you during this meeting, which is required under the
Right-To-Know Law.

City Clerk Lovering called the roll and asked them to state the reason he or she could not attend, confirmed
that they could hear the proceedings, and stated who was present with him or her.

The roll call was taken with 15 members of the Board of Aldermen present: Alderman Michael B. O’Brien,

Sr., Alderman Patricia Klee, Alderwoman Shoshanna Kelly, Alderman Richard A. Dowd, Alderman June M.
Caron, Alderman Benjamin Clemons, Alderman Thomas Lopez, Alderman David C. Tencza, Alderwoman

Elizabeth Lu, Alderman Ernest Jette, Alderman Jan Schmidt, Alderman Brandon Michael Laws, Alderman

Skip Cleaver, Alderman Linda Harriott-Gathright, Alderman Wilshire.

Mayor James W. Donchess and Corporation Counsel Steven A. Bolton were also in attendance.

Page Image
Board Of Aldermen - Minutes - 3/15/2021 - P1

Board Of Aldermen - Minutes - 3/15/2021 - P2

By dnadmin on Mon, 11/07/2022 - 06:58
Document Date
Mon, 03/15/2021 - 00:00
Meeting Description
Board Of Aldermen
Document Type
Minutes
Meeting Date
Mon, 03/15/2021 - 00:00
Page Number
2
Image URL
https://nashuameetingsstorage.blob.core.windows.net/nm-docs-pages/boa_m__031520…

Special Board of Aldermen 03-15-2021
ROLL CALL
Alderman O’Brien

| am present, | can hear the proceedings and | am alone.

Alderman Klee

| am here, | can hear the proceedings and at this time, | am all alone.

Alderwoman Kelly

| am here, | am alone and | can hear everyone.
Alderman Dowd

| am present, | can hear everyone and | am here alone.
Alderman Caron

| am here, | am alone and | can hear everyone.
Alderman Clemons

lam here, | am by myself and | can hear everyone.
Alderman Lopez

| am here, | am alone and | can hear everyone.
Alderman Tencza

Present, | am alone and | can hear everyone.
Alderwoman Lu

lam here alone and | can hear you.

Alderman Jette

| am here, | am with my wife, and | can hear the proceedings.
Alderman Schmidt

| am present, alone and | can hear everyone.
Alderman Laws

| am here, | am alone and | can hear everyone.
Alderman Cleaver

Present, | am alone and | can hear everyone.

Page 2

Page Image
Board Of Aldermen - Minutes - 3/15/2021 - P2

Board Of Aldermen - Minutes - 3/15/2021 - P3

By dnadmin on Mon, 11/07/2022 - 06:58
Document Date
Mon, 03/15/2021 - 00:00
Meeting Description
Board Of Aldermen
Document Type
Minutes
Meeting Date
Mon, 03/15/2021 - 00:00
Page Number
3
Image URL
https://nashuameetingsstorage.blob.core.windows.net/nm-docs-pages/boa_m__031520…

Special Board of Aldermen 03-15-2021 Page 3

Alderman Harriott-Gathright

Present, | am at the hospital with my husband; a nurse or someone could be coming in at any time and |
am using ear phones.

President Wilshire
| am here, | am alone and | can hear everyone.

Susan Loving, City Clerk

You have 15 in attendance.
President Wilshire

Thank you, Madam Clerk.

City Clerk Loving

You're welcome.
President Wilshire

Tonight we are gathered for a presentation on the Mohawk Tannery Site. | am not sure if | should |
recognize the Mayor or Director Cummings; but whoever wants to go.

PRESENTATION

Mohawk Tannery Update

President Wilshire recognized Mayor Jim Donchess and Tim Cummings, Director of Economic
Development on the Mohawk Tannery Update.

Mayor Donchess

Yes, thanks Madam President. Director Cummings is going to give the detailed presentation, but it’s been
awhile since we visited this subject — that is the Mohawk Tannery and therefore | thought I'd give a brief
background of how we go to where we are. The Mohawk Tannery closed in about 1984 leaving behind
some so-called lagoons which are basically just holes dug in the earth filled with tannery waste that was
accumulated over many years and they left, of course, without cleaning it up. Now at various times over
the course of the intervening decades, the EPA suggested that this technically could qualify as a Superfund
Site, but always warned the City against joining the Superfund list and this has been done numerous times
over many years, because they said the pollutants in the lagoons are not the most serious, are not
migrating. Therefore, if we in the Superfund List we would really never get reached because the funds
would never go down far enough in the Superfund List. So they advised staying off the Superfund List.

