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Environmental Management

The "Fort Worth Method"

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"Fort Worth Method" Documents

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Cowtown Inn Demolition

Key Dates in "Fort Worth Method"

Cowtown Inn Open Houses

Phase 1 Demolition

The U.S. Environmental Protection Agency announced in July 2004 that before determining whether to allow Fort Worth’s proposal for an alternative method for the management of asbestos containing materials during demolition to proceed, it would use a location other than Fort Worth to test an alternative method for asbestos removal. The newer EPA method was tested in the spring of 2006 at a remote location at Fort Chaffee, Arkansas, chosen to assure no public exposure. More information on the Fort Chaffee project is available on the EPA web site at

Background and Goals of the Fort Worth Method

In 1998, the City of Fort Worth stepped up its war on urban blight through special emphasis on property redevelopment and sustainable communities issues. The City of Fort Worth Code Compliance Department received direction from the City Council to demolish substandard commercial and multi-family residential structures, which specified approximately 50 "facilities" as defined by the asbestos regulations of the National Emission Standards for Hazardous Air Pollutants (Asbestos NESHAP). These commercial structures included bowling alleys, bars and taverns, grocery stores, automotive service stations/stores, strip centers, churches, and shopping malls.

The Universal Problem of Substandard Buildings

The problem of substandard abandoned structures is not unique to Fort Worth, which currently has identified over 3,250 such buildings. The problem is universal among America’s cities. Although there is no national census of vacant and abandoned buildings, researchers at Ohio's Miami University and the University of South Carolina estimate that an average of 18 percent of urban structures sit unused, based on a survey of 100 cities.[1] Between 1996 and 2001, Detroit demolished 18,200 condemned buildings at a cost of $66 million, with an estimated 10,000 substandard structures still remaining. [2] In 1982, it cost that city an average $3,403 to demolish an abandoned building, but by 2002, the average demolition cost had increased to $7,500. Detroit Mayor Kwame Kilpatrick has recently stated that complying with Environmental Protection Agency asbestos NESHAP regulations will increase the average cost to about $10,000.[3] The number of vacant and abandoned buildings that Detroit has been financially able to demolish has steadily decreased since 2001. During fiscal year 2001-2002, that city demolished more than 2,500 such buildings. That number decreased to 785 during 2002-2003, and in fiscal year 2003-2004, which ends June 30, only 684 buildings have been demolished, although 1,300 had been projected.[4] The number of abandoned buildings demolished in 2003 was a 22 year low.[5] Philadelphia, Pennsylvania, reportedly is home to at least 25,000 abandoned buildings, although some city officials think there are twice that many.[6] Baltimore reportedly has an estimated 15,000 abandoned buildings.[7] 

According to a May 2004 article in PM Engineer, abandoned properties tend to be small. “Sixty percent of vacant buildings are between 1,000 and 5,000 square feet, and 89% of all idle structures claim less than a 10,000-sq.-ft. footprint. These buildings are older—87% of them were erected prior to 1969. Ninety percent of them are one- or two-story structures. They all offer easy access for juveniles, vandals, and the homeless.”[8] 

While many vacant and abandoned buildings have the potential to be rehabilitated and reoccupied, a great many have lived out their usefulness and need to be demolished.

The cost of demolishing abandoned, substandard structures is high. The asbestos removal alone can account for 50% to 90% of total demolition costs in Fort Worth. Illustrative of this is a City of Fort Worth brownfields redevelopment. In 2003 the City of Fort Worth Environmental Management Department began cleanup of the Evans and Rosedale Business and Cultural District, a 25-acre City-owned brownfields redevelopment project approximately one mile southeast of downtown. Regulated Asbestos Containing Materials (RACM) were removed from 12 substandard commercial and residential[9] structures prior to their demolition. Asbestos removal cost the City $64,441 or 57% of the total demolition cost of $113,571. The single-family residence at 908 Missouri alone required $10,535 in asbestos removal costs, which came to 76% of the total demolition costs of $13,880.

Cities simply do not have the fiscal resources to demolish all of these structures in a timely manner. The City of Fort Worth Code Compliance Department, for example, has budgeted approximately $650,000 in fiscal year 2004 for demolition of substandard structures. The costs associated with asbestos removal and demolition of a site as large as the Cowtown Inn alone are at least twice this annual budget. The cost of not demolishing the structures is even higher – in terms of fire hazards, criminal activity, propagation of disease vectors, safety and health hazards for children, lowered property values, and continued degradation of neighborhoods.

