Two documents came back from a records request to EGLE last week. They’re the environmental assessments the University filed on the Textile Road land, and they answer a question people here have been asking for a year.
Both are posted in full: the one for 10221 Textile Road and the one for 10455 and 10635. They’re long and mostly appendices, but the part that matters is on the first page of each.
What a BEA is, and why filing one tells you something
A Baseline Environmental Assessment exists for one purpose. Under Part 201 of Michigan’s environmental law, if you buy land that’s already contaminated, you can be held liable for that contamination as the new owner — unless you document the existing conditions before or shortly after you take ownership. Do that, and you’re exempt from liability for what was already there.
You don’t file one on clean land. There’d be nothing to be exempted from.
The form asks the question directly: is the property at which the BEA was conducted a “facility” as defined by Section 20101(1)(s)? “Facility” is a legal term here — it means a hazardous substance is present above the generic residential cleanup criteria.
The University’s answer, on both filings: Yes.12
That covers all three parcels. All 138 acres.
What’s in the soil
On the 20-acre parcel at 10221 Textile Road, sampled October 4, 2024, the tables show metals across the site. Mercury at 91 µg/kg against a volatilization-to-indoor-air criterion of 50. Lead at 24,000 µg/kg in a berm sample. Arsenic at 6,400. Silver, selenium, chromium, barium, copper and zinc all present. PCBs at 3,000 µg/kg in one sample. In soil gas, tert-Butylbenzene at 19 µg/m³ against a residential screening level of 14.1
On the 118 acres at 10455 and 10635, the report is tighter. Three contaminants exceed generic residential criteria: arsenic at up to 7,100 µg/kg, chromium at up to 10,000 across seven sample locations, and silver at 160 at a single point.2
I want to be careful with these numbers, because this is exactly the sort of thing that gets overstated.
Arsenic and chromium are commonly elevated in Michigan soils, and the residential criteria are strict by design. The first report uses a specific notation for concentrations that exceed a criterion but stay below the statewide default background level — meaning some of what’s flagged may be ordinary for this part of the state. Nobody should be telling you this land is a toxic waste dump. It isn’t.
What it is, legally and factually, is contaminated ground. The University said so itself, twice, in writing, to the State of Michigan.
The part I’d pay attention to
The soil gas sampling on the 20-acre parcel was measured against Volatilization to Indoor Air Pathway screening levels.
That’s the pathway where contamination under a building works its way up through the slab and into the air people breathe inside it. It’s the exposure route that becomes relevant precisely when you put a large occupied structure on the land — which is the plan.
The mercury exceedance on that parcel is against the same pathway.
Where this fits the timeline
The dates are worth laying out, because they show the University doing this properly.
- September 30, 2024 — Phase I assessment completed for the 20-acre parcel
- October 4, 2024 — soil and soil gas sampling
- November 5, 2024 — the University takes ownership
- January 13, 2025 — first BEA filed with EGLE
- March 11, 2026 — BEA report completed for the Norfolk parcels
- March 18, 2026 — purchase closes
- March 26, 2026 — second BEA filed
Assessment before purchase, filing within the statutory window, both times. That’s how the process is meant to work and I’ll say so plainly.
Which makes the silence harder to explain, not easier.
What was said instead
In December 2024 — eleven months before the first BEA, and two months after the sampling — the University’s application to the Michigan Strategic Fund was asked whether the investment would result in remediation of environmental contamination. The answer: a Phase I had identified recognized environmental conditions, and a Phase II was therefore planned.3
True as far as it goes. Also the only public mention of environmental conditions on this land that I’m aware of, anywhere, in two years.
It doesn’t appear in the project FAQ. It didn’t come up at the September town hall. It wasn’t in the postcard.
And in May 2024 — five months before the sampling — the University signed MEDC’s confidentiality form, whose Exhibit A designates environmental studies related to a Development Project prepared by the Company or its agent
as exempt from disclosure.4
These came out anyway, because EGLE holds them and EGLE answers records requests.
The document nobody has asked for
Owning a Part 201 facility comes with obligations. Under Section 20107a, an owner has to exercise due care — preventing exposure, stopping contamination from spreading, and not making it worse. Documentation of those evaluations has to be available to EGLE within eight months of taking ownership.
For the 20-acre parcel, that window closed around July 2025.
That document would describe how the University intends to manage contamination it already knows is there, on land it intends to build on. I’ve requested it. Either it exists and says something, or it doesn’t and the deadline passed.
What still needs answering
- Why has the community never been told these parcels are Part 201 facilities?
- Will the University publish the due care documentation filed under Section 20107a?
- What vapor intrusion mitigation is designed into the buildings, given the soil gas results?
- How will contaminated soil disturbed during construction be managed, and where does it go?
- What stormwater controls will keep disturbed soil out of the Huron River during two to three years of construction?
Every one of those has an answer sitting in a design document. None is classified.
Sources
- Baseline Environmental Assessment, submittal 81000971-BEA-1, 10221 Textile Road, filed January 13, 2025 (PDF). Prepared by Apex Companies, LLC for the Regents of the University of Michigan. Obtained from EGLE under the Freedom of Information Act.
- Baseline Environmental Assessment, submittal 81000985-BEA-1, 10455 and 10635 Textile Road, filed March 26, 2026 (PDF). Report dated March 11, 2026. Obtained from EGLE under the Freedom of Information Act.
- MEDC memorandum to the Michigan Strategic Fund Board, December 10, 2024. Board packet (PDF)
- MEDC confidentiality agreement, May 24, 2024 (PDF) — see Exhibit A
I’m not an environmental professional. I’ve read these documents carefully and reported what they say, and I’ve linked both in full so you can check me. If you work in this field and I’ve misread something, tell me and I’ll fix it and say that I did.
Has this been shared with our Township Supervisor so comparative tests can be performed debunking UM’s contaminated soil claim?
Hi Laura – this has been shared with the township, though I’m not exactly sure what you’re speaking about debunking. These are baseline analysis of the soil at the Textile road site. These assessments were legally required as part of the purchase of those parcels, and conducted by a third party.