ACHIEVING
ENVIRONMENTAL JUSTICE
      - A DEPARTMENTAL STRATEGY --
     U.S. Department of Housing and Urban Development






             March 24, 1995      j

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                U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
                             THE SECRETARY
                          WASHINGTON. D.C. 20410-0001       i

                           March 24, 1995         '
 Carol M. Browner, Administrator                 i
 U.S. Environmental Protection Agency
 401 M Street, S.W.                               i
 West Tower, Room A101
 Washington, D.C.  20460

 Dear Administrator Browner:


      The President's Executive Order 12898,  "Federal Actions to
      ss Environmental Justice  in Minority Populations and Low-
        Populations," signed February 11, 1994., requires the
 Department of Housing and Urban Development  (HUD) , along with

     addrl;^ ?%*"?**' tO dSVel°P a strategy which identifies
     addresses the disproportionate and adverse impacts of
    inwT11    Y IfSafe and. ^suitable living environments faced
   r-i°n    ?6 2nd minority Populations.  The Executive Order
 directs us to demonstrate how we intend to integrate

               JUStice concerns  into  HUD policies,, programs,  and
                          tO define a COnmon sense! approach to our
                  -°nlY caPtures several of the Department's
                   V?^ "" emP°werment zones,  childhood lead
           brownf ields cleanup, and colonias development — but
also advances  the  fundamental philosophy of HUD ' s cSmmi tment t o
communities, to  the  housing needs of its poorest  and most

Indn?oa?oL??PU"£ti°nS'  t0 fair h°using a^d °Pen  ^oSsTnf markets,
and to locally-ariven economic development.   At HUD,  we believe
rn^i00^"1^  t0 and ensurin9 environmental justice not on?y
complements the  Department's mission but also the current efforts
underway to downsize and "reinvent"  the agency.   \ Current eff°^ts


     Ir,am Pleasea  to submit to you the  Department :Of  Housing and
                                                               nd
                               Sincerely,

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                         TABLE OP CONTENTS




 A Message from the Secretary                   !



 I.    Environmental Justice:  Priority Initiatives



      A.    Creating Healthy,  Viable  Environments through
           Empowerment  Zones  and  Enterprise Communities



      B.    Fighting Childhood Lead Poisoning



    .  C.    Revitalizing Central Cities through Brownfields
           Redevelopment



     D.    Improving Fundamental Living Conditions in the Rural
          Colonias



II.  Environmental Justice: Options for Implementation

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                    A. Message from the Secretary
 lives'^? £??a?omenVf H^sing and Urban  Development  touches the
 dav   mm ii^      of people and thousands of communities  every
 with -5SJJ i?S  £rovlde the nation's  families and communities
 credi?  225 J% SmeS'  renta*  assistance<  Access to mortgage
 credit, expanded homeownership opportunities, homeless
 assistance, and  family and social  services, and acts  as a
 catalyst for community development, economic growth,  and job
            JrSrJ?iany Americans'  especially low-income  and minority

                      "                             °f life and
     _ Ensuring environmental justice is a natural goal in HUD's
 mission and priorities.

      We, at HUD, are committed to creating communities of
              1How€Ter'.£fal opportunity - economic,  educational,
 ™          less tangible for those Americans who are trapped in
 run-down,  isolated public housing which is contaminated with
 or IdnfrJinr ?SS- famijies:,who live_in inner-city neighborhoods on
 «nh^?C?ntK VndUStrial waste sites,  and for those  families who
 subsist in border communities that lack basic infrastructure
 ?^Stng'uanQ sanitation-  HUD is helping to change those
 intolerable conditions — to change the way our society thinks
 about _ urban policy and environmental issues.   Three basic
 principles arive HUD's environmental justice effort.

     HUD will promote sound environmental considerations in
     community development and housiny policies that,  at the same
     time,  wan preserve housing affordability and encouraae
     rural and urban economic growth and private sector
     investment.

   _  HUD is  able to address environmental ineguil-ies in  two
primary capacities.   First,  HUD helps provide  resources  to
Americans  urban communities,  an investment which has become
increasingly urgent over the past  several  decades as we  have
witnessed  capital  flight — human  and financial  —  from  our
central  cities    The major shift in  the nation's  industrial base
from heavy manufacturing to other  forms of production has left
behind  "brownfields"  —  obsolete,  contaminated industrial sites -
- that  few want  to  develop.   Such  lost  land use  opportunities
weaken  the economic  base of  the nation's metropolitan
communities .

