SEPA
United States
Environmental Protection
Agency
Washington, D.C. 20460
Office of Solid Waste and
Emergency Response (5101)
EPA5QO-R-98-OQ1
    July 1998
      Characteristics of Sustainable
            Brownfields Projects
                    Task t Report
              Sustainable Redevelopment
Linking the Community and Business for a Brighter Future

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    Characteristics of Sustainable Brownfields
                           Projects

                        TASK 1 REPORT
                           July, 1998
Prepared for:

U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
Office of Special Projects and Outreach
Washington, D.C.
Contract No. 68-W7-0060
Prepared by:

Platinum International, Inc.
5350 Shawnee Road, Suite 200
Alexandria, VA 22312

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This report was prepared for the  United States  Environmental Protection  Agency, Office of  Solid
Waste and Emergency Response, Outreach and Special Projects Office under EPA Contract No. 68-W7-
0060 by Platinum International, Inc. of Alexandria, Virginia.

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We would like to acknowledge the many individuals who provided the benefit of
their knowledge, insights and observations of the Brownfields process to this
report.  These individuals include EPA and other Federal Agency staff who
were interviewed as a part of this study, local government officials and
Brownfields project personnel who hosted site visits by the project team, and
the many local citizens who participated in discussions of the Brownfields
process.  Their time and efforts are greatly appreciated.

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EXECUTIVE  SUMMARY
                                    The industrial explosion and economic market cycles that our
                                    nation has  experienced during the twentieth century have
                                    combined to  produce one of  the  healthiest  and  most
                                    prosperous societies  in the world today.   However, this
                 growth has  left behind a legacy of abandoned or underutilized  industrial and
                 commercial  properties across the  country that have an assortment of real or
                 perceived chemical contamination problems. These properties have come to be
                 known as "Brownfields."

                     "By  working to  transform Brownfields  into hubs  of economic
                     activity,  we create jobs, new revenue and new opportunity.  These
                     partnerships bring together government, business, and community
                     leaders  and  citizens   to   guarantee   stronger  and   healthier
                     neighborhoods for the 21st century -  places where our children can
                     grow, our families can thrive and the economy is sure to prosper."
                                                          - Vice President Gore, 1998

                 The challenge put before us  by the Vice President demands new approaches,
                 innovative ideas, commitments and cooperation, and a common vision that are
                 tailored to each community's or neighborhood's unique  qualities.  The short-
                 term "use-it-and-leave-it" and "quick-fix" approaches to  development can no
                 longer be tolerated.   Communities,  both  urban  and rural, need  to  make
                 significant advances  toward  sustainability by reusing these Brownfields  assets,
                 and developing processes that help prevent the creation  of more Brownfields

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EXECUTIVE SUMMARY
                  over the  coming  decades.   The  question  then becomes, what exactly is
                  sustainable and how does it relate to the redevelopment of Brownfields?

                  There are  three bodies  of literature  that are quickly growing in their scope and
                  content   —   sustainability,   sustainable   development,   and   Brownfields
                  redevelopment.  However, information that associates the broad-scale, abstract
                  nature  of  sustainability and sustainable development with  the  program  -  or
                  project-level   precision   required  for  Brownfields  redevelopment  efforts  is
                  somewhat  limited.

                  The purpose  of this study therefore, is to provide information to assist and
                  guide  communities, municipalities and other  government organizations  in the
                  planning and  implementation of sustainable Brownfields redevelopment.  The
                  results  of  the study will also assist the U.S. Environmental Protection Agency
                  (EPA) in evaluating the various approaches being taken by communities in order
                  to refine or develop new policies and technical tools that may be needed.