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Neighborhood Impacts of Abandoned Buildings

In his study examining crime in abandoned buildings in Austin, Texas, William Spelman, Associate Professor of Public Affairs at the University of Texas, concluded that 41 percent of abandoned buildings could be entered without use of force. Of these open buildings, 83 percent showed evidence of illegal use by prostitutes, drug dealers, property criminals, and others. Crime rates on blocks with open abandoned buildings were twice as high as rates on matched blocks without open buildings.[10] 

A 2001 Temple University Study of Philadelphia, Pennsylvania, found that houses within 150 feet of a vacant or abandoned property experienced a net loss of value of $7,627. Those within 150 to 300 feet depreciated by $6,819 and those within 300 to 450 feet depreciated by $3,542.[11] 

In his study, "Abandoned Buildings: Models for Legislative & Enforcement Reform," Mark Setterfield, Associate Professor of Economics at Trinity College in Hartford, Connecticut, states,

It would take very little to convince a visitor to, much less a resident of, any of America's cities that there exists an abandoned building problem. Even the most cursory glance at the central urban environs of cities such as Hartford and New Britain reveals a preponderance of burned out or boarded up buildings and vacant lots. Meanwhile, residents of neighborhoods blighted by abandoned buildings complain of a variety of economic and social problems connected with commercial and residential structures that have fallen into disuse and disrepair. As the examples of Hartford and New Britain attest, these problems are by no means confined to larger metropolitan centers; the phenomenon of the small city with “big city problems”’ is very much a part of the urban landscape of contemporary America.[12] 

In addition to wasted resources, lost tax revenues and declining property values, Professor Setterfield cites the negative effects on the community as one of the chief concerns associated with abandoned buildings. He states, “Abandoned buildings can also have an insidious effect on the social fabric of a community, by encouraging ‘social atomization’ — a process which isolates the individual (or individual family) within a community, weakening ties to others and, hence, the sense of collectivity which is the hallmark of any thriving community….abandoned buildings may foster a sense of despondency and resignation that detracts from the vitality of a community….buildings which fall into disrepair and remain dilapidated are interpreted as a signal that no one cares.”

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Arson and Abandoned Buildings

Abandoned buildings pose a major fire hazard that endangers the lives of both citizens and firefighters. The United States Fire Administration reports that over 12,000 fires in vacant structures are reported each year in the United States, resulting in $73 million in property damage annually. The administration also reports that more than 70% of fires in vacant or abandoned buildings are incendiary or suspicious.[13] Following the 1999 death of six Worcester, Massachusetts, firefighters while fighting a fire at a structure that had been abandoned for a decade, the administration concluded that “abandoned buildings are a serious threat to firefighters and fire departments….”[14] In that fire, firefighters were induced “to take the offensive because a homeless couple was known to use it periodically for shelter. When some of the firemen became disoriented inside the burning building, others rushed to their aid.”[15]

In 1987, a Detroit firefighter was killed when a fire in an abandoned warehouse flashed over. When the fire spread to other structures, two more firefighters died when a wall collapsed as they tried to limit the fire's growth. The fire department had previously been called to numerous small fires in the building, which had been started by vagrants for warmth.[16] In 2003, a homeless man and two homeless women were smoking crack in an abandoned building in Yonkers, New York, and started a fire for warmth. The fire spread through a dozen buildings, killing five members of the same family and leaving another 200 homeless.[17]  In October 2003 a homeless man and woman died when a three-story vacant building near the University of Cincinnati caught fire in what was considered a suspicious fire.[18]

In Fort Worth, firefighters have battled three major fires of a suspicious/incendiary nature at Texas Tanning since February 2002, most recently on November 10, 2003. The city has subsequently demolished three burned buildings at the site. The facility, a century-old abandoned tannery located next to a predominantly Hispanic residential neighborhood in north central Fort Worth, has abandoned drums containing solvents, acids, ethers, poisons (including 21 drums of lead acetate), and petroleum-based products, along with open pits containing hexavalent chromium waste. There are also large amounts of other combustible materials at the site, creating a huge fire load. While the EPA and the Texas Commission on Environmental Quality each have indicated their agencies may perform a removal action at this site, it will undoubtedly fall to the city to complete remediation of the site including the removal of asbestos containing materials from the remaining structures.

