There’s a Chicago dry cleaner celebrating 100 years in business. They claim they used to dry clean suits for Al Capone, Bugsy Siegel, Lucky Luciano, Meyer Lansky, and a lot of celebrities, all of whom had reputations for being snappy dressers. Truth be told, I have always admired snappy dressers, though I’ve seldom emulated that trait.

That dry cleaner’s “glory days” are long gone. For the past 50 years or so it has been a drop-off facility with the cleaning done well off-site at a centralized location. Now, the drop-off is for sale and the other day Lucy, the loan officer at a local CDC, called me to discuss a 504 loan to a potential buyer. As they say, here’s what went down:

LUCY. The usual laundry list of items I need to get is right there on page 320 of SOP 50 10 7.1. It says I need to provide an  …“Environmental analysis in accordance with Section A, Ch. 5, Para. E, Environmental Policies and Procedures, if applicable.”   

ME. Of course, I’ve had to read Section A, Chapter 5 before I could decide if it is applicable. And lo: Way down there, on page 88, it says “ … for any Property with on-site dry cleaning facilities, whether currently in operation or operated historically at the site, that uses, has used, or likely used chlorinated and/or petroleum-based solvents, a Phase I Environmental Assessment followed by a Phase II Environmental Assessment is required.”

LUCY. “….has used or likely used …” Richard, I can’t resist checking out the dry cleaner’s practices from way back when … Hello Mr. Capone? Remember that dry cleaner you used in 1924? Did they use chlorinated and/or petroleum-based solvents?

ME. Very funny, Lucy. Scarface was a good student at his parochial school. But he launched his career at the age of 14 after he was expelled for hitting a teacher in the face. So he probably couldn’t have answered your question. The teacher probably couldn’t have either.

Today we know that even a Phase I Assessment will not tell us what we need to know. We need an investigation that addresses soil, groundwater, and soil vapor. And that’s just what a Phase II Environmental Assessment will do. And so SBA requires Phases I and II. Better go tell your potential applicant to get ready!

Richard Jeffrey, Senior Associate
CDC/504 Program