                  As discussed in Chapter One, this study has been organized into two tasks.  The
                  objectives  of Task 1 are to explain the broad concepts  of sustainability and
                  sustainable development; to distill  them  down and associate them with  the
                  Brownfields  redevelopment  process.  This will enable  the  study to establish
                  those  desirable qualities which must be considered by the practitioners at the
                  operational level who are  charged with implementing sustainable Brownfields
                  redevelopment  programs  and  projects.   This  has  been  accomplished by
                  researching a  variety of data sources in order  to identify, define,  and verify the
                  parameters,   elements,   and  characteristics  (PECs)   associated  with  both
                  sustainability and Brownfields redevelopment.  Task 2 will use these parameters,
                  elements,  and characteristics to construct qualitative model frameworks  for
                  successfully implementing sustainable Brownfields redevelopment in urban and

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EXECUTIVE  SUMMARY
                  rural settings.  This report presents the findings of Task 1 exploratory research
                  only.

                  Chapter  Two  describes  the  exploratory research methods  and  descriptive
                  analysis used  to  describe  the  PECs, to  determine  why these factors  are
                  important,  to  explain  how they support  the basic  theory  that  sustainable
                  Brownfields redevelopment is  necessary for success, and to discuss what factors
                  inhibit sustainable Brownfields redevelopment.  These  factors are then verified
                  by association with existing projects  in order to validate, to  a somewhat further
                  degree, the basic theory or corollaries to it.

                  A variety of primary and secondary data sources  were employed in  the study.
                  These  include  literature  and  database  searches, a  detailed   review of  a
                  representative  set  of EPA Pilot Projects, structured interviews with EPA  and
                  other  Federal agency  officials  involved  with  Brownfields  redevelopment
                  activities, and  personal interviews with local officials and on-site representatives
                  involved with  Brownfields efforts in Cape Charles/ Northampton County, VA;
                  Boston, MA;  Chattanooga, TN;  New  Orleans, LA; and, the State  of Rhode
                  Island in Providence, RI.

                  A summary of the study's research and data collection is presented in  Chapter
                  Three. Essentially, the research found that despite the growing use of the terms
                  "sustainability" and  "sustainable development," their interpretation may mean
                  many different things to many different people.  Therefore, these concepts were
                  examined by analyzing the definition of sustainability as a normative process, as
                  an evolutionary process, as context dependent, as it applies to development and
                  self-sustainability, and as  applied to  the challenges to sustainability. The study
                  further identifies  fundamental premises and parameters of  sustainability across
                  the range  from global or  theoretical,  to the  community level, and  for the

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EXECUTIVE  SUMMARY
                 Brownfields  redevelopment process  at  the project level.   The following
                 represents a summary of these fundamental premises.

                 ^  The determination of what is ultimately sustainable is not based on a
                     set of fixed criteria, but will reflect the changing attitudes and values
                     of the individual community as a whole.

                 ^  Because  the  general  principles  of sustainability and  sustainable
                     development  are  not  clearly  understood,  community  outreach,
                     education, and collaboration are critical.

                 ^  Achieving  sustainable   development   at   the   community   and
                     Brownfields  project  levels  will   require   changes   in  the   way
                     communities are planned to create new linkages and balance among
                     the parameters of sustainability.

                 ^  The  Brownfields  redevelopment  process  must  be  a  grass-roots
                     process, rather  than a top-down oriented process, because what is
                     sustainable in one community may not be in another.

                 ^  Sustainable redevelopment should  be concentrated on the broadest
                     range of issues that may affect current and future site conditions.

                 ^  Sustainability  of  the  Brownfields  redevelopment process  is  not
                     dependent upon  an  outcome, but on the manner  in which the
                     community responds  to its economic  and social needs — as  well as
                     the ecological issues.

                 ^  The  risks associated with Brownfields can  be  accommodated and
                     redevelopment  sustained if  the  uncertainties   are  defined  and
                     mitigated.

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EXECUTIVE  SUMMARY
                 The three fundamental parameters of sustainability — ecological, economic, and
                 social sustainability are identified and described as they relate to development on
                 the community and project levels. Also included is a summary of the data that
                 illustrates the various perceptions and understandings of what the sustainability
                 and Brownfields  redevelopment processes are  according to  those  people
                 interviewed.  Based on literature research and the range of responses, a working
                 definition of sustainable  Brownfields  redevelopment is established.   For the
                 purpose  of this  study,   sustainable  Brownfields  redevelopment refers  to
                 redevelopment and growth that are maintained over the long-term and occur
                 within the limits of the environment so that the current needs of the citizens are
                 met without compromising the ability of future generations to meet their needs.