     Meanwhile,  poor people,  and especially poor minority
Americans,  have  become increasingly  concentrated  in central
cities and other isolated urban communities.  Where industry has
stayed in the cities, poor or minority  neighborhoods have
literally become dumping grounds for industrial waste.   All of

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as
metropolitan communities.  HUD




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                  ma   ardt
  socially from the larael n™™,  "olatfd b°th physically and

  Public and IndiaS houIJng'sCJd'L^fe^wi?/?10^6 Sh
  source of pride to the rnmSim?i-,,    f   '^ well-designed, and a
  attract violent crime   ST?h ^' ^ rundown high-rises that









 environments  fo? raising a ^i^5515^  homes  offer healthy

      forward iri                      ""    n mind as  «•
of environmental  p?SbleS thaj bef??!  °S* n0t  rePrese"t the range
                                                              in
along the u.s  - nxi     or        ^eveoped con^unities
co^it^ent to                               c
                                    enry G.yfcisneros

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           I.  ENVIRONMENTAL JUSTICE:  PRIORITY INITIATIVES


 Introduction
r-«rt-ii          in the Secretary's message, HUD has proposed to
radically restructure the. way we serve the nation's communities
and low- income families.  HUD is proposing to consolidate 60 of
          Pr°9rams.into three performance-based funds, transform
 nhi               .                                  ,  ransorm
 public housing as  it exists today, and create an entrepreneurial
 government -owned FHA corporation.  If approved by Cong?els  these
 changes will be launched as early as FY 1996.     ^On9ress, tnese

      The proposed  changes will improve the federal role in
 meeting the community development and housing needs of today's
 fooi^S5'  AS-WS reduce the number of HUD programs and increase
 local discretion,   the Department will explore ways in which to
 sustain national standards in local community and housing plans.
 HUD will not sway  from the basic principle that low-income
 families and _ minority families should 'have equal, access to
 nealthy,  thriving living environments.

      As HUD works with Congress,  state,  tribal,  and local
 leaders,  and community-based organizations through this
 legislative and budget cycle,  we will be  sensitive to
 environmental  justice concerns.   The  reinvention ' of HUD will give
 policymakers and the public a  real opportunity to redesign
 federal housing programs and policies from the bottom up to
 better  assist  state,  tribal and  local leaders to meet housing  and
 community development needs.   This complete overhaul  preset?  a
 good  avenue  for environmental  justice considerations  to be
 integrated into the core mission of the  "new"  HUD.

      The  President's  Executive Order  asks  each of  the federal
 agencies  to  identify  several key  initiatives  or  projects that  can
 be undertaken  immediately to address  today's  environmental
 tnS£hSVSS?eS'  *hv  ^Jowins section lays out  HUD's commitment
 to the  creation of  healthy  and viable communities through  the
 il^    ?t'S-EmpOW?rment  Zone Pr°gram< the prevention  of childhood
 lead poisoning,  the "greening" of  urban brownfields, and the
 revitalization  of distressed rural communities along the U S  -
Mexico  border.   in  each  discussion, HUD illustrates the
 environmental issues  confronting the  communities, evaluates our
 e± torts to date, and proposes  a series of  "next steps" to ensure
a thoughtful implementation of these priority initiatives

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          A.  EMPOWERMENT  ZONES AND ENTERPRISE


 The  Problem
              nt  clinton/s Empowerment Zones and Enterprise
              program provides needed resources,  flexibility  and
               -
 res'  the "Powernent  zone program targets
 resources at low-income and minority areas suffering from
      SOrt   WhiCh °ften  includes hi9h  incidence of crime,
                     9orP°rate Capital,  adequate public services
 HUD Response-to-Date
 to heal?hvla?H^?0helP Urban cornmunities which have a commitment
 to nealthy,  viable communities to better meet their environmental
        ' 9nSw iThr°U?h ?he ^ministration's EmpowerSnTzSnT"
                   W°rk closely with ?2 large and small cities (6
      nerinent-ZOneS' 2 8«RPle°«ntal zones,  4 enhanced
      o? 5h^STU^ltieS' and 6° Urban enterprise communities),
      °ft.whlnch ha^e integrated environmental concerns into their
      n^ty plans,b^ Providing federal resources,  relieving federal
    S* ?°n?'  a?d combinin^ federal funding strums to e"£Lre
    ediate local action in reviving distressed communities?
      HUD  has  a  lead role in the Interagency Task Force which
  vinter? the Admini^ration's largeit urban economic
development initiative — the Empowerment Zones and Enterprise
Communities  (EZ/EC)  program.   The Administration's  EZ/E? program

