SERA
BROWNFIELDS AND URBAN
AGRICULTURE:
Interim Guidelines for Safe Gardening Practices
Summer 2011
t
-------
Introduction 1
Overview of the Issue: Brownfields and Urban Agriculture 1
Process: Development of these Guidelines 3
Recommendations 4
Overview of Recommendations 4
Complicating Factors 4
How clean is clean for gardening activities? 5
How clean is clean for plants to be safe for consumption? 6
Step-by-step Guidelines 7
1. Identify Previous Use 7
2. Perform Sampling 9
3. Interpret Results 11
4. Manage Risks 12
5. Begin Farming 14
Why Include a Business Plan? 15
Summary 16
Resources and References 17
Participant List 19
-------
INTRODUCTION
This document is a condensation of the input of 60 experts from academia, state and local government, and the
nonprofit sector who gathered in Chicago on October 21 and 22,2010 to outline the range of issues which need to
be addressed in order to safely grow food on former brownfield sites. A list of the participants in this workshop is
available in Appendix A.
In short, there are three major issues:
1. Before deciding whether to garden on a site, it is important to research its history, because a site may
have a range of contaminants depending on its past uses;
2. Once the past uses have been determined, there are options for testing, cleanup or exposure-
management approaches which prospective urban farmers can utilize in order to garden safely; and
3. Although a wealth of experience has been gained through brownfields cleanup over the last 15 years, the
cleanup standards in existence are designed to protect people on the site from ingestion and inhalation of
contaminants in the soil, water and air, but do not address consumption of food grown on the site. Over
time, we expect that standards will be updated to address this gap. In the interim, existing residential
cleanup standards can be used as a benchmark for safe gardening.
Overview of the Issue: Brownfields
and Urban Agriculture
Across the country, communities are adopting the
use of urban agriculture and community gardens for
neighborhood revitalization. Sites ranging from former
auto-manufacturing sites, industrial complexes, and whole
neighborhoods, down to small individual lots, including
commercial and residential areas, are being considered
as potential sites for growing food. As an interim (less
than five years) or long-term use, greening a parcel by
implementing agricultural practices can improve the
environment, build amenities, revitalize neighborhoods,
and have direct benefits to residents' food access and
nutrition.
Redeveloping any potentially contaminated urban property
(often referred to as brownfields}, brings up questions
about the site's environmental history and the risks posed
by proposed reuse. Current brownfield and contaminated
land risk-based cleanup approaches establish cleanup
levels based on proposed reuses. For residential,
commercial or industrial brownfield redevelopment,
individual states have set rules and standards for how
to conduct an investigation and clean-up activities
through what are known as Voluntary Cleanup Programs.
Residential reuse requires the most stringent cleanup as
it assumes children and families will live on the property.
The benefits of urban agriculture vary from health
and environmental to economic and social.
Gardening in urban areas:
• Increases surrounding property values,
beautifies vacant properties, increases a
sense of community, and provides recreational
and cultural uses.
• Increases infiltration of rainwater, reducing
stormwater overflows and flooding, decreases
erosion and topsoil removal, improves air
quality, and reduces waste by the reuse of
food and garden wastes as organic material
and compost.
• Increases physical activity and educates
new gardeners on the many facets of food
production from food security to nutrition and
preparation of fresh foods.
Kids who garden are more likely to try and
like vegetables and eat more of them, and the
combination of the social connection of gardening
with the increased access to fruit and vegetables
creates a new norm in children who continue to
make healthier choices
(Robinson-O'Brien, 2009, Alaimo, K et al., 2008).
BROWNFIELDS AND URBAN AGRICULTURE
GO
LiJ
CJ
CJ
-------
However, the rise of agriculture as infill redevelopment creates new questions about the risks associated with
agricultural uses, particularly where food crop or animal forage production is concerned. In many parts of the country,
advisory standards and practices for agricultural redevelopment simply do not exist.
U.S. Environmental Protection Agency (EPA) Brownfields and Land Revitalization, in cooperation with programs
within the Office of Solid Waste and Emergency Response (OSWER), and our State and Tribal program counterparts
from around the country are working with communities on many of these on-the-ground redevelopment projects.
In addition, the EPA Region 5 (Illinois, Indiana, Michigan, Minnesota, Ohio, and Wisconsin) Community and Land
Revitalization Branch began working with local and regional stakeholders and a national committee in mid-2010
to learn more about implementing urban agriculture and community gardens in the safest way possible. These
guidelines are intended to protect public health by informing communities about safe gardening practices when
creating gardens on vacant lands or structures that may have an environmental history.
The committee quickly identified a number of policy gaps contributing to the uncertainty around gardening on former
brownfield sites. The first is that at this time, there are no definitive standards for soil contaminant levels safe for food
production that reflect the soil site conditions and management practices common at agriculture sites. EPA has long-
established soil screening levels for contaminated site cleanup but these threshold-screening levels frequently serve
as a starting point for further property investigation and do not factor in plant uptake or bioavailability. Nonetheless,
the application of these contaminated land analysis and screening approaches can provide support to emerging
operations and reassure consumers and markets about food risks from environmental contaminants.
Another policy gap surrounds the connection between soils and food safety issues. US Food and Drug Administration
(FDA) and US Department of Agriculture (USDA) regulate certain elements of food safety and material application
in food production areas, such as biosolids or sewage sludge application on farmed land. Farms seeking organic
certification also have restrictions on materials use and application. USDA also regulates the international import of
soils. There are also agreed international standards on levels of contaminants in final food products (FAO, Codex
Alimentarius)1 but neither FDA nor USDA have standards that regulate the quality of soil as a growing medium.
There are also gaps in practice. The extent of contamination on sites and properties that have been selected for
urban agriculture isn't clear. Many community gardening and developing farm organizations test for agronomic
parameters - nitrogen, phosphorus, and potassium (N-P-K) as well as pH and organic content. A smaller subset
of organizations may test for environmental contaminants, although often only for lead. Other organizations and
USDA extension agents encourage full metal panel testing which incurs greater costs to the gardener. A recent
compendium of urban agriculture practice and planning by the American Planning Association (see Resources and
References section) noted few local requirements for soil testing and very few examples of locally driven testing on
^ behalf of community organizations.