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Development of “Fort Worth Method”

While cities wait until sufficient funding can be raised to demolish these substandard structures, they continue to deteriorate and serve as the cancer which destroys once vibrant neighborhoods. At some point in the future, these structures become “in danger of imminent collapse” and then may be demolished with asbestos in situ pursuant to the Asbestos NESHAP.

In 1999, seeking a way to proactively address the problem of decaying central city areas in a manner that was both protective of human health and the environment and cost effective for taxpayers, the City of Fort Worth Department of Environmental Management filed an application with the United States Environmental Protection Agency (EPA) for regulatory flexibility under Project XL. The City of Fort Worth's XL project was entitled "Asbestos Management in the Demolition of Substandard Structures as a Nuisance Abatement," which became known as the “Fort Worth Method.” Project XL stands for “eXcellence and Leadership.” The program was developed by the EPA as a way to encourage industry and state and local governments to develop better or more cost-effective ways of achieving protection of the environment and public health, and was coordinated by the Office of Policy, Economics, and Innovation.

As defined, the “Fort Worth Method” is not for everyone. This tool, which is a work practice modeled after the Asbestos NESHAP standard for buildings in danger of imminent collapse but much more restrictive, has been developed to allow only local governments the opportunity to demolish substandard structures that are either not owned by the municipality or that have been assigned to the municipality through property tax foreclosure.[19] It is intended for use only by local governments with authority to take possession, control, and demolish substandard buildings as a nuisance abatement. These structures have been ordered, through administrative or judicial processes, to be brought up to code or demolished, and their owners have failed to comply. Although substandard, the buildings are not yet in danger of imminent collapse but will likely degrade to that point by the time the municipality has the money to perform the asbestos abatement and demolition.

Although the cost of disposal is slightly higher using the “Fort Worth Method” to demolish substandard buildings, the overall cost savings are expected to be 40%-60% per structure once the project moves into Phase 3. This method will allow the City of Fort Worth to address more abandoned, substandard structures by freeing up funds, while maintaining the protection of the health of Fort Worth’s residents by controlling emissions. Eventually, the method may be able to be duplicated by other cities across the country.

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Buildings in Danger of Imminent Collapse

For facilities where RACM [20] is not removed prior to demolition because the facility is being demolished “under an order of a state or local government agency, issued because the facility is structurally unsound and in danger of imminent collapse,”[21] the Asbestos NESHAP dictates that the portion of the facility that contains RACM must be kept adequately wet during the wrecking operation.[22] Asbestos-containing waste material [23] must be kept wet at all times after demolition and during handling and loading for transport to a disposal site.[24] No other engineering controls are required. No air, water, or soil monitoring is required. No demolition practices or wetting practices are specified. There are no limitations on the size of the buildings that may be demolished, and there are no site security provisions. Leaving demolition debris on the ground overnight is not prohibited. Cleanup plans in the event of a release of asbestos to the environment are not required, and there are no site closure provisions. Asbestos-containing waste materials do not have to be sealed in leak-tight containers or wrapping, but may be transported and disposed of in bulk.[25] Vehicles used to transport asbestos-containing waste material must be marked during the loading and unloading of waste so that the signs are visible.[26] The markings must be displayed in such a manner and location that a person can easily read the legend, they must conform to the size, font, spacing, and other visibility requirements of 29 CFR 1910.145(d)(4) and 40 CFR 61.149(d)(1), and must state: DANGER. ASBESTOS DUST HAZARD. CANCER AND LUNG DISEASE HAZARD. Authorized Personnel Only.

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Application of The “Fort Worth Method”

The “Fort Worth Method,” simply stated, applies the EPA regulation for demolition of buildings in danger of imminent collapse[27] to a structure:

  1. that has been declared to be substandard by a local governmental agency (in Fort Worth this is done through an administrative process via the Building Standards Commission, or through a judicial process), and ordered brought up to code or demolished;
  2. that has not been brought up to code or demolished by the owner pursuant to such order;
  3. that is not yet in danger of imminent collapse; and
  4. that will be demolished by the local governmental agency as a nuisance.