                rVl
thei  rin.                                 co:mmunitie  a
^eJJ residents  to create Dobs and opportunity;  take  effective
action to solve  the difficult and pressing economic   human
community, and physical  development challenges  today; and build
ffr.?   "^  fUtUre throu5h a partnership  of Federal  l?ate  and
local governments  and the private sector in each region
Businesses will  be encouraged to invest in distressed areas
thereby creating jobs, and the entire  region will be  challenged
to make Dobs  throughout  the local labor market accessible to the
residents of  the designated communities.         -essioie to the

     The majority  of  EZ/EC applicants  cited past land
     ^1113^0? andv. lead~based Paint  hazards  in homes as serious
     iments to urban  redevelopment  and included proactive
environmental initiatives  in their  comprehensive community plans.

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                                                                  D

      Among the empowerment  zone and supplemental empowerment
 zones designated by  the  President  on December 21, 1994
 Baltimore, Chicago,  Detroit,  Los Angeles,  and Cleveland all
 included environmental justice  and/or brownfields related
 activities in their  proposals.   Chicago,  for example, has a
 strategy for addressing  the so-called "toxic doughnut" on its
 soutnside.  Los Angeles  proposed an expedited cleanup of
 fcrownfields through  low-cost  loans  and improved procedures and an
 environmental justice program to identify  and disseminate risk
 information to residents.   Cleveland has a model brownfields
 initiative.  Among the Enterprise Communities,  the Minneapolis
 plan calls for the cleanup  of contaminated soil and groundwater
 while Bridgeport,  Pittsburgh, and Tacoma each identified linkages
 to environmental justice concerns.

 Next Steps:  HUD Proposal for Future Strategies

 1.   Promote Environmental Justice  through the  Interagency Task
      Force
^  ^    Intera9ency  Task  Force  is  responsible for assisting all
tne designated empowerment zones and enterprise communities in
implementing their strategic plans.  To date, the Task Force has
made contact with all of the urban  and rural designees.  Initial
visits to all of the  sites will be  completed within the next few
         ° 1iowi£g the first set of  visits, HUD, in conjunction
w                                         ,     ,
witn_EPA and other agencies on the Task Force, will  identify
specific environmental justice issues which will ,need addressing.

     The empowerment zone program,  due to its  convergence of
tederal  assistance,  provides the perfect platform  for
comprehensively  addressing on-going local and  intergovernmental
et torts  in  reducing lead hazards,  restoring brownfields, treating
obsolescent  energy and water systems and other environmental
etforts.  The  empowerment zone program also provides a prime
opportunity  for  federal agencies to work in coordination, with
increased flexibility,  in initiating new efforts to resolve
complex  environmental  issues that  require multiple agency
involvements,  such as  Energy,  Defense,  and  EPA.

     Again,  the  Task Force will identify the range of
environmental  issues to be addressed in these communities.   Where
innovative interagency collaborations  in dealing with
environmental  justice  issues are successful, the Task Force will
be eager to  replicate  and build upon those model efforts in other
communities.                                  -  ;           ^uiiei

2.    Promote Environmental Justice  vrith Non-Designees

     The Administration is committed to  providing assistance to
communities which  applied for  the empowerment zone or enterprise
community designation,  but which were not selected".  This will

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               asS±Stance as »el1 **  federal  agency
       t5e,J'ask Force  contacts  these  communities, we will
pd     Sre are enviro^ntal  justice issues 'that nied to

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                                                                 8

                    B.  CHILDHQQP ^EAD POISONING
 The Problem
           P°.isoning is the number one health hazard to America'^
           nderthe 3ge °f Six'  Approximately 1.? Sil?io^
                    exP°sed to dangerous levels of lead   Lead
                                            behavioral probJel,

 cdrev-                         '  the Problemontus for
 stock has Jot  b ^ PJ?domina?tly poor areas where the housing
 hazards of ?L5SSn e"ectlvely maintained.  Eliminating the
 Hazards of lead-based paint in the nation's housing is a
 cornerstone of lead poisoning prevention efforts; It must be
             a^Slistic environmental justice concern  not simply
            health,  or environmental issue.       ,
      The Journal's  findings  reinforces  the greater need for
                                                iioa^r
                       other and with
Date8 Laraer Role and Environmental Justice AcooffipliBhments  to
                                                 I