This document is designed to fill the identified gaps presented above by presenting a process and set of
^ recommendations for developing agricultural reuse projects on sites with an environmental history. Potential
£ gardeners, state environmental agencies and regulators can use this process to determine how to address the risks
inherent to redeveloping brownfields for agricultural reuses while being protective of human health. There is a large
^ body of ongoing research as concern about contamination emerges and urban gardening becomes a common
j practice, particularly in communities with limited economic activity. This document can be used as an interim
Si
D 1 The Codex Alimentarius Commission was created in 1963 by the Food and Agriculture Organization (FAO) and the World Health
^ Organization (WHO) to develop food standards, guidelines and related texts such as codes of practice under the Joint FAO/WHO Food
25 Standards Programme. The main purposes of this Programme are protecting health of the consumers and ensuring fair trade practices in the
^ food trade, and promoting coordination of all food standards work undertaken by international governmental and non-governmental organiza-
tions.
BROWNFIELDS AND URBAN AGRICULTURE
-------
guideline until such research can provide more definitive standards and policies for agricultural reuse on these sites.
Although the guide was developed in the Midwest, it may be used to benefit tribes and communities throughout the
country wishing to utilize urban agriculture on brownfield sites and vacant properties.
Process: Development of these Guidelines
While creating urban agriculture projects, local governments and community non-profits have identified gaps in
knowledge and policy that create unintentional roadblocks to completion of agriculture redevelopment projects on
brownfield sites, particularly for food production.
To address the identified gaps in a meaningful way, our first task was to inform each other on the current state of
knowledge on agricultural redevelopment. Two webinars in Fall 2010 presented a snapshot of the state of science
and policy issues in urban agriculture:
1. The State of Science and Research Needs, included contaminant exposure routes, bioavailability, and
plant uptake; and
2. Policy Barriers and Incentives to Reusing Brownfields for Community Gardens and Urban Agriculture,
included stability of land tenure and the lack of clear cleanup standards.
3. These webinars were widely attended by practitioners and local governments across the country, and are
available for viewing on the U.S. EPA's Urban Agriculture website at:
4. http://www. epa.gov/brownfields/urbanag.
The webinars provided the foundation for the Brownfields and Urban Agriculture Midwest Summit October 21
and 22, 2010, which brought together over 60 invited experts from non-profits, community groups, academia, and
various forms of government to develop a decision protocol for safe urban agriculture.
CJ
-------
RECOMMENDATIONS
Overview of Recommendations
Just as conventional agriculture can pose risks to farmers, neighbors, and the environment, each urban agriculture
scenario poses its own risks. The convened experts developed a list of ideas and a process for addressing these
risks so that growers can be aware they have selected a brownfield and brownfields can be redeveloped safely and
efficiently into agriculture projects. They found that the underlying question in this strategy becomes: How clean is
clean? This somewhat simple question becomes complex when considering the scientific data required and policies
that need to be in place in order to answer this question fully.
Complicating factors
GO
LiJ
CJ
CJ
-------
subsequent section will provide a clear process for organizations to identify and reduce risks, reassure gardeners,
and yield safer, more efficient growing scenarios.
How clean is clean for gardening activities?
Clean-up and reuse of any brownfield site is based on risk assessment and exposure scenarios -the levels of
contamination present and how a person can be exposed to that contaminant, based on the intended reuse. These
criteria for residential, commercial and industrial reuse are based on potential exposure: length of time spent on the
site, types of activities performed on the site, and potential contamination pathways such as inhalation, ingestion, or
possible dermal contact with contamination.
Urban agriculture is a new category of land use with different patterns of exposure - people are in closer contact
with the soil than for any other category, for different time periods. While residential use is based on living,
sleeping and eating in a dwelling on a property, the overall time and proximity to soil and potential contaminants
make gardening and farming somewhat different from residential or commercial use. A commercial-scale urban
agriculture scenario would have yet another set of exposure criteria to the workforce and potential neighbors. While
these risk scenarios still require refinement based upon additional research and policy discussion, it is clear that a
separate category of use should be established.
However, as with all reuse categories, there are potential best management practices (BMPs) that can significantly
reduce risk from multiple exposure pathways. Uncertainty about specific cleanup and reuse standards serves as a
recognized policy barrier to implementing agriculture projects, but we also must recognize the health benefits from
eating locally grown food and balance this with the manageable risk associated with using brownfield sites. While
clean up levels were not the focus of the workshop efforts, they are a known policy issue that should be resolved in
the future.
Exposure pathways
8Sii&^
Direct exposure to contamination. Inhalation of contamination. Uptake by plants and subsequent
consumption.
CJ
«=c
Q_
CD
-------
How clean is clean for plants to be safe for consumption?
The high degree of variability in soils, limited control of public spaces and unique characteristics of how crops
(species and variety, edible portions of plants) and humans respond (age, precautions taken) makes issuing
blanket statements of safety virtually impossible. Plant uptake of contaminants is a concern to urban gardeners and
those who would like to include locally grown food on their menus. While many of the uptake risks from urban soils
can be controlled by demonstrated BMPs discussed in further detail below, ongoing research on plant uptake and
bioavailability continues to bridge knowledge gaps.
Success in brownfield redevelopment across the country, and success in other gardens intuitively tells us that
gardening in populated areas is not a new idea, nor is it impossible to do safely. EPA has developed a simple logic
model, included below, that is based on the results of our working session and BMPs identified at successful larger
scale agriculture projects. This does not answer every question that has been raised; rather it poses the questions
you should ask in order to garden safely, and discusses what information you should collect in order to make
decisions.
This model describes the process by which a gardener should consider safely implementing a garden of any type
(hoop houses or greenhouses, farm stand, vertical, aquaculture, community gardening plots) on a piece of property
that has potential contamination.