The “Fort Worth Method,” however, is much more restrictive than the Asbestos NESHAP requirements for buildings in danger of imminent collapse. Under the “Fort Worth Method,” certain asbestos containing materials (ACM) would be removed under full containment in accordance with federal and state law prior to demolition, and all other ACM would be left in place for demolition. The “Fort Worth Method” requires removal of the following ACM prior to demolition:

  1. Spray-on fireproofing in quantities greater than 160 square feet or 35 cubic feet (off facility components where the length or area could not be measured previously);
  2. Thermal System Insulation (TSI) [28] in quantities greater than 260 linear feet on pipes, 160 square feet on other facility components or 35 cubic feet off facility components where the length or area could not be measured previously;
  3. Transite® material in quantities greater than 20% coverage for every 1 linear foot of building exterior (e.g., 1 LF of a 10’ high building could not contain greater than 2 SF of Transite®); and
  4. Friable or Category II Non-Friable material that contains asbestos (greater than 1% as determined by Polarized Light Microscopy) other than chrysotile and that is non-porous in nature.
  5. Additionally, Vermiculite Attic Insulation (VAI) must be removed prior to demolition.

The reasoning behind removal of the ACM identified above prior to demolition is as follows:

  • Based on its friable nature and attachment to structural members, it is felt that spray-on fireproofing cannot be adequately wetted and safely left in place during demolition. Spray-on fireproofing is rarely encountered by the City of Fort Worth during asbestos assessments of buildings.
  • Thermal System Insulation (TSI) usually contains amosite which is hydrophobic (lacking affinity for water) and thus cannot readily be wetted. It is felt that TSI above the NESHAP threshold could not safely be left in place for demolition. TSI is routinely encountered by Fort Worth, primarily in the form of hard pack fittings that fall below the identified NESHAP threshold levels, and thus are not required to be removed prior to demolition under the NESHAP.
  • Transite material is typically encountered either in full exterior coverage or in limited coverage. With limited coverage it is felt the material is less likely to become RACM and again would then not be regulated under the current NESHAP.
  • Material that contains asbestos other than chrysotile and is non-porous in nature would be hydrophobic (lacking affinity for water), and it is felt that this material could not be safely left in place during demolition.
  • Vermiculite attic insulation is not a material currently regulated under the Asbestos NESHAP. Before it closed in 1990, a mine near Libby, Montana provided much of the world’s supply of vermiculite. The mine had a natural deposit of asbestos which resulted in the vermiculite being contaminated with asbestos. Attic insulation produced using vermiculite ore, particularly ore that originated from the Libby mine, may contain asbestos fibers. Today, vermiculite is mined at three U.S. facilities and in other countries which have low levels of contamination in the finished material.[29] Currently, EPA and the Agency for Toxic Substances and Disease Registry (ATSDR) are concerned with specific technical issues involving vermiculite sampling that can complicate testing for the presence of asbestos fibers and interpreting the risk from exposure. Until testing techniques are refined that produce more definitive and accurate test results, the City of Fort Worth is proposing that vermiculite attic insulation be removed prior to a demolition using the "Fort Worth Method." This is more restrictive than the Asbestos NESHAP requirements for a traditional NESHAP demolition.

Structures suitable for the “Fort Worth Method” of demolition will range from one to three stories, with a maximum height of 35 feet. This is more restrictive than the Asbestos NESHAP requirement for the demolition of buildings in danger of imminent collapse, which does not set a height limit. Demolitions will be performed by heavy equipment only. No explosives will be used to explode or implode structures, and burning will not be utilized to demolish structures. There are numerous other safeguards built into Phase 2 of the "Fort Worth Method" that are not required under the Asbestos NESHAP regulations. There must be a thorough site assessment before a site is chosen for demolition, and the EPA and Texas Department of Health must concur on the choice of site. The city must go through a stakeholder process, and give the community the opportunity to comment on the proposal.

The site must be surveryed prior to demoliton to determine presence of hazardous wastes, industrial wastes, lighting, and other materials that should be removed before demolition. This includes fluorescent light ballasts and light tubes, high intensity discharge (HID) lamps, cleaning and maintenance products, and air conditioning system coolant. Authority to stop work for violations of the Method documents, worker safety issues, visible emissions, and inadequate wetting is provided. No direct impact of demolition debris by heavy equipment tracks for waste consolidation is allowed. No demolition debris may be left on the ground over night. The entrances to and perimeter of each site must contain signs that state: DANGER - ASBESTOS - CANCER AND LUNG DISEASE HAZARD - AUTHORIZED PERSONNEL ONLY. After-hours security will be provided for when warranted. There must be a clean up plan prepared prior to start of implementation, and implemented should a significant environmental release occur. The site graded and stabilized following completion of demolition, and potentially impacted soils must be removed and disposed of along with the demolition debris. A soils clean up standard of 0.08% is provided for, which is more protective than required by Texas law for residential properties (0.15%).