     Although laws governing lead-based paint have been  in
existence since 1971, the Housing Act of 1992 was th! fir"st
comprehensive piece of legislation to regulate the reduction of
lead, hazards in homes built before 1978, the year lead was bam
i
                                       ,            ea  was  am*
in paint.  HUD has taken an active role in thigh ^against lead
       n        followin9 list highlights some of^'f mSjor
                 in ensuring lead-safe homes  in this country!

          to develop lead-based paint guidelines and policies
          applicable to HUD and other Federal housing programs to
          thlir^homJs- families are Protected  from lead haiardl ±n

          to operate a  grant program for  State and aocal
          governments to develop cost-effective methods for
          reducing lead hazards in low-income private housing-

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           to conduct and supervise HUD or interagency lead-based
           paint research;

      •     to conduct demonstrations,  studies,  and standards
           development and promote technology improvements  in
           lead-hazard reduction;  and

      •     to support and design public information and awareness
           initiatives on lead poisoning.

      HUD has been  working  and will continue  to work in earnest to
address the  complicated and sometimes competing  facets of  the
lead  poisoning  problem.  HUD must partner with health advocates,
low-income housing providers,  realtors, the  insurance industry,
environmentalists  and state and local leaders, in order to
achieve the  fine balance between  affordability and childhood
health.

      While the  scope of  the lead  issue stretches  from public to
private housing and  from low-income to middle-income  families,
HUD has made great strides  over the years  to respond  to the lead
problems faced  by  poor and  minority families.  The  following is a
list  of_HUD's accomplishments  to  date in  addressing lead issues
in public  housing  and low-income  and  minority  neighborhoods.

A.    Lead  in Public  Housing

1•    General  Lead  Reduction Activities.  HUD provides public
      housing  agencies  and Indian  Housing Authorities with funds
      to test  and abate lead in  paint  prior to  all public housing
     modernization activities.  At  the  same time, in accordance
      to a  congressional mandate,  PHAs have completed testing for
      lead  hazards 'in  approximately  80 percent  of the nation's
     public housing built before  1978.  HUD has also awarded a
      total of $15 million since FY  1992 to eligible HAs to
      conduct  risk  assessments in  individual housing developments.

2•    Studies  on Lead  Testing in Public Housing. ; HUD has  several
     studies underway  to examine  the  quality of lead testing in
     public housing:

      •  Comprehensive  Review by the Army Corps of Engineers.   HUD
     has  enlisted  the  assistance  of the Army Corps of  Engineers
     to review the quality  of public housing leaid-based paint
     testing done to date.  The Army Corps will retest, a  sampling
     of public housing units for  accuracy.  Final conclusions  and
     recommendations are expected in June 1995.

        Short-Term Analysis with  the  Center for Lead-Safe
     Housing,  While the more comprehensive study is taking
     place, HUD, in conjunction with the Center for Lead  Safe
     Housing, has conducted a short-term analysis of completed

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                                                                 10
      paint  inspections  by 40 public housing authorities   The
      rinal  recommendations were submitted  to HUD at the "end of
      au?d??n  ^94n  ThS recoi^dations served as an important
      guide  to  the  Department,  in advance of the 1994 testina
      deadline, enabling HUD to take immediate remedial actiSns to
      prevent inaccurate inspections in untested public housing
      ^^°pmfnt?  and to reinspect  or correct already completed
      unreliable inspections.

 S.   Lead in Low- Income and Minority Neiffhborhoods

 1*   Lead Hazard Control  m-ant  Program.  Since FY 1992  HUD hsc-
      awarded a total  of  $279 million through 64 grants 'to 56
      state and local  governments to reduce lead hazards in
      private, low-income  housing.  The grant program supports
      such activities  as public  education,  paint inspections and
      risk assessments, low-cost interim controls,  and lead
      abatements of varying levels of completeness.   Grantees have
      the flexibility  to choose  the hazard control  methods that
      work best locally,  provided the work is  done  safely   An
      intensive evaluation is underway to determine the
      effectiveness of local intervention strategies.

 2-    Neighborhood-Based Lead Poisoning Prevent inn  Demonstration
      In FY^1994,  HUD and the Centers for Disease "Control  jointly
      funaea  competitive grants to Chicago,  Illinois and
      Providence,  Rhode Island, to develop comprehensive
      innovative lead poisoning prevention programs in  targeted
      low-income neighborhoods.  Local residents are involved in
      tne planning and implementation of  these local strategies.