The process for assessing properties for
the presence or potential presence of
environmental contamination often is referred
to as "environmental due diligence," or
"environmental site assessment." Phase I
Environmental Site Assessments (ASTM 1520)
and All Appropriate Inquiry (ASTM 312) are
the industry standards for identifying potential
environmental concerns according to previous
uses of the property. These methods require
desktop-based investigation like looking at
Sanborn maps, historical aerial photos, city and
county records and reviewing environmental
databases, as well as conducting interviews
of neighbors and previous owners, and
visiting the site to assess any visual cues for
contamination, such as evidence of storage
tanks. Potential property owners have an
environmental professional prepare a report
containing this type of information prior to
most real estate transactions, but historical
information is commonly available to anyone
wishing to do the research on the internet, at a
local library, or county records office.
BROWNFIELDS AND URBAN AGRICULTURE
-------
STEP-BY-STEP GUIDELINES
The following logic process proposes a series of questions you need to ask and the information you need to gather
in order to make decisions while implementing an urban agriculture project. Each of these steps has multiple
sub-steps and issues that you may want to look into further. However, this model may be applied to any urban
agriculture project on any brownfield site, and may be of value for other reuses where contact with soil may be
higher, such as parks or recreational areas.
1. Identify Previous Use
What is the history of your proposed site?
The previous use of the property and those
surrounding it will be the major deciding factor on
how cautious you should be before gardening. It
is important to gather enough information about
the site prior to beginning actual gardening
activities so that you may tailor additional site
investigation to the likely contamination left
behind. Special environmental assessments
are commonly required prior to purchasing most
commercial and industrial properties, but those
simply leasing the land from the owner or local
landbank, or those receiving donated land should
also plan to do some level of research.
The more historical information learned about a
site's previous uses, the more informed decisions
can be made during garden development. If you
plan to sell produce or value-added products,
now is the time to draft a business plan for
your garden. Farm design and duration (short
or long term use), types of crops planted and
expected costs for construction or remediation
will all be informed by the site's previous uses
and the expected condition of existing soils. The
business plan should be revisited throughout this
process to ensure the potential for success of
your garden. More information on developing a
business plan and its ties to the redevelopment
process is presented in the final section of this
document.
Identify Previous Use
Draft
Business Plan
Low
Risk
I
^^^H
:orm Sampling
High
Risk
Basic I Rigorous
Sampling^" Sampling
Interpret Results
Manage Risks
JH
Modify
Business Plan
Perform Cleanu
mplement BMPs
BEGIN FARMING
Implement
Business Plan
GO
LiJ
CJ
CJ
-------
Determine Whether Previous use is High or Low Risk to Site Soil and Water
What does the site history suggest about the likelihood of contamination and potential site risks to food
production?
No two vacant parcels are alike. However, we can infer possible types of contamination based on the previous
use of the property. For example, residential areas may have unsafe concentrations of lead where the presence
of older housing stock or structures indicates lead-based paint was present. Polycyclic aromatic hydrocarbons
(PAHs), a group of chemicals formed during the incomplete burning of coal, oil, gas, wood, garbage, or other
organic substances, can be found at former residential properties as well as commercial and industrial properties
from fires or combustion processes. PAHs stick to soil particles and are found in coal tar, crude oil roofing tar, wood
smoke, vehicle exhaust, and asphalt roads. Sites previously used for parking may have high concentrations of
petroleum from leaking oils and fuel, and gas stations may have had leaking underground storage tanks that can
cause contaminated groundwater and soils, or poor indoor air quality. Even greenspace or agricultural uses may
have hotspots from over-fertilized ground, pesticides, or animal feed spills. The table below presents some example
contaminants of concern found on brownfield sites.
GO
LiJ
CJ
CJ
-------
of thumb, recreational or residential previous uses are typically lower risk while commercial and industrial uses
can be considered higher risk, although you may find information in your research that suggests otherwise for
your particular site. Consult with your state environmental agency, local health department, or county's USDA
Cooperative Extension office to determine what kinds of samples you should take to accurately represent the
conditions at your site.
Finding your ag extension
The USDA National Institute of Food and Agriculture funds the Cooperative Extension System - a nationwide
educational network staffed by experts in agriculture working to identify and address current issues and
problems. Extension offices are located in each US state and territory at its land-grant university, as well as
in local and regional networks often in each county. Find your local Extension office at:
http://www.csrees.usda.gov/Extension.
2. Perform Sampling
What additional information is needed to determine soil quality? What additional information is needed to
identify or rule out potential contamination risks?
Two types of soil quality sampling are recommended for every site: soil as a growing medium, and soil contaminant
concentrations for safety. Because each parcel of land is unique, each sampling approach should be considered
individually. However, given that not all previous uses are created equal, we can make some assumptions about
the relative risk of the previous use, and this will guide our sampling strategy. Low risk previous uses like residential
areas, green space, traffic corridors and parking areas generally have a narrow band of likely contamination that
allows for a basic sampling strategy. High risk uses, like manufacturing or railyards, open up the possibility of
many types of contamination over a wide area of the site, and requires a more rigorous sampling strategy. Some
organizations can provide technical assistance for soil testing, including the EPA and state brownfields programs,
and USDA Natural Resources Conservation Service (EPA 2009).
CO
Sampling methodology
CJ
How do you decide where to sample and how deep to go? Sampling methodologies will vary slightly depending §
on what you are sampling for or the type of crop you are planning to grow because some plant root systems y|
are deeper and more extensive than others. Refer to the University of Louisville's Urban Agriculture and Soil g
Contamination: An Introduction to Urban Gardening and Purdue University's factsheet entitled, Collecting Soil
Samples for Testing for more information on sampling frequency, collection, location, and the best time to take your ^
samples. Don't forget to call ahead of time to have utilities marked before digging anywhere on your site. Find your ^
local "Call before you dig" service at http://www.call811.com.
Low risk uses - basic sampling
LJ_
en
Sampling for soil quality should include a composite sample that represents the on-site soil structure and
composition and reflects the preferred growing area. This type of sampling and analysis is simple to perform ^
and relatively inexpensive to do. Sampling for pH, organic matter, nutrients (nitrogen, phosphorus, potassium), £zi
soil composition (sandy, clayey, etc) and texture will determine what types of improvements should be made or ^
amendments added so that plants can thrive in your garden.