Now, of course, the City has had Superfund sites in the past; the most significant of which was the Gilson
Road Site which was cleaned up by EPA Region 1 at a cost of many millions of dollars when | was Mayor
before. So the site has just remained dormant, there’s been a few things done, some buildings torn down,
a little bit of cover work has been done. But the lagoons remain. Several years ago, the EPA approached
the City and a private developer and said that for the first time they were interested in getting involved in
possibly working to clean up the site. They indicated that the reason they were interested is that they
thought, and this was critical, a public/private partnership could be arranged. And they thought, especially

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Document Date
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Meeting Description
Board Of Aldermen
Document Type
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Meeting Date
Mon, 03/15/2021 - 00:00
Page Number
4
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at the time, that the public/private aspect made this a project that they would devote some funds to. What
the meant by a public/private partnership is a partnership in which the EPA and a private developer would
share the cost to do the cleanup.

So we proceeded along that course. Initially there was an EPA Report regarding what was required for a
cleanup. The EPA Report recommended a consolidation of the waste into one area and a covering of the
material. The potential developer was also on board at that time and there was following the EPA’s decision
that it would get involved in that type of cleanup, but would not get involved in a removal because that was
two reasons; a lot more money and they said you are just moving the waste from one place to another.
After the EPA indicated that was its preferred solution then there was an undertaking to determine what the
approximate cost would be. Now that has taken some period of time and they and the developer have
exchanged plans and have arrived at at least an approximate cost.

The City along the way, of course, has encouraged this public/private partnership. Getting this area
cleaned up would be certainly a benefit. It has been clear the public/private partnership arises because the
site would be developed by a private developer into housing or assisted living. There have been various
ideas and plans presented, nothing definite yet to date; possibly some commercial development out near
the Broad Street Parkway and there would be access to the Broad Street Parkway. Along the way the City
has made it very clear that we are very interested in the public/private partnership that if a small amount of
City funds were necessary to sort of close the gap we might be willing to participate. But under no
conditions would we pay for the cleanup, we were most interested in the public/private partnership originally
proposed by the EPA.

That’s pretty much where we are now. They’ve sort of narrowed down the solution, begun to narrow down
the cost and we decided we should come to you now just because we hadn’t reported to you for some time
and we wanted to give you an update on where things stand at the present time. So I’ve given you an
overview but Mr. Cummings has been involved in very detailed discussions over time with the EPA, the
developer. We have had some neighborhood meetings along the way and Director Cummings will fill you
in on the remaining details.

President Wilshire
Thank you Mayor. Director Cummings, good evening.

Tim Cummings, Director of Economic Development

Yes thank you Madam President, for the record Tim Cummings, Director of Economic Development. |
appreciate you making the opportunity this evening as I’d like to give you a brief overview as to where we
stand with the Mohawk Tannery Project. So | have a few goals that I’d like to accomplish this evening.
First, |am hoping to just provide some general background and history. | am not sure whom on this Board
is actually familiar with this subject matter and as it has been a new Board since probably the last time we
discussed this, | thought it would be good just to give an overall update on the subject matter.

The update though is going to be really just confined to the last 2 or 3 three years relative to the efforts not
anything of past history. And then lastly | want to assess the appetite relative to a TIF as this is something
that had been discussed previously and | am just looking to get some direction and some feedback on the
idea of using this type of tool for this specific project.

So one of the things | thought | would do and | promise | am not going to share my screen for too long as |
know members don’t like to have screen share up. But | thought it would be wise just to quickly show my
screen if | could and orientate everyone into where we are exactly talking about within the City of Nashua.
So what you have up in front of you is a map that shows where my cursor is going down, that’s the Broad
Street Parkway right there. This is Fairmount Street right here; | give this to you just so you have some sort
of orientation. So over the next hour or so you are going to hear me talk about differing land areas and |
just thought you'd like to have this type of context. So right here, this is what we refer to as the City