 C.    Lead Education Campaign

   _   Although lead  in the environment has many sources, the
 primary  residential source of lead affecting children is  surface
 dust  from lead-based paint.   Young children playing Sn flSor Jo?
 around windows  contaminated with 'leaded dust ari easily po?Soned
 when  they put  fingers, toys,  and other objects which have been
 contaminated with leaded dust  in their mouths.
™          abatement and  hazard reduction of lead-based paint
are costly and time  consuming,  and because as many as 9.9 million
American homes contain lead-based paint and are occupied by
families with children under  the age of 6, lead education is
critical to protecting children from lead poisoning,.  Parents  in
            *"    ^ ^ position to keeP their chilSS safe
    .Young children in deteriorated housing with peeling and
flaking paint are most at risk for lead poisoning.  All too
often,  poor African American and Latino children ar«=> livino in
such deteriorated dwellings, and they are therefore

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disproportionately affected by lead-based paint! poisoning.
                                                               11
                   ,          messages  that parents need to
i      ora0"  ^ ^isoni^ that HUD will reinforce
          Lead is dangerous.


                                            °£
                   built be£ore 1978 may contain lead-based


          Chipping and peeling paint should be promptly repaired
          by persons trained to minimize dust generation

          Dust  should be wet -mopped and wet -wiped.


                   Sh°Uld be taught to wash thei^ hands before
                   *hSuld eat healthy diets high in  calcium and
              which  discourage the absorption  of lead  in the
                                tO  be  re^larly  tested for lead
    Lead-Based Paint Hazard Control Grant Pr-orrr-^   HUD has
    awarded over $279 million to 56 State and lowl governments
    for the abatement or hazard reduction of lead-based Sint in
    pnvately-ovmed homes that are owned by or rentSd to loS
    rSSu^JT1^3-  EaCh of.thes^ abatement programs is
    f *?^~i       3Ve a S13nificant lead-education program and to
    actively promote community participation.   ,    ^r&™ ana to

    Although each grantee's program is different,  the programs
    SL^lude.act^vities ^ed specifically at a nun^e? of^
    constituencies including children, parents,  landlords      '
    ins??^?ion;nd rent?rS'  medical Professionils,  and Seal
    hhloi    J  S '   Grantees use a variety of means to reach
    these  audiences including educational events,  screening
    programs,  attendance at community meetings,  ind SSct
    outreach to home dwellers.   They support these activities
    with various materials including brochures,  posteST fact
                5'  artlCles'  t-shirts,  coloring1 books ,' b^ons

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                                                                  12

        n
                         Wil1 be suPerse
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                                                                13
       £Ver?ee  lead reduction activities in public and




and EL ?   • ?  lnspector performs according to contract
and how to  interpret the inspector's report    Where
inaccurate  testing is found, HUD has and will continue to
advise housmg authorities to retest pain? surfwes'?

Based on the short-term analysis by the Center fnr T«»*  o,*
Housing,  HUD was able to distribute in February ?9 9 5 such
    aCaealS°n lead testin9 to all 3?a'£o of o
              nHTv   lead testin9 to all  3'o  of  our
             and Indian housing authorities,  all HUD field
               ?nd k?Y ?Ublic housi*9 inter4st groups  like the
        AH     pSw?oaS10n-°f S°USing and R^evllopment officials
      th^imrf?  f T Housin5 Directors  Association  (PHDA)', and
      the Council of Large Public Housing Authorities  (CLPHA)
      Given staff and other resources, HUD is int£r?sted  in
      conducting field training on the new lead  guiSncf .
                f°T:7ard to the  final  recommendations from the
      ^	^-^^j.^                                         ln

2.
                           «°l that, amongthe
                                 to £ollow "ini™™ lead
                                                            o!  of
                Paint Hazards in Housing.  HUD
B.
!•   Implementation nf
         KSS 53S;
                   »«
                   -S proposed rule on national sandards
          their funds.   Within  the next two years, HUD
     anticipates increased activity in lead hazard reduction

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                                                           "'
                                    affordable housing in the
                                           with
     forasisted ^unaoa^3** ?aillt  eguations
     income neighborhood!   ?hese chana^^f 1
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                                                                 15
 2-



                       and methods for making tir us
                             Bs — HUD has  the  support  of  the
£.   Economic Growth and  Job Creation

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            includes  classroom instruction, workshop skill
            indT   ng'      on-the-job work  experience.  TO da
       16

date, 48
            ISSth cX??1? Tand African American cOMnuninear
            south-Central Los Angeles.  More than 1 1 « TO,, T
                                   -