BROWNFIELDS AND URBAN AGRICULTURE
-------
Sampling for soil safety should include, at a minimum, composite sample(s) which would be tested for a wide
range of metals (including heavy metals, iron, and salts, some of which are necessary plant nutrients, such
as magnesium, potassium, calcium, sodium), PAHs, and additional constituents based on likely contaminants
associated with the site's previous use. Any area that appears out of the ordinary, is suspicious looking (including
stained or discolored soils, or the lack of plant growth in soils), or indicates a potential for contamination, should be
submitted with additional discrete samples in each area. This will allow you to identify the type and extent of existing
contamination and to estimate if cleanup is required or if you only need to have special considerations when
designing your garden.
For your records, you may wish to draw, photograph or note soil sample collection locations on a map depicting the
site. If you collected five samples to combine into one composite sample, you should note their individual locations.
For example, you would identify that sample #3, was taken from the top 2 inches of material at a location 2 feet
from the north (left) side of the path and 5 feet east of the entrance. You may also wish to flag or mark sample
locations until your results come back; typical lab turnaround time is approximately two weeks.
High risk uses - more rigorous sampling
Any large parcel with multiple historical uses will require more rigorous sampling in addition to the methods
mentioned above. This should include multiple composite or discrete samples for any suspected contaminant
in each area of the site. Additional discrete samples should be collected where contamination is suspected. If
groundwater contamination is likely, or if a spill is suspected, deeper soil sampling and groundwater sampling is
strongly suggested.
BROWNFIELDS AND URBAN AGRICULTURE
-------
3. Interpret Results
What do the sampling results mean for risk to growers or healthy plant growth? What contaminant levels are
low, frequently seen, easily addressed and can be managed with good practices? What levels are too high and
require involvement of environmental experts?
While the EPA prescribes groundwater/drinking water guidelines, no hard and fast rules for agricultural soils exist
on the federal level. Most states set guidelines for soil cleanup with risk-based standards based on anticipated
reuse of the property. Residential clean-up levels are the most restrictive, so if contaminant levels are below
residential use levels, it is safe to assume your site is safe for gardening and will be protective of public health. We
recognize, however, some communities may want to seek levels lower than residential reuse levels in the interests
of precaution.
Because no agricultural reuse standards exist as discussed above, contamination levels falling within the
commercial and industrial reuse categories warrant a site-specific risk determination and mitigation. If you don't
have a qualified environmental professional on staff and you are concerned about your sampling results, you
should get help interpreting the results of your sampling effort. State and local health agencies, state environmental
agencies and USDA Cooperative extension offices, located in most counties, are good places to start for help in
determining what safe gardening levels in your soil may be.
Not all types of contamination will have the same effect on you as
a gardener or on your crops. Research on soil metal chemistry and
plant uptake conducted at the USDA has found that most metals are
so insoluble or so strongly attached (i.e. adsorbed) to the actual soil
particles or plant roots, that they do not reach the edible portions
of most plants in levels which would compromise human health
when eating grown crops. Maintaining a neutral soil pH can control
much of the risk of exposure via plant uptake. For example, lead is
known to be toxic to humans, and can be found in extremely high
concentrations in some urban soils where extensive lead-based paint
was used or where historical lead industry activity occurred. The risk
to the gardener, inhaling dust or ingesting actual soil from dirty hands
is much higher than the risk of the consumer eating the properly
washed crops grown from this soil. Important exceptions to the
strategy of keeping a neutral pH include soils with high concentrations
of cadmium and cobalt, which can be toxic to humans, and sometimes
molybdenum and selenium, which are more of a concern for livestock
(Chaney, 1984).
Other soil metals, such as copper, are phytotoxic and will kill the
plant before the metal concentration in the soil would be harmful to a
gardener. In these cases, accidental ingestion of the actual soil during
initial preparation or as part of ongoing gardening activities would
have the greatest negative health effect.
It is important to know which areas of the site are contaminated in
levels that are unsafe for in-ground gardening activities and what that
means for your garden design. Additional testing may be necessary to
determine the extent of contamination if a hotspot is found.
A note on analysis
Most tests for soil contaminants
use extraction methods (i.e., the
sample is digested in acid and then
diluted prior to analysis) yielding a
total contaminant concentration. The
amount of that contaminant that is
bioavailable or bioaccessible (i.e. the
ability of ingested contaminants to be
absorbed by the body) to plants or
people will be less than the resulting
total contaminant level - actually a
fraction of the total value. Often in the
case of lead in urban soils, a small
fraction of the total lead concentration
is found to be bioavailable, likely
due to the historic applications of
fertilizers, manures and composts,
which change the characteristics of soil
and can cause inactivation of lead in
soils overtime. Because determining
bioavailability is costly and because
regulating a total concentration is the
most protective of human health, test
result interpretation frequently focuses
on total concentrations.
BROWNFIELDS AND URBAN AGRICULTURE
GO
LiJ
CJ
CJ
-------
00
Q_
CD
CD
ce
00
cc:
£
00
CD
4. Manage Risks
Perform Clean-Up
When is clean-up necessary? Which remediation techniques are best for agriculture reuses?
If results indicate that the existing soil is not safe for gardening activities and you are planning to plant in-ground,
remediation may be necessary. Work with your state environmental agency's Voluntary Cleanup Program to
determine which remediation technique would be most effective for your site. Consider cost, accessibility, the
timeframe needed, environmental effects, and effectiveness for agriculture before choosing a remediation
technique (RUAF 2006). Techniques most applicable for agriculture projects include physical (excavation, installing
geotextiles, soil washing or soil vapor extraction) or biological (microbial, phytoremediation, or application of soil
amendments).
Will phytoremediation work for
my site?
Phytotechnologies are long-term
remedial solutions that use plants to
remediate soil and water impacted
with different types of contaminants.
Organic contamination including:
oils, solvents, and some pesticides,
and inorganic contaminants like salts
(salinity), and heavy metals, especially
nickel and arsenic are well suited
to a long-term phytoremediation or
phytoextraction approach. Using
plants to stabilize soils, keeping an
appropriate pH, and controlling metal
mobility, as well as keeping dust down,
is a proven strategy for reducing
exposure to contaminated soils.