                 The information collected during the exploratory phase of this  study forms the
                 basis for the development of the key elements and their characteristics that are
                 associated with sustainable Brownfields redevelopment.   Chapter Four presents
                 the  analytical results in which  ten key elements associated with sustainable
                 Brownfields  redevelopment  are  identified and described  in  detail.    These
                 elements, and their relationship to the Brownfields process, are summarized in
                 Table ES-1.

                 Although the elements defined are common to the  Brownfields process, they
                 should  not  be considered as requirements  for all  projects.  Depending on the
                 nature  of the site, scope of the  project, and desires of the community, only
                 some of these elements may apply. Likewise, the listing is not all inclusive. New
                 elements may be defined as experience  in developing  Brownfields grows and the
                 time  period over which  these  projects can  be  monitored and evaluated  is
                 extended.

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EXECUTIVE SUMMARY
Table ES-1: Summary of Key Elements Associated with Sustainable Brownfields Redevelopment

Elements
Community Profiling
Comprehensive Community

Organizational Focus and
Structure
Site Identification and
Characterization
Risk Management and
Restoration

Legal/Regulatory Issues
Site Marketing and
Redevelopment

Technology Applications
Project Funding and Finance

Environmental Justice

Effect on Sustainable Brownfields Redevelopment
Sets the foundation for all community decisions and future
growth
Involves, integrates, and commits community participants and
stakeholders to common vision and goals
Integrates the program into the political and administrative
workings of local government
Reduces the risks which influence remediation, financing,
marketing, redevelopment, and regulatory strategies
Addresses the  fears and misconceptions associated with
redevelopment by clarifying uncertainties and balancing benefits
with costs
Prescribes requirements for property transfer and utilization, as
well as liability of owners, operators, lenders, buyers, and
municipal government
Highlights the importance of balancing economic, social and
ecological factors of land use with  focus on community needs
and future generations
Increases cost  benefits and quality of life as new technologies  are
identified, developed and integrated
Provides the fiscal basis to initiate programs/projects and ensure
their continued operation until market forces take over
Ensures environmental equity, equitable costs and equitable
benefits for the community and stakeholders

                 The  analysis  also  considers  the factors  of  sustainability  and  sustainable

                 development,  as well as the  specific  activities  involved  in  the Brownfields

                 redevelopment process at the  local level, in order to derive and describe the

                 various characteristics that are associated with the above elements, how these

                 characteristics have  been applied - successfully and  unsuccessfully in various

                 situations or scenarios, and what barriers may exist with their implementation.

                 These characteristics are  highlighted  in  Table ES-2 and discussed in Chapter

                 Four.

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EXECUTIVE  SUMMARY
       Table ES-2: Characteristics of Elements Associated with Sustainable Brownfields
Elements
Community Profiling
Comprehensive Community
 Planning
Organizational Focus
and Structure
Site Identification
and Characterization
             Redevelopment

Characteristics
    Develop environmental baseline inventory for future ecosystem management
    Estimate natural resource consumption limits
    Incorporate important landscape and attractive community features
    Associate ecological assets with community values
    Define the composition and character of the community
    Understand the socio-cultural influences and needs that promote stability
    Preserve natural, cultural, and historic resources for inter-generational
    continuity
    Develop a sense of community self-reliance
    Determine the economic basis of the community and climate for investment
    Recognize the skills and knowledge of the community labor force
    Develop private-public partnership
    Incorporate community concerns into the decision-making processes
    Integrate the regional ecosystem(s) perspective
    Include "Best Practices" for sustainability
    'S   Develop a comprehensive approach to all concerns
    'S   Identify the carrying capacity of the ecosystem
    'S   Establish urban growth boundaries
    'S   Determine current and planned surrounding land use
    'S   Promote the potential benefits for minimizing automobile use
    'S   Determine economic self-sufficiency
    'S   Depend on community-stakeholders' consensus
    'S   Identify uncertainties and build-in flexibility in planning options
    'S   Equalize benefits and burdens for the community and stakeholders
    Emphasize need for strong community and public leadership
    Include all project stakeholders and concerned or interested citizens
    Centralize local government coordination, point-of-contact, and authority
    Integrate all public and private resources
    Determine which party is best to initiate and perform the site <
    Obtain accurate ecological information
    'S   Delineation of site characteristics
    'S   Representation of nature of contamination
    'S   Site assessments
    'S   Integration of assessments, audits and inspections
    'S   Identification of groundwater contamination
    'S   Create continuous updating procedure
    'S   Use of technical resources available
    Assess the redevelopment potential of the site
    'S   Adjacent land owners  and uses
    'S   Cooperation of the owner
    'S   Cost of remediation
    'S   Socioeconomic conditions of the community
    'S   Transportation and infrastructure
    'S   Attractive natural or historic features
    'S   Current economic conditions
    Illustrate the basis of prioritizing the site over other candidate :
    'S   Site prioritization schemes
    'S   Multi-level screening process/prioritization model
: characterization

















