CARA-1 Sites: The Practical Risk Checklist for Downtown Infill

Downtown infill development often means building on previously developed land. In Washington and Oregon, many urban sites fall under CARA-1 (Current and Reasonably Anticipated Future Use) designation, triggering specific environmental assessment requirements that can derail schedules if not handled early.

What Is CARA-1?

CARA-1 sites are those where current or reasonably anticipated future use involves direct human contact with soil or groundwater. This includes:

• Residential development
• Schools and childcare facilities
• Parks and playgrounds
• Commercial uses with outdoor dining or similar exposure
• Mixed-use with residential components

The designation triggers more stringent cleanup standards than industrial or commercial-only sites, even for the same contamination levels.

The Risk Checklist

Use this checklist during site acquisition and early design phases:

1. Historical Use Research

• Review Sanborn maps and historical aerials
• Identify previous uses: gas stations, dry cleaners, auto repair, manufacturing
• Document timeline of property use changes
• Check state environmental databases (EIM, ECY, DEQ)

Red Flags: Gas stations, dry cleaners, and auto repair facilities are high-probability contamination sources. But don't ignore industrial uses—manufacturing operations often leave heavy metals or VOCs.

2. Adjacent Property Screening

• Review environmental status of adjacent properties
• Check for known releases or cleanup sites within 500 feet
• Identify upgradient groundwater contamination sources
• Document vapor intrusion pathways from adjacent sites

Risk: Contamination migrating from adjacent properties can trigger assessment requirements even if your site's history is clean.

3. Phase I ESA Review

• Ensure Phase I is less than 180 days old at permit submittal
• Verify environmental professional qualifications (EPA AAI standard)
• Check for recognized environmental conditions (RECs)
• Review historical use conclusions and data gaps

Timing Issue: Many jurisdictions require Phase I ESAs to be current (within 180 days) at time of permit application. If you completed one during acquisition, you may need to refresh it.

4. Phase II Assessment Triggers

Phase II (soil/groundwater sampling) is typically required if:

• RECs identified in Phase I
• Historical use suggests contamination potential
• Adjacent site contamination may migrate
• Regulatory agency requires it based on use pattern

Budget Impact: Phase II can cost $10,000–$50,000+ depending on scope. Delays in completing Phase II can hold up permit issuance.

5. Cleanup Plan and Timeline

If contamination is found:

• Develop cleanup plan (interim action or full cleanup)
• Submit to Ecology/DEQ for approval
• Budget for cleanup implementation
• Factor in regulatory review timeline (often 90+ days)

Schedule Risk: Cleanup plan review and implementation can add 6–12 months to project timeline if not anticipated early.

6. Vapor Intrusion Assessment

For CARA-1 sites, vapor intrusion (VI) assessment is mandatory if:

• VOCs detected in soil or groundwater
• Adjacent sites have known VI concerns
• Building includes occupied spaces below grade

Common Oversight: Developers sometimes focus on soil contamination but miss VI requirements until building design is locked. VI mitigation can require significant design changes.

7. Institutional Controls

If cleanup leaves contamination in place (common for urban sites):

• Environmental covenant restrictions
• Activity and use limitations (AULs)
• Land use restrictions on future modifications
• Ongoing monitoring or maintenance requirements

Future Implications: Institutional controls can limit future site modifications or redevelopment. Factor this into long-term property value assessments.

Common Pitfalls

1. Waiting too long: Environmental assessment should happen during due diligence, not after permit application.

2. Underestimating regulatory review time: Ecology/DEQ review of cleanup plans typically takes 60–90 days minimum.

3. Assuming "no further action" means done: Even after cleanup, institutional controls and monitoring may be required.

4. Ignoring vapor intrusion: VI assessment is increasingly required and can require design modifications late in the process.

Municipal Requirements Vary

Not all jurisdictions handle CARA-1 the same way:

• Seattle: Has specific Director's Rules on CARA-1 assessment
• Portland: DEQ requirements, but city may have additional conditions
• Smaller cities: May rely entirely on state standards or have local variations

Early engagement with both state environmental agencies and local building departments is critical.

The Bottom Line

CARA-1 designation doesn't mean your project is doomed, but it does mean environmental assessment and potential cleanup must be factored into project schedule and budget from the start. The biggest risk is discovering contamination requirements after permit application, when design changes and regulatory review timelines become critical path items.

For project-specific CARA-1 risk assessment, contact us through our project intake form.