However, not all contaminants react
the same way to phytoremediation,
and some metals like lead, cadmium
and zinc, just aren't mobile enough to
benefit from phytotechnologies. Get
more information on phytoremediation
and other phytotechnologies in the
Interstate Technology Regulatory
Council document, "Phytotechnology
Technical and Regulatory Guidance
and Decision Trees, Revised,"
available at:
www.itrcweb.org/Documents/PHYTO-3.pdf.
BROWNFIELDS AND URBAN AGRICULTURE
Many non-remedial options exist for sites with low levels of
contamination, or sites with contamination exposure risks which can
be controlled by planting above ground, including installing raised
beds, gardening in containers, green walls or rooftop growing, and
aquaponics. More information on Best Management Practices and
alternative growing techniques is presented on the following page.
Each remediation technique has unique benefits and drawbacks.
Digging away the contaminated soil and disposing it in a landfill
is the most effective technique for removing contaminants but
can discard valuable topsoil. This is also the most expensive
method, and replacing the contaminated soil with clean, non-
industrial fill (that has been sampled for contaminants or has been
certified as safe) can be cost-prohibitive to a non-profit gardener
or community group. In-situ or on site remediation techniques
or biological strategies may take multiple growing seasons or
multiple applications, costly monitoring, and maintenance. Even
remediation by amending with compost may be more involved
than it sounds since composting needs to have preceded growing
to create sufficiently healthy soil. In one EPA pilot project, yard
waste compost added to a waste site for agriculture reuse used 20
tons of compost per acre for corn fields and 120 tons of compost
per acre for peanut crops (EPA 1997). Not all projects will require
this level of remediation, but working closely with your state
Voluntary Cleanup Program will ensure that your urban agriculture
development achieves the proper cleanup goals.
-------
Implement Best Management Practices (BMPs)
Are there things I can do to garden safely without performing a full remediation? What are everyday practices
that will reduce risk?
Regardless of the degree of brownfields contamination or scale, every urban garden should implement BMPs to
ensure continued protection from urban soils. In most instances, simply following these BMPs will bypass any
potential exposure pathways from existing site contamination. However, projects should still be vetted with the
state Voluntary Cleanup Program or local health officials to address any possible environmental and public health
concerns. Because research has found that the predominant exposure routes of concern are direct contact with
or ingestion of potentially contaminated soils, many of the BMPs presented below focus on separating you as a
gardener from existing soils. In many cases, implementing BMPs such as those suggested below will allow safer
gardening in a wider range of site conditions. Not every BMP is necessary for every single site, but a combination of
BMPs appropriate for your particular site will provide better health outcomes.
Construct physical controls
Risk is based on the extent of hazard or contaminant present and the potential for exposure to the hazard. Actions
to remove or reduce hazard (amend soil) and reduce exposure (cover soil), reduce risks. Many good gardening
practices, like adding compost and soil amendments, improve the soil while reducing the amount of contaminants
and exposure to them.
• Build your garden away from existing roads and rail, or build a hedge or fence to reduce windblown
contamination from mobile sources and busy streets.
• Cover existing soil and walkways with mulch, landscape fabric, stones, or bricks.
• Use mulch in your garden beds to reduce dust and soil splash back, reduce weed establishment, regulate
soil temperature and moisture, and add organic matter.
• Use soil amendments to maintain neutral pH and add organic matter and improve soil structure.
- Not all amendments are the same; be sure to choose the
right amendments for your soil. For more information on
choosing the right soil amendment, refer to the Colorado
State University Extension webpage on soil amendments
at http://www.ext.colostate.edu/pubs/garden/07235.html.
- Keep in mind that each amendment type will have
different application rates and techniques (e.g.
rototilling), and may need to be maintained and reapplied
annually.
- Be sure to work with your local or state regulatory
agency, and ask if your municipality provides free
compost or mulch. Some amendments, such as Class A
biosolids from sewage sludge, may be regulated under
various regulatory programs.
• Add topsoil or clean fill from 'certified soil sources' to ensure the
soil is safe for handling by children or gardeners of all ages and
for food production. Your state or local environmental program,
extension service, or nursery may be able to direct you to
providers of safe certified soils, or to recommended safe sources
for gardening soil.
BROWNFIELDS AND URBAN AGRICULTURE
-------
Build raised beds or container gardens
- Raised beds help improve water drainage in heavy clay soils or low-lying areas. They also create
accessible gardening locations for many users and allow for more precise soil management.
- Foot traffic should not be necessary in the bed, so the soil does not become compacted and soil
preparation in the coming years is minimized.
- Your state or local city agency may recommend using a water permeable fabric cover or
geotextile as the bottom layer of your raised bed to further reduce exposure to soils of concern.
- Raised beds can be made by simply mounding soil into windrows or by building containers.
Sided beds can be made from wood, synthetic wood, stone, concrete block, brick or naturally rot-
resistant woods such as cedar and redwood.
Emphasize good habits
Wear gloves and wash hands alter
gardening and before eating.
Jake care not to track dirt from
the garden into the house.
Clean produce before
storing or eating.
Q_
CD
Peel root crops, and remove
outer leaves of leafy vegetables.
Teach kids to wash fruits and
vegetables before eating.
s
ct:
o
5. Begin Farming
Whether it is a long-term or an interim use, simply greening a once-blighted or vacant property and improving the
soil structure has real effects on the economic and social value of land and community health. It can also reduce
the runoff of urban soil, silt and contaminants into stormwater systems by allowing greater infiltration of rain into
soils improved with added compost and soil amendments. The ability to grow food or horticultural crops such
as flowers or trees on this newly greened area will produce multiple beneficial effects to those who may farm it.
Healthy eating, increased physical activity, reduction of blight, improved air quality and improved quality of life are
all nearly immediate health benefits from urban agriculture.
c
BROWNFIELDS AND URBAN AGRICULTURE
-------
WHY INCLUDE A BUSINESS PLAN?