e sites

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EXECUTIVE  SUMMARY
Table ES-2: Characteristics of Elements Associated with Sustainable Brownfields Redevelopment (Continued)

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EXECUTIVE   SUMMARY
Elements
Risk Management and
Restoration
Characteristics
•   Identify and clarify the barriers to effective risk management
    'S   Lack of communication and coordination with stake holders
    'S   Reluctant or hesitant stakeholders
    'S   Community priorities and objectives
    'S   Incomplete or inaccurate site characterization
    'S   Threat of contamination spread
    'S   Long-term remedial approaches
    'S   Government policy and requirement changes
    'S   Loss of market opportunity window
    'S   Contingent risks of owners /developers
•   Address the community concerns
    'S   Relate scientific results and risks to community understanding
    'S   Inform the public  of issues critical to their interests
    'S   Empower the public to act with respect to the risk communicated
•   Address the project participant concerns
    'S   Reluctance to participate and liability indemnification for current owner
    'S   Return on investment and risk factors/perception for buyer & developer
    'S   Borrower circumstances and property value maintenance for lender
•   Identify the tools for Risk Management
    'S   Project organizing
    'S   Federal and State agency roles
    'S   Use risk based corrective actions based on future uses
    'S   Identify property ownership alternatives
               institutional controls and insurance
Legal/Regulatory Issues
Site Marketing and
Redevelopment
    CERCLA
         "Joint and Several Liability"
         SARA, 1986
         EPA Guidance, 1992
         "Covenant not to Sue"
         "Prospective Purchase Agreements"
         CERCLA Amendment, 1996
         "Comfort Letter Policy"
         "Secured Lenders and Fiduciaries" protections
    RCRA, Clean Air Act, Clean Water Act, Toxic Substances Control Act, etc.
    Promote program factors
    'S   Community expectations
    'S   Rationality and incentives
    'S   Ownership
    'S   Program life cycle
    'S   Control of development
    Promote ecological factors
    'S   Eco-Industrial parks
    'S   Reclaimed Brownfields for parks and open spaces
    'S   Green space and open space as interim use
    'S   Reclaimed Brownfields in ecologically sensitive areas
    'S   Landscape design considerations
    Promote socioeconomic factors
    'S   The right property
    'S   The right use
    'S   The right incentives
    Site Marketing
    'S   Sites as community assets
    'S   Role of prevailing market forces
    'S   Market or feasibility analyses