                                                    •»«> central
 will  Sn?;ue°SIdanb!n?igraie pj??
 strategy and envirSnSntll 1                "160* ' S
               ' f eal
 deficit redction  nd bnced Sudet^^h' n^*1 envir°™^t of
                             ""
-ccf

                      -iSt--d-- - ° ^     -   |;ess
passed legislation which provide minimJn standards for extractor


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                                                   .
           stipulation that inn»i       a result of the grant

 their funds untif s?£te-Side legislatio^hf ^ CannOt tap into
 recently have  certain state! and                   ^*

                                  *               programs.


                               to continue in FY 1995




                                                     isar
ousing

or -bonuses-  in  the
                                              SUpply side of
                                                   abatement,
                                                  SSlmity
set

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                                                  :               is
                        BROWNPIEI.DS
  The Problem


    unknown, it is estimatd t    ?SJ    £ the brownfields problem
 ranges froi^ 100^000 to 500 000       nUmber °f conta^nated sites
                                                                 '

-^vintage  of  exijting infral^Se^rec^rC" ^°


HUD Response-to-Date

                                                         The loan

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                                                                 19

 asJiSta66 assisted activities must be eligible for CDBG


 coliaterafrSfthfioan grant*e?* °£S alistance^fuleTas
 Next Steps:  HUD  Proposal for Future Strategies

 1.   Pursue Recommendations from HDD's Symposium on Brovnfields

      In December  1994, HUD,  with the active  support and
 redSv^o10n ?f E5A' held  a sW>osium on the  barriers to the
 hJni^XSJ 0Pment and reuse of urban brownfields.  The symposium
 brought together  practitioners and policy-makers  representing a

            persPectiveS:  devel°Pe"   enviro^Stalistl? comSun?ty
                        State and local  official£i:  The symposium
                         in meeting urban redevelopment and
                   1S simul^eously,  identified barkers that must
 ™K           su^ested actions that HUD  could take to
 contribute to solving these  problems.  A number of innovative and

 SoSTd aik!%SUgge?tl0nf We?e made at  the sy»Posium which HuT
 would like to explore further with other federal and private
 sector partners.   Some of  these  include:             private


           developing new financing strategies such as 'industrial
           revenue bonds,  credit enhancements, real estate
        -  investment trusts, HUD loan guarantees;

           creating new public-private vehicles,  such as  land
           banks  and receiver programs, to oversee cleanup and
           redevelopment process;

           assigning States a greater role to  oversee the  clean-up
           f* *• ^-^ w c o S /                                              .


                             °f environmental  insurance to  limit
          providing better information to  communities and the
          andVate  SSCt0r °n sites caPable  of being redeveloped;
     assessing the cumulative  impact of environmental
     requirements on  cities, and devising better means of
     making urban communities  more economically competitive
     in the regional  economy.                   '

These, and other innovative recommendations are contained in
ummary of the proceedins of the
          ,                       ecommeaons are
the summary of the proceedings of the symposium, which is
Sn^i   e.fr°m HT^>/S office of Policy Development and Research
The Department, in coordination with EPA, is currently assessing
                c                                            1

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                                                                 20
  2.    Partner with EPA in the Recently Announced "Brownfields
       Action Agenda"

       In January 1995,  EPA Administrator Browner announced a  new
  k£°^fl®idVnit^tive Before the U.S.  Conference  of Mayors.   In
  short,  the  Brownfields Action Agenda calls for:

           removing 25,000 sites from the Superfund inventory to
           help  improve their prospects  for redevelopment;
               • >                                 i
           funding 50 pilot communities  to develop  brownfields
           cleanup and  redevelopment  strategies; and

           issuing a package of reforms  to limit liability when
           redeveloping contaminated  sites.

.      HUD is working with  EPA on this new initiative.  Already,
 HUD has met with  EPA and  the lending community to  fashion ways in
 which to help private  sector leaders overcome the  stigma of
 investing in urban  brownfields.   The Department intends to
 continue to take  an active  role in implementing the
 Administration's  agenda for brownfields.