Urban agriculture exists in various forms and scales. From community gardens to commercial enterprises, from
edible landscapes to beekeeping, on a residential lot or on a former industrial site, there is no one-size-fits all to
urban agriculture. However, most successful and sustainable urban agriculture projects do share one thing in
common: a business plan. The urban agriculture business plan provides a road map to the garden's activities, an
internal planning tool, and a way to communicate the project to external stakeholders and potential funders. Nearly
every section of a business plan has strategic items that may be altered due to the condition of existing soils. Many
farmers will find a new site before they make too many changes to their business plan, or will choose a new site
based on remediation costs; but contingencies such as these also need to be addressed and communicated with
investors and stakeholders via a well-designed business plan.
EPA, HUD and DOT have been working together under the Partnership for Sustainable Communities to ensure
that federal investments, policies and actions support development that is efficient and sustainable. In one such
brownfield pilot project in Toledo, OH, the EPA provided technical assistance to develop the Urban Farm Business
Plan Handbook. This handbook provides a complete framework for developing an urban farm business plan and
describes what information should be collected, evaluated, and presented in each section of the business plan,
once the site is cleaned and ready for growing. The Urban Farm Business Plan Handbook is available for download
at:
http://www.epa.gov/brownfields/urbanag.
The level of cleanup required and the costs for implementing that cleanup, such as transportation and disposal
of dirty soils or clean fill, may have huge implications on the viability of your garden as originally planned. The
business plan should be modified to address any changes from the original farm design after determining what level
of cleanup may be required. The state of existing site soils may require a fresh look at the marketing, operating and
financial aspects of your urban agriculture project, depending on whether your urban agriculture site is an interim
or long-term use. A simple modification of garden type to save remediation costs, such as moving from in-ground
planting to raised beds, may have implications on farm function or crop plans. While the risks of gardening on
brownfield sites do exist, the end goal does not change. Gardening safely on sites with an environmental history is
possible and economically feasible if planned properly.
BROWNFIELDS AND URBAN AGRICULTURE
-------
SUMMARY
Implementing urban agricultural practices on brownfield sites addresses and mitigates public health concerns,
reduces blight and preserves neighborhoods, while directly improving food access and nutrition. Communities
wishing to redevelop brownfield sites into urban agriculture projects are faced with a unique problem because
no set cleanup standard exists for urban agriculture reuse. In order to understand the issues surrounding urban
agriculture redevelopment, EPA convened a group of experts that work on different aspects of urban agriculture
and asked how communities should approach the redevelopment process, and what they need to know to develop
urban agriculture safely.
What we found is that investigation into historical uses of the property and consideration of how existing
contamination changes the gardening strategies available to you improves the likelihood for success of your urban
agriculture project. Although urban lands are generally affected by previous activities with impacts on existing soils,
using safe gardening practices and BMPs will control a wide range of contamination issues. Working with your state
environmental agencies to properly addresses risk and, where BMPs are not enough, set cleanup goals, will result
in a garden that brings benefits to the community for years to come.
Additional work continues to describe relationships between plant uptake and contamination, and to begin setting
risk-based criteria for urban agriculture on the state level. ASTSWMO, the Association of State and Tribal Solid
Waste Management Officials, has named urban agriculture standards and practices a priority topic for discussion in
2011, and EPA will continue to work with the states, other Federal Agencies, academics, and other partners as they
examine possible urban agriculture reuse standards. Until more data is available, these Interim Guidelines can be
used to identify types of information needed to make decisions in order to garden safely at a site that has potential
contamination.
BROWNFIELDS AND URBAN AGRICULTURE
-------
UJ
Q
O uj
(/) LL
LU UJ
-------
oo
LiJ
CJ
Alaimo K, Packnett E, Miles RA, Kruger DJ. (2008) Fruit and Vegetable Intake Among Gardeners. Journal of Nutrition Education
and Behavior, 40(2), 94-101
American Planning Association
Creating Community-Based Brownfield Redevelopment Strategies
http://www.planning.org/research/brownfields/
Urban Agriculture: Growing Healthy, Sustainable Places (2011),
http://www.planning.org/apastore/
American Planning Association, Zoning, Practice for Urban Agriculture, March 2010
http://www.urbanfarmhub.org/2010/03/american-planning-association-issues-zoning-guide-for-urban-agricu^^
Agency for Toxic Substances and Disease Registry (ATSDR)
ATSDR Brownfield/Land Reuse Initiative
http://www.atsdr.cdc.gov/sites/brownfields/
Boulding, Russell, and Jon S. Ginn. "Figure 11.7 Land Use/public Supply Well Pollution Potential Matrix." Practical Handbook of
Soil, VadoseZone, and Ground-water Contamination: Assessment, Prevention, and Remediation. Boca Raton, FL: Lewis, 2004.
456-57. Print.
California Fnvironmental Protection Agency, California Department of Toxic Substances Control
Information Advisory: Clean Imported Fill Material (2001)
http://www.dtsc.ca.gov/Schools/upload/SMP_FS_Cleanfill-Schools.pdf
Colorado State University Extension
Choosing the Right Soil Amendment (2005)
http://www.ext.colostate.edu/pubs/garden/07235.html
Cornell Waste Management Institute, Department of Crop and Soil Sciences in the College of Agriculture and I ife Sciences at
Cornell University.