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EXECUTIVE  SUMMARY
Table ES-2: Characteristics of Elements Associated with Sustainable Brownfields Redevelopment
(continued)
                               Characteristics
Elements
Technology Applications
Project Funding/Finance
                               •
Environmental Justice
                                   Energy Technology
                                   'S   Reducing energy demands
                                   'S   Renewable energy
                                   Environmental Technology
                                   'S   Industrial Ecology
                                   'S   Eco-Industrial parks
                                   'S   Pollution prevention and waste minimization
                                   'S   Site assessments and remediation
                                   'S   Ecological monitoring and assessment
                                   Transportation Technology
                                   'S   Intelligent Transportation Systems (ITS)
                                   'S   Alternative fuels and vehicles
                                   Telecom/Information Technology
                                   ^   Geographic Information System (GIS)
                                   Public Safety Technology
                                   Redevelopment processes requiring funding
                                   */   Site characterization and remediation
                                   */   Planning, public outreach and design approval
                                   */   Development and reconstruction
                                   */   Long term operational support
                                   Public Sources of funds, primarily for the initial stages of the project
                                   S   Federal - EPA, HUD, DOT, DOC, SBA
                                   */   State — environmental or economic agencies, tax programs, loans
                                   */   Local — incentive programs, tax increment financing programs, grants
                                   Private Sources of funds
                                   */   Property owners or other responsible parties
                                   */   Prospective purchasers or developers
                                   */   Equity investors
                                   */   Commercial banks

                                   Early, adequate and meaningful community involvement in decision making
                                   Stakeholders who are committed to effecting a change for the better
                                   Equal access to all information relating to the redevelopment
                                   Willingness to negotiate to achieve a win-win situation
                                   Environmental equity, equitable costs and equitable benefits for all
                     Further,  throughout  the  discussion  of  these  elements  and  characteristics,
                     distinctions have been pointed out regarding their application to urban and rural
                     projects.  In general, all the parameters  and  elements apply to both urban and
                     rural projects.  However, significant differences occur between these two types
                     of projects with respect to which characteristics may apply and to what degree.

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EXECUTIVE  SUMMARY
                 Because of the limitations inherent to this study (discussed in Section 2.3), and
                 because the  primary  sources  of data  are  based on individual perspectives,
                 opinions, and experiences, every effort was made during the site visits to verify
                 the elements and characteristics  collected with at least more than  one  other
                 source.   In addition,  eight municipal Brownfields  coordinators were queried
                 about the key elements and applicability of the characteristics.

                 All eight municipalities confirmed  the importance and applicability of the  ten
                 key elements, although the actual degree to which the elements apply varies in
                 relative  importance on  a site-by-site basis.   The respondents  also  provided
                 descriptions and explanations of many of their processes, some of which  are
                 common to all Brownfields projects.  However, some of these descriptions also
                 reflect unique approaches to  addressing some of  the key characteristics  of
                 sustainability associated with Brownfields.   Table ES-3  below summarizes  the
                 key  elements  and  those  additional  characteristics  verified through  the
                 municipality interviews.

L      TABLE ES-3: SUMMARY OF CHARACTERISTICS VERIFIED BY
                                 MUNICIPALITIES
   Community Profiling
   •   Community vision is more critical than historical information
   •   Market analysis is a key component
   •   Ecological baseline  data not as relevant to urban/suburban communities as it is to rural
   Comprehensive Community Planning

   •   The variety of plans  need to be integrated  so their components  support each other and
       make sense for the community
   •   A mechanism or strategy for continual or periodic updating should be included
   Organizational Focus and Structure

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 EXECUTIVE  SUMMARY
     •  Brownfields  are  best  addressed  by  the  local  economic  development  and  planning
        departments with environmental functions
     •  All  business  loans,  grants,  municipal funding,  and financial  partnerships  should be
        coordinated through the same point-of-contact
     •  Technical, legal and financial expertise should be  integrated into  the local organization to
        retain responsibility, credibility and ownership of decisions and outcomes
     •  Close collaboration with State and Federal regulatory officials is critical to timely and flexible
        interpretation of project requirements
     •  Academic institution resources are cost effective, able to provide unique technical support,
        and provide on-the-job  training opportunities to students

     Site Identification, Characterization & Prioritization

     •  Sites that have existing end-users or potential developers should be a prime focus

     b*  Regional  prioritization  of sites not feasible where crossing  of political  jurisdictions is
        involved — unless respective jurisdictions participate and support the process
     L*  Legislative incentives  to entice private property owners to participate — especially non-local
        owners — are needed
     •  All project information  should be centrally available for quick and reliable access

     Risk Management and Remediation

     •  State legislation that deals with clean-up levels and release from liability is critical