      To supplement  this effort,  HUD  and  EPA will also jointly
 undertake a number  of  research projects  to better understand the
 impact of brownfields  on  inner city  development and to develop
 more effective program strategies to  address the vacuum of
 investment.   The  first research project will assist HUD and EPA
 in determining the  extent to which environmental hazards and
 environmental regulation  impede  private investment  in urban
 locations.   A second project will develop several  reuse and
 redevelopment models to guide  local revitalization  efforts
 These efforts will-be  integrated with HUD's initiatives to'
 promote economic development through Empowerment Zones  and
 Enterprise  Communities and -to  eliminate lead-based  paint hazards
 in the nation's housing stock.

 3.   Provide Better Technical Assistance

      HUD will explore ways in which we can advise and train
 localities  to cope with the many facets of this  problem.  For
 instance, HUD can work in cooperation with EPA to provide
 assistance  to communities on the spectrum of issues dealing with
 brownfields  rehabilitation and reuse, including  identifying the
 scope of the problem,  understanding and working  through federal
 and  state environmental regulations,  choosing appropriate use and
 health standards,  developing economic development and marketing
 plans,  working with the business community,  and  working closely
 with and providing assistance to residents to assure that their
 views  and concerns are  identified and addressed.

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 4 .   Explore Other Interagency Efforts

                  to the  Aforementioned interagency
                         e      Fr                        where
 in coordination with othtenc^13*06' ^ Int6nds tO
                            ^

                                                      'in the
           use the Consolidated Plan and the newly created Office
           of Community Viability as a vehicle for proviSno
           important linkages with other agencies^? enhanSI the
           effective use of Federal funds at the local  levX;  and
          nL?on^°rUn^tY'  metrOP°litan,  state,  regional,  and
          national  levels,  pursue linkages with other  ageAcies
          whose programs can be used to  enhance HUD     gencies
          constituencies.   Among these are the  DOT Livable
               ^1£b?r0Sram'  HHS/S Healthy Communities, and
               s Urban  Resources Partnership.
5'   Retention    ^   Bro^fi&1^ Redevelopment through


     Under HUD's reinvention plan, HUD will establish *
consolidated, performance-based fund called the CommSnit-v

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                                                                 22
      Problem
                             ze
  and drainage, and  subltlndaJd

  These dist?essld a?eafa?f
  New Mexico, Arizona  and
  of negligence to g^a
  and land development
                                                       ^-Mexico
                                                 inadequate roads
                                                    of the Texas,

                                                        from
                                                sanitation needs
 to ground water  cntmintiS  ?nf fhW3ter a2d Sewer systenis
 for drinking and StnTng    ?LJ2  conlitf SnS  contai^""ed water

 health, safety and  envi?onmen?J!  riSk to ?h»P°?S a.serious P^
 income families  of  the borSJ?  region         minority and low-


 HUD Response-to-Date








 of  colonias  residents   in IQQ!  JJ  Jargeted to «>ee.t  the  needs

 total  of  $12 millSn ior ?he coioniL  ^  ^^ allocat^ a












approve the  legislation       resn°n.  However, Congress did not



Next Steps :  HUD  Proposal for Future Strategies   i
                       Bc
the lack of authority^or  J
outlines HUD's strategy  to
other federal agencili^to
              agencies to
                                                 .
                                           connunities ,  despite
                                         pro^^'   The following
                                         WOrklng closely with
                                    a more comprehensive strategy

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                                                                 23
             ilie;-liVirnTH alon9.the country's  southern border;  2)
 inr         existing HUD activities in the  colonias; and 3)
 incorporate colonias initiatives in HUD- s  reinvention plan.


 1.   Actively Participate in EPA's Colonias  Workiny Group


 Gr01mAf J™r?  ?f^f°rmeLS°Yernor  Anne Richards' Border Working
 sS LS    Sfc^d  iV"2  in suPP°rt of NAFTA, the Texas Colonias
 iSSK OUP-  cha^ed  by the Environmental Protection Agency, was
 fSS  to. develop an integrated  and coordinated approach to
 implementing  financial  and technical  assistance for drinking

               KeW2ter inf ^structure in the colonias along tL
               border area.
      The sub-group has proved to be a successful vehicle for
 coordinating State and Federal activities involved in financing
 water and wastewater infrastructure for the colonias by bSSg
 agencies together to share and discuss common issues,  provide

                                       issues' and
issue
  ssue  toe   t      tio

 *nS  ii!:ai  asflstance to colonias,. but also compliance with State

 JSbdi?isions     Preventing the Proliferation of  illegal  colonia



 rT.nilT,HUDTwil^coritinue to Participate in the Texas Colonias  Sub-
 ?h2  Si  • ? addlt^on-  HUD will actively pursue efforts, through
     aS
 h     •                                              ,    roug
^L,afSJStance ?J other a^cy ^roup members, to explore wayi of
formulating similar working groups in the other three border
stat
states .