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By dnadmin on Mon, 11/07/2022 - 06:58
Document Date
Mon, 03/15/2021 - 00:00
Meeting Description
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Document Type
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Meeting Date
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Special Board of Aldermen 03-15-2021 Page 5

property that’s “City Right of Way”; this is up along the Broad Street Parkway. This blue is the Fimbel Door
site and then just to the south of it you have the Mohawk Tannery, Site 1, Parcel 1 and the Mohawk
Tannery Parcel 2 or what is referred to as the southern site. Here’s the Nashua River along here. The
Fimbel Door is technically its own separate site and that’s just something folks should know from a context
perspective. It is its own separate site from an environmental remediation standpoint as it is a “capped
brown field”. And then this lower green area is actually the Mohawk Tannery. It gets a little confusing as
time goes on as | start to explain the project. Again, over here is the Turnpike. So | just want folks to have
that type of orientation as | begin to make my comments this evening.

lam going to stop sharing my screen and just the Memo | previously provided is just some good context; |
won't read that Memo but rather just add some additional details that hopefully will add some sufficient
background. So as the Mayor said previously, just a few moments ago, the site is known as the former
Mohawk Tannery Site also known as Granite State Leathers. It operated at the property between Fairmount
and Warsaw where it produced tan hides for leather between 1924 and 1984. The Mohawk Tannery Site
consists of two continuous parcels of approximately 15 acres each. The Tannery waste that was also part
of the disposal operation was mainly in the northern parcel not in the southern parcel of this site. Chester
Realty Trust is the current owner of the Mohawk Tannery Site. EPA and Chester Realty have a settlement
agreement for the site. It has been represented that the land area is under a Purchase & Sale Agreement
with the purchaser Blaylock Holdings, LLC. It is also my understanding the Blaylock Holdings, LLC. It is
also my understanding that Blaylock Holdings has a Purchase & Sale Agreement also executed to acquire
Fimbel Door from the current owner. Finally, Blaylock Holdings has expressed an interest in wanting to
acquire some of the right-of-way that abuts the Broad Street Parkway.

So | say that all to you to give you some context. Now | am going to talk a little bit about the environmental
situation at the site. The tannery produced sludge and acidic residue, much of which was disposed of in
two lagoons and other areas on the site. The sludge in the soils in the areas are contaminated with heavy
metals and semi-volatile organic compounds including among other substances Dioxins, 4-Methylphenol
Arsenic, Antimony, Cadmium, Manganese, Pentachlorophenol and Benzo(a)pyrene . Studies have also
shown that ACM is found in some of the areas in the surface and within the subsurface of the soil. EPA
and NH DES have been involved with many response activities at the Mohawk Tannery Site since in or
around about the summer of 1999. EPA and NH DES have provided that Blaylock has provided all the
available information relative to the existing contamination on the site and the adjacent properties. EPA
proposed the site for the National Priorities List in May of 2000 but it was never listed, it was withheld from
moving forward. The EPA performed an Engineering Evaluating Cost Analysis which was referred to as an
EE/CA in 2002 for the site. EPA completed an amendment to the 2002 EE/CA in 2018 at which time it
issued an Administrative Record for the EE/CA. The EPA then issued an Action Memorandum in
September of 2019 for removal to address the site for removal of the environment hazards.

EPA issued an Administrative Record on this in 2019 for that removal action. In September of 2019 the
Removal Action called for the removal of approximately 56,000 cubic yards of contaminated sludge, soil
and other hazardous material, easement and the removal calls for it to be consolidated and encapsulated in
an imperviable cap in and around the area of the Mohawk Tannery Site where approximately 68,150 cubic
yards of contaminated sludge overlaying soil is also present. Then the Blaylock has represented that they
would like to consolidate additional environmental hazards which was on the Fimbel Door Site and also the
environmental hazard that is in the right-of-way of the City, which is mainly asbestos, into this consolidated
cap site. My understanding is for this to occur, the EPA costed out the project to be somewhere between
$8 and $14 million dollars on their preferred alternative, which is, again, keeping the environmental hazards
on-site but encapsulated. My understanding is that through this public/private partnership that price could
be lowered. It has been represented that it could be represented significantly to something like $8 to $10
million dollars at which point the private developer would undertake this with assistance from the EPA and
the City of Nashua.

So the EPA recently updated their most recent public document on February 12, | believe that was the
Administrative Record that was produced previously in 2019. There was a public comment period which is
one of the reasons why | wanted to get this Memo to you, so you had the opportunity, if you so desired to

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