     •  Deed restrictions and environmental covenants are  effective institutional controls at  local
        level
     •  Community involvement should be managed so the  community does not use the vector of
        potential  health risk  to force greater demands on owner/potential  developer  than are
        economically feasible
     •  Extended timeframes for Brownfields redevelopment pose greater financial risk to  rural
        communities dependant on short-term grants or limited funding capabilities
     •  Caution should be used to avoid increasing community optimism that the project will create
        jobs — especially when fewer jobs, different skill level jobs, or long delays in the project may
        occur
     •  Environmental liability insurance is an increasingly feasible tool to manage risk
•I
Legal/Regulatory Issues

•   Mechanisms for municipal liability release are needed especially for municipalities forced to
    assume ownership due to foreclosure, abandonment, or eminent domain
•   Less stringent liability and more flexibility is needed for Brownfields which are generally a
    less serious health threat than Superfund sites

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EXECUTIVE  SUMMARY
    Site Redevelopment and Marketing

    •   Development or redevelopment follows certainty in the economic marketplace

    •   Market demands can pose greater barriers than availability of project funding

    •   Organized marketing programs in rural communities are not sustainable without long-term
       grants
    •   Brownfields properties should not be marketed or advertised as "Brownfields"

    •   Building on  historical  and natural resources  develops permanence  and  continuity of
       development among generations

    Technology Applications

    •   Community needs to identify and trust proprietary remediation technologies

       Transportation  infrastructure  needs to  be tailored to  meet changing land uses  and to
       provide better public amenities

    Funding/Financing

    •   Best to integrate assessment and clean-up costs into overall redevelopment financing plan

    •   Lack of certainty in  cost of remediation important barrier or risk

    •   Cost/benefit models  are very complicated and  only useful  if they are designed  for  site-
       specific conditions or situations
    •   Ultimately, private financing based on market driven economy will sustain process

    •   Resale value of the  property after clean-up is generally less in rural areas than the cost of
       clean-up and regional market values
    •   Rural communities  need  financial  assistance with  infrastructure installation in order to
       promote redevelopment of sites

    Environmental Justice

    •   The biggest problem is lack of understanding about what environmental  justice means

    •   The emphasis should be on addressing the community's overall needs


                 In  conclusion,  this  Task 1  report  presents the parameters,  elements,  and

                 characteristics  that are  qualitatively  associated  with  sustainable Brownfields

                 redevelopment projects.  Through extensive research,  the  study establishes a

                 working definition  of sustainable Brownfields redevelopment and examines the

                 abstract  concepts of sustainability and sustainable development. This is done to

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EXECUTIVE SUMMARY
                  operationalize these concepts at the project level. By associating the fundamental
                  premises and parameters of sustainability with the detailed characteristics of a
                  Brownfields redevelopment process, a series of key elements and their respective
                  characteristics have been  identified, defined and  verified.  These parameters,
                  elements  and  characteristics will be  organized, and  various  relationships
                  established, in the subsequent phase of the study, in  order to  construct model
                  frameworks of successful and sustainable Brownfields redevelopment.

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TABLE  OF  CONTENTS
                Jf  *
Executive Summary	i
Table of Contents	xiv
List of Appendices	xvi
List of Figures	xvii

1.0 Introduction 	1
       1.1 Purpose and Scope	1
       1.2 General Overview of the Brownfields Initiative	2

2.0 Analytical Approach	7
       2.1 Method of Analysis	7
       2.2 Description of Analyses Performed	9
              2.2.1 Primary Data Sources	10
              2.2.2 Secondary Data Sources	11
              2.2.3 Pilot Project Case Studies	11
       2.3 Analytical Limitations and Controlling Assumptions	13

3.0 Summary of Data Sources	17
       3.1 Overview of the Sustainable Development Concept	19
              3.1.1 Definition of Sustainability	21
              3.1.2 Sustainability at the Community Level	33
              3.1.3 Sustainability at the Project Level	47
       3.2 Overview of the Brownfields Redevelopment Process	51
              3.2.1 Secondary Data Sources —Literature and Database Review	51
              3.2.2 Primary Data Sources — Structured Interviews with
                   EPA and other Federal Agencies	66
              3.2.3 Primary Data Sources — Structured Interviews with On-Site
                  Municipal Officials and Project Stakeholders	70