Sources and Impacts of Contaminants in Soils (April 2009)
Guide to Soil Testing and Interpreting Results (April 2009)
http://cwmi.css.cornell.edu/soilquality.htm
-------
Purdue University Cooperative Extension Service, Department of Horticulture
Consumer Horticulture: Container and Raised-bed Gardening (2009)
http://www.hort.purdue.edu/ext/ho-200.pdf
Collecting Soil Samples for Testing (2001)
http://www.hort.purdue.edu/ext/HO-71.pdf
Resource Centres on Urban Agriculture and Food Security
Soil Contamination and Urban Agriculture: A Practical Guide to Soil Contamination Issues for Individuals and Groups (2006)
http://www.ruaf. org/index.php?q=node/1003
Robinson-O'Brien R, Story M, Heim S. (2009). Impact of Garden-Based Youth Nutrition Intervention Programs: A Review. Journal of
the American Dietetic Association. 109(2). 273-280
U.S. Department of Agriculture Agricultural Research Service
Cooperative Extension System Offices
http://www.csrees.usda.gov/Extension/
Chaney RL, et al. (2008) Element Bioavailability and Bioaccessibility in Soils: What is known now, and what are significant data
gaps? Proc. SERDP-ESTCP Bioavailability Workshop, Aug. 20-21,2008, Annapolis, MD. pp. B36 to B-72in Workshop Report.
http://www.serdp.Org/content/download/8236/101212/version/1/file/BioavailabilityJVkshp
Chaney RL, et al. (1984) The Potential for Heavy Metal Exposure From Urban Gardens and Soils
http://indytilth.org/Links/Chaney_Exposure.pdf
U.S. Environmental Protection Agency
Urban Agriculture website:
http://www.epa.gov/brownfields/urbanag.
Urban Farm Business Plan Handbook (2011)
Ecological Revitalization: Turning Contaminated Properties Into Community Assets (2009)
http://www.clu-in.org/download/issues/ecotools/Ecological_RevitalizationJ~urning_Contaminated^
Assets.pdf
The Use of Soil Amendments for Remediation, Revitalization, and Reuse (2007)
http://www.clu-in.org/download/remed/epa-542-r-07-013.pdf
Innovative Uses of Compost: Bioremediation and Pollution Prevention (1997) LU
http://www.epa.gov/osw/conserve/rrr/composting/pubs/bioremed.pdf
Reusing Potentially Contaminated Landscapes: Growing Gardens in Urban Soils (2011) g:
http://www.clu-in.org/download/misc/urban_gardening_fact_sheet.pdf CD
LiJ
University of California Cooperative Extension, I os Angeles Division of Agricultural and Natural Resources g
-------
h
h
z
0.
o
h
Q.
-------
Last Name:
Anderson
Auker
Barni
Basta
Behringer
Belt
Benveniste
Berman
Bildersee
Boyd
Buchanan
Carroll
Caton Campbell
Chaney
Choi
Clayton
Colsman
Cooper
Crause
Cwik
Didier
Doetch
Downing
Doyle
Dufficy
Durnbaugh
Fisher
Foster
Furio
Graham
Grosshans
Harrell
Heberle
Hettiarachchi
Hillman
Jones
King
Koonce
Laberge
Larsen
Lauterbach
Lofton
Long
Mahoney
Mangrum
Martin
McElmurry
Miller
Morrison-Ibrahim
Mysz
Newport
Reichtell
Rhodes
Rock
Scan Ion
Slattery
Spencer
Spliethoff
Sprinkle
Thompson
Valicenti
Van Der Kloot
Weber
Wilkinson
Worthington
Versa vie h
Young
Zautner
First Name:
Ryan
Karla
Marie
Nicholas
David
Shawn
Patsy
Laurel
Jenn
Martha
Susan
Ann
Marcia
Rufus
Chris
Zach
Mark
Dan
Tom
Stephanie
Matt
Ronald
James
David
Joseph
Aaron
Wynecta
Sabrina
Brooke
Dave
Jon
Chris
Lauren
Ganga
Debbie
Edde
Gary
Frances
Kevin
Kelly
Mary
Kerry
P. Wayne
Michele
Linda
Sabine
Shawn
Tom
Deborah
Amy
Bob
Bobbi
Harry
Steve
Joanne
Chris
Diane
Henry
Kristin
David
Lyndon
James
Ford
Bruce
Kimberly
Amy
Mickey
Lilah
Organization:
Delta Redevelopment Institute
The Ohio State University Extension, Cuyahoga County
The Ohio State University
Behr Geo Environmental LLC
Cleveland Botanical Garden
Chicago Botanic Garden
ATSDR
Portland Brownfield Program
Angelic Organics Learning Center
Great Lakes Center for Children's Env Health, UIC
US EPA
Center for Resilient Cities
USDA-Agricultural Research Service
U.S. EPA
Chicago Department of Environment
TetraTech
Chicago Park District
Illinois EPA
USEPA Region 5
USEPA Region 5
Urban Ag Design
City of Cleveland, Department of Community
Development
U.S. EPA
US EPA Region 5
Chicago Department of Environment
E2inc
E2lnc
USEPA
City of Chicago Department of Environment
USEPA
City of Indianapolis
University of Louisville, Center for Environmental Policy
and Managment EFC4
Kansas State Universiy
Illinois Local Food and Farms Coalition
Chicago Department of Environment
Illinois Environmental Protection Agency
Wl Dept of Natural Resources
Chicago Department of Environment
Windy City Harvest Chicago Botanic Garden
US EPA, OSWER, OSRTI
Illinois Department of Agriculture
University Of Kentucky, Cooperative Extension Service
US EPA OSWER OSRTI
U.S. EPA-Region 5
Kansas State University
Wayne State University
Saginaw County Land Bank
IUPUI Dept of Earth Sciences/Public Health
U.S. EPA
U.S. EPA Region 5
Neighborhood Progress, Inc
Growing Home
USEPA
E2lnc.
Delta Redevelopment Institute
U.S. EPA
NYS Department of Health
E2lnc.
Integrated Sustainability Solutions
Chicago Department of Environment
USEPA
Lucas County Improvement Corporation
US EPA Region 5 Pesticides Section
City of Chicago Dept of Environment
Ohio EPA-DERR
US EPA Region 3 - BF/LR
Neighborhood Progress Inc.