2.   Administer and Monitor Colonias  Funds
of^o J?Vri?9  the  past three years,  the Department ! has sought to
effectively  use  its  limited resources to assist the bordSr
region.  To  date,  nearly $3 million dollars have been awarded to
^Lf?ur.border  states,  their  local governments, and non-profit
organizations working on behalf  of colonia residents for the
purpose of providing technical assistance, capacity building,  and
economic development opportunities /initiatives to colonia
f?!!™^^;3-  The  Department has made these grants available
through the  HUD's  Technical Assistance Program.
p™,.    DePartment will continue to use its Technical Assistance
Program as a means to channel funds to colonia communities in
       anc;.?f lts fff^ts to help improve the environmental and
       conditions of colonia residents.

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have
           housing  oic?r£OVer2mants to
enhance homeownerlhip oSSJtSifiS^ vulnerable populations,
housing counseling and iSpporWve sir?icef     8 S ""^ °f
                  as

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      II-   ENVIRONMENTAL JUSTICE:  OPTIONS FOR H«PLEMENTATION
                                                              25
BSSLB
          agencies to-  ct
 expand opportunities for m£5i
 information;  and submit rSortS
 the Order on  the progress in
 environmental juslicS
                                                       Order
                                             analvze data;
                                           n'- iinProve access to
                                         m°nths of the date of
                             isc
and threatened elimination   SesoiS
determined to do everything we XJ
fiscal realities  to fu?f??i      '
Executive Orde? and
wholesome,
                                                   rescissions,
                                          °bstacles' HUD is
                                          our  authority and

                                         °f  the
subsequent discussion
                                        -
                                   ^ustlce initiatives.   m the
   1•   Devise  internal coordinating mechanism

   2"   f^fiuate fc,he inventory



   3.



        *        ^"^    ^* ^^ "• ^"^ ^^^i^ZXi *  3.CC?^^^ ^ t™ ^^ *i v> f J~L I'^JT	j_ *
        involvement               -»-=oo cu inroarmataon


   5.    Provide effective  education/training and communication

   6.    Provide technical  assistance and guidance


                                of the six areas of

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                   SIX OPTIONS FOR IMPLEMENTATION
 1.   Devise internal Coordinating Mechanism
                                                                26
2.
           facets  of  the
    a
    b
    c
    d
    e.
    f.
    g.
    h.
    i.
    3 .
    k.
    1.
   m.
 Site and  neighborhood  standards;       '!
 Environmental reviews  and regulations;
 Planning  guidance;
 Project selection factors;
 Housing quality standards;
 Fair housing enforcement;
 Consolidated plan;
 Citizen participation requirements;
 Applicant  certifications;
 Applicant  narratives;
 Remediation and relocation policies;    •
NOFAs, regulations, grant agreements; and
Technical assistance and training for grantees and HUD

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4.
5.
      par as ^HJiS£*5eis=t
      benchmarks in the perforSSS bom^ v«°™atal Justice

      consolidated funds to rSS?d\Si?U* 5?°ls . under each of the
      governments.          reward well -performing State and local
                                            I


                            *=«« to information
                                                   citizen
     b-
     d-
   d.
                                                     .
                                               communities;

         Increase distribution of HUD's  fin»i  «   •
         justice strate                final  environmental
                 strategy;
     e.   Consult  and seek input from citizen groups.
                                                       on
                    iownrieids Redevelopment,  Colonias •





                        -ass

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6.
                                                               28
Provide Technical Assistance and Guidance

a.
          Identify, note, and participate in interagency effort^

          niaSJrrvP°SSible t0 avoid duplication of ef Srt £?
          Snle?takings;°ther ^^ enviro^ntal justice
          =        .review-  and screen HUD programs,  applications
          and public and Indian housing portfolios to assSre     '
          consideration of  environmental justice concerns;


          Improve the capacity for  localities participating in

          iuS;?~1St?d pr??rams bv  developing environmental
          justice information/guidance material and  strategies
          for community outreach;                    ^ai-egies


          Communicate to builders and lenders the importance of
          environmental  justice considerations in the development
          of  their HUD-assisted and insured projects; and/o?


          Give special attention to environmental justice

          acc1ntahlSYlPr°Vidin? ^^ SUpport and us^ful and
          acceptable  language for program regulations and
          guidance material.

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