[1]National Center for Policy Analysis, Cities Begin Considering the Risk of Vacant Buildings. Retrieved March 22, 2004, from the NCPA web site:

[2]Detroit Free Press, City pushes for revitalization: Even more demolitions needed for better quality neighborhoods (August 27, 2001). Retrieved March 22, 2004, from the Detroit Free Press web site:

[3]Detroit Free Press, DEMOLITION SLOWDOWN: Dilapidated buildings standing tall in Detroit (June 3, 2004). Retrieved June 9, 2004, from the Detroit Free Press web site:

[4]The Detroit News, Detroit demolitions decrease. Retrieved June 9, 2004, from the Detroit News web site:

[5]Detroit Free Press, DEMOLITION SLOWDOWN: Dilapidated buildings standing tall in Detroit (June 3, 2004). Retrieved June 9, 2004, from the Detroit Free Press web site:

[6]American Planning Association, Dateline September 4, 2000. Retrieved March 22, 2004, from the APA web site:

[7]CBS News – 48 Hours. What to do with Abandoned Buildings? (May 21, 2001). Retrieved March 22, 2004, from the CBS web site:

[8]PM Engineer, Fire Protection: A Not-So-Innocent Danger, by Mark Bromann (May 2004). Retrieved June 10, 2004, from the PM Engineer web site:,2732,124163,00.html

[9]These residential structures did not fall outside of the definition of facility as per the Asbestos NESHAP Clarification of Intent, 60 FedReg 145.

[10]Spelman, “William, Abandoned Buildings: Magnets for Crime?” Journal of Criminal Justice, 1993.

[11]Temple University, Blight Free Philadelphia: A Public-Private Strategy to Create and Enhance Neighborhood Value (2001)

[12]Trinity College, Abandoned Buildings: Models for Legislative & Enforcement Reform, Mark Setterfield·Associate Professor of Economics. Retrieved June 10, 2004. From the Trinity College web site:

[13] American Re, New Tool Ready To Combat Arson; Vacant & Abandoned Buildings Targeted. Retrieved March 22, 2004, from the AmRe web site:

[14]U.S. Fire Administration, Technical Reports: FEMA Review Deadly 1999 Worcester, Mass., Provides Insight Into Lessons Learned. Retrieved March 22, 2004, from the U.S.F.A. web site:

[15]PM Engineer, Fire Protection: A Not-So-Innocent Danger, by Mark Bromann (May 2004). Retrieved June 10, 2004, from the PM Engineer web site:,2732,124163,00.html

[16]Insurance Committee for Arson Control, Fires in Abandoned Buildings Continue to Plague Firefighters, Citizens. Retrieved June 10, 2004, from the ICAC web site:

[17] Last Defendant Pleads Guilty in Yonkers Fire, June 4, 2004. Retrieved June 10, 2004 from the web site:

[18]Cincinnati Enquirer, Two die in suspicious building fire, October 27, 2003. Retrieved June 10, 2004 from the Cincinnati Enquirer web site:

[19]It should be stressed that the Fort Worth Method is not intended as a means for local governments to demolish public facilities that they own but fail to maintain.

[20]Regulated asbestos-containing material (RACM) means friable asbestos material; category I non-friable asbestos-containing material that that has become friable; category I non-friable asbestos-containing material that will be or has been subjected to sanding, grinding, cutting or abrading; or Category II non-friable asbestos-containing material that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by forces expected to act on the material in the course of demolition or renovation operations regulated by the Asbestos NESHAP (40 CFR §61.141).

[21]40 CFR §61.145(a)(3)

[22]40 CFR §61.145 (c)(9).

[23]As applied to demolition and renovations operations, the term “asbestos-containing waste material” includes regulated asbestos-containing material waste and materials contaminated with asbestos including disposable equipment and clothing (40 CFR §61.141).

[24]40 CFR §61.150 (a)(3).


[26]40 CFR §61.150 (c).

[27]40 CFR §61.145 (a)(3)

[28]Thermal System Insulation (TSI) is defined as “Asbestos-containing material applied to pipes, fittings, boilers, breeching, tanks, ducts, or other interior structural components to prevent heat loss or gain or water condensation.” U.S. Environmental Protection Agency, Terms of Environment. Retrieved March 23, 2004 from the EPA web site:

[29]U.S. Environmental Protection Agency, Current Best Practices for Vermiculite Attic Insulation - May 2003. Retrieved March 31, 2004, from the EPA web site:

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