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TABLE  OF CONTENTS
              3.2.4 Brownfields Pilot Project Case Analysis	84

4.0 Analytical Results	101
       4.1 Parameters, Elements and Characteristics of Sustainable
          Brownfields Redevelopment	101
              4.1.1 Community Profile	102
              4.1.2 Comprehensive Community Plan	108
              4.1.3 Organizational Focus and Structure of the Brownfields Program	120
              4.1.4 Brownfields Site Identification, Characterization, and Prioritization	127
              4.1.5 Risk Management and Site Restoration	139
              4.1.6 Legal/Regulatory Issues	154
              4.1.7 Site Marketing and Redevelopment Approach	161
              4.1.8 Technology Applications	174
              4.1.9 Project Funding/Finance	183
              4.1.10 Environmental Justice	192
       4.2 Verification of Identified PECs	196

5.0 Conclusion	207

References     	I

Appendix A   	A-l
Appendix B   	B-l
Appendix C   	C-l
Appendix D   	D-l
Appendix E   	E-l
Appendix F   	F-l
Appendix G   	G-l

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APPENDICES
APPENDICES
              Appendix A      List of Acronyms
              Appendix B      Glossary of Terms
              Appendix C      Summary of Brownfields Pilot Projects Analyzed
              Appendix D      Summary of Program Information Sources
              Appendix E      Summary of EPA and Federal Agency Interviews
              Appendix F      Summary of On-Site Interviews
              Appendix G      Local Contacts for Brownfields Projects Cited in this Report

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LIST  OF  FIGURES
          ES-1 Summary of Key Elements Associated with Sustainable Brownfields Redevelopment







          ES-2 Characteristics of Elements Associated with Sustainable Brownfields Redevelopment







          ES-3 Summary of Characteristics Verified by Municipalities







          2.1    Basic Theory Testing Approach







          2.2    Conceptual Model Framework for Sustainable Brownfields Redevelopment







          3.1    Principles of Ecosystem Management







          4.1    Typical Stakeholder Configuration for a Brownfields Redevelopment Program







          4.2    Matrix Characterization of Brownfields Sites







          4.3    Evolution of Brownfields Environmental Liability







          4.4    Summary of Characteristics Verified by Municipalities







          5.1 Key Elements Associated with Sustainable Brownfields Redevelopment







          5.2 Characteristics Associated with Elements of Sustainable Brownfields Redevelopment

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CHAPTER  1
INTRODUCTION
                                                                       INTRODUCTION
                                                                         Purpose and Scope
                                                                         General Overview
                                    The factors upon which the long-term viability of redeveloped
                                    Brownfields depend have neither  been adequately  defined
                                    nor quantified in model frameworks that can be used by the
                  U.S.  Environmental Protection Agency  (EPA)  to assess  and  support  the
                  sustainability  of Brownfields  environmental restoration  and  socioeconomic
                  development.   In  addition, the  concepts  of sustainability  and  sustainable
                  development are not fully understood  by the general public  — especially with
                  regard to their application to community development and economic growth.
                  The overall purpose of this project is to provide information to assist and guide
                  communities, municipalities and other government structures in  the  planning
                  and implementation of sustainable Brownfields redevelopment.  This study will
                  also provide  the  EPA with  model frameworks for the  evaluation  of Pilot
                  program results and predictive criteria for the success of sustainable Brownfields
                  Pilot Projects.

                  For the purpose of this study, a sustainable Brownfields project is defined as one
                  in which redevelopment  and growth are maintained over the long-term and
                  occur  within  the limits of the  environment so that the  current  needs  of the
                  citizens are met without compromising the ability of future generations to meet
                  their needs.   This study explains  the derivation  of this definition from the

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CHAPTER  1
INTRODUCTION
                  theoretical concepts of sustainability and sustainable development, to how they
                  are applied on an operational level.