Title:
Carbon Program Director
Director
Professor of Soil and Environmental Chemistry
Owner
Urban Farm Manager
Vice President, Community EDucation Programs
Brownfields Coordinator
Program Coordinator
Program Director - Urban Initiative (Chicago)
MD, MPH
Senior Policy Analyst
Milwaukee Director
Senior Research Agronomist
Community Planner
Env. Engineer III
Senior Environmental Scientist
Environmental Manager
Manager, Office of Site Evaluation
Environmental Scientist
Founder
Development Officer
Email Address:
randerson@delta-institute.org
auker.karla@epa.gov
barni.4@osu.edu
basta.4@osu.edu
dbehringer@behrgeoenv.com
sbelt@cbgarden.org
pbenveni@chicagobotanic.org
laberman@cdc.gov
jenn.bildersee@portlandoregon.gov
martha@learngrowconnect.org
sbucha3@uic.edu
carroll.ann@epa.gov
marcia.catoncampbell@resilientcities.org
rufus.chaney@ars.usda.gov
choi.christopher@epa.gov
zachary.clayton@cityofchicago.org
mark.colsman@tetratech.com
dan.cooper@chicagoparkdistrict.com
tom.crause@illinois.gov
cwik.stephanie@epa.gov
didier.matthew@epa.gov
rdoetch@aol.com
jdowning@cleveland.oh.us
Sustainability Coordinator doyle.david@epa.gov
Brownfields and NPL Reuse dufficy.joseph@epa.gov
Deputy Commissioner adurnbaugh@cityofchicago.org
Social and Environmental Equity Project Coordinator wfisher@e2inc.com
Associate sfoster@e2inc.com
program analyst furio.brooke@epa.gov
Environmental Engineer III dgraham@cityofchicago.org
Community Planner grosshans.jon@epa.gov
Brownfield Redevelopment Coordinator charrell@indy.gov
Director lauren.heberle@louisville.edu
Assistant Professor of Soil and Environ. Chemistry
Coordinator
Program Director
Manager, Division of Remediation Management
Natural Resources Supervisor
Environmental Engineer III
Supervisor
Environmental Protection Specialist
Office of the Director
ANR Agent/County Coordinator
Environmental Scientist
Brownfields Project Manager
TAB Director
Assistant Professor
Manager
PhD Student
Environmental Health Scientist
Stormwater Specialist
Sr VPfor Programs
Executive Director
Env. Engineer
Technical Analyst
Senior Director
Environmental Scientist
Research Scientist
Program Manager
Principal
WRD Environmental Project Manager
Land Revitalization Coordinator
Environmental Scientist
Deputy Commissioner
Manager, SABR
Environmental Protection Specialist
Sustainability Manager
ganga@ksu.edu
dlhillman@sbcglobal.net
eddejones@cityofchicago.org
gary.king@illinois.gov
franceskoonce@wi.gov
klaberge@cityofchicago.org
klarsen@chicagobotanic.org
lauterbach.mary@epa.gov
kerry.lofton@illinois.gov
phillip.long@uky.edu
mahoney.michele@epa.gov
mangrum.linda@epa.gov
smartinl@ksu.edu
s.mcelmurry@wayne.edu
saginawlandbank@gmail.com
deemorri@umail.iu.edu
mysz.amy@epa.gov
newport.bob@epa.gov
blr@neighborhoodprogress.org
hrhodes@growinghomeinc.org
rock.steven@epa.gov
jscanlon@e2inc.com
cslattery@delta-institute.org
spencer.diane@epa.gov
hms01@hea It h. state, ny.us
ksprinkle@e2inc.com
dmt@isschicago.org
ly n d o n .va I ice nti @ cityof ch i ca go .o rg
vanderkloot.james@epa.gov
FWeber@LCICOH.com
wilkinson.bruce@epa.gov
kwo rt h i n gto n @ cityof ch i ca go .o rg
amy.yersavich@epa.state.oh.us
young.mickey@epa.gov
lcz@neighborhoodprogress.org
Phone:
312-554-0900x14
312-353-2112
216-429-8200
614-292-6282
216-906-7752
216-645-7798
847-835-6945
312-886-7476
503-823-7764
773-344-7198
312-996-0806
202 566-2748
414-289-7799x3075
301-395-4852
312.353.5006
312-744-3161
303-312-8883
312-742-4287
217-524-1658
312 886 0913
312-353-2112
815-742-3450
216-664-4059
913-551-7667
312-886-1960
312-744-7468
504-390-1707
434-975-6700x256
4402501705
312-744-3639
312-353-5617
317-327-5845
502-852-4749
785-313-7024
847/328-7175
312-746-9773
217/782-0245
4142638697
312-742-0463
847-650-7303
703-603-0330
312-814-4866
502-569-2344
703-603-9057
312-353-2071
785-313-0136
313-577-3876
989-980-1336
317-670-4658
312-886-0224
312-886-1513
216-830-2770 ext 207
773-546-9122
513-569-7149
434-975-6700x253
312-554-0900x21
312-886-5867
518 402 7800
434-975-6700
312.493.4970
312-742-0150
312-353-3161
419-213-4510
312-886-6002
312-744-9139
614-644-2285
386-451-6688
216-702-1423
City:
Cleveland
Columbus
Aurora
Cleveland
Glencoe
Chicago
Portland
Chicago
Chicago
Washington
Milwaukee
Beltsville
Chicago
Chicago
Denver
Chicago
Springfield
Chicago
Milwaukee
Cleveland
Kansas City
Chicago
Chicago
metairie
Charlottesville
westlake
Chicago
Chicago
Indianapolis
Louisville
Manhattan
Evanston
Chicago
Springfield
Milwaukee
Chicago
Chicago
Millersville
Chicago
Louisville
Washington
Chicago
Manhattan
Detroit
Saginaw
Indianapolis
Chicago
Chicago
Cleveland
Chicago
Cincinnati
Charlottesville
Chicago
Chicago
Troy
Charlottesville
Chicago
Chicago
Chicago
Chicago
Chicago
Columbus
Philadelphia
Cleveland
State:
OH
OH
OH
OH
IL
IL
OR
IL
IL
DC
Wl
MD
IL
IL
CO
IL
IL
IL
Wl
OH
KS
IL
IL
LA
VA
OH
IL
IL
IN
KY
KS
IL
IL
IL
Wl
IL
IL
MD
IL
KY
DC
IL
KS
Ml
Ml
IN
IL
IL
OH
IL
OH
VA
IL
IL
NY
VA
IL
IL
IL
IL
IL
OH
PA
OH
BROWNFIELDS AND URBAN AGRICULTURE
-------
------- |