                  This  study has been organized into two tasks.  The objective of Task 1 is to
                  identify, define, verify,  and quantify, if possible, the parameters,  elements, and
                  characteristics that are indicative  of successful and unsuccessful Brownfields
                  sustainable   redevelopment.   Task  2  involves  using  those  parameters,
                  characteristics and elements to create the links or relationships needed to build
                  model  frameworks  that can be  used  by  the EPA to evaluate  and support
                  potential  scenarios  for Brownfields  cleanup,  environmental restoration,  and
                  redevelopment.   Where the data allows, model frameworks for Brownfields
                  redevelopment in an urban and  rural setting will be developed.  This  report
                  presents the findings of Task 1 research only.

                  The  remainder of  this chapter  establishes  the  context  for the  report  by
                  presenting an overview of the Brownfields initiative and EPA Pilot Projects,
                  which were central to this  study.  Chapter 2.0 describes the analytical approach
                  used  to obtain and verify  the data, and the assumptions  inherent to the study
                  approach.  Chapter 3.0 presents a summary of the findings of the research into
                  the concepts of sustainability and the Brownfields redevelopment process.
                  Chapter 4.0 explains the parameters, elements and characteristics  of sustainable
                  Brownfields  redevelopment that have been identified through the research and
                  discusses the results of their verification.  Chapter 5.0  summarizes the general
                  premises, elements,  and characteristics  that are recommended to promote the
                  success of sustainable Brownfields redevelopment.
                 The dynamics of an industrial economy, and even information and service-based
                 economies, produce cycles  of business expansion, stagnation, and  decay.  In

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CHAPTER  1
INTRODUCTION
                  industrial based economies, at the lowest phase of these  cycles, facilities  that
                  once housed vibrant manufacturing  activities  are often abandoned  leaving
                  dormant, contaminated sites.

                  A report by the U.S General Accounting Office (GAO, 1987)  estimated as many
                  as  425,000  former  industrial  and  commercial  sites  potentially  containing
                  hazardous waste may exist throughout the nation.  To date,  most of these
                  abandoned or underutilized facilities have  been in the  more populous urban
                  areas.   Subsequent  shifts of resources such as  industries,  wealth, levels of
                  knowledge, technical expertise, and creativity out of these urban areas have been
                  identified as the root cause for environmental degradation and loss of economic
                  viability, all of which impact negatively on the quality of human life.  Efforts by
                  the EPA and the states to investigate these sites indicated that either many were
                  only perceived as being contaminated based on prior use, or  had insufficient
                  levels  of contamination  to require a  CERCLA  (Comprehensive  Emergency
                  Response, Compensation, and Liability Act of 1980; generally referred to as
                  "Superfund")  response action.  Unlike the undeveloped greenspaces  that are
                  highly viable  for economic development, these  sites have become known as
                  "Brownfields," and are viewed by  many community residents as liabilities and a
                  hindrance to development.

                  The EPA defines Brownfields as "abandoned, idled, or underused industrial and
                  commercial facilities where expansion  or redevelopment is complicated by real
                  or perceived environmental contamination" (Fields, 1995).  For the purposes of
                  this  study, Brownfields are further  defined as those sites  containing chemical
                  contamination subject to CERCLA.  Under current Federal legislation, only the
                  worst of these sites qualify for Federally-funded remediation. The challenge to
                  the EPA, states, and local communities is how to ensure the public  health and
                  the environment can be protected  while placing the majority of these remaining
                  sites back into productive use  for economic development by local communities.

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CHAPTER  1
INTRODUCTION
                 The question that needs to be asked is, "How can these properties be converted
                 from local liabilities into lasting community assets?"

                 On  January 25, 1995,  EPA Administrator  Carol  Browner announced  the
                 "Brownfields Action Agenda" that outlined the Agency's activities and plans to
                 help  communities implement and realize the potential value and benefits  of
                 Brownfields  sites to economic redevelopment.   The EPA recognized that
                 Brownfields  cleanup  and  redevelopment involve a different paradigm from
                 existing environmental compliance programs and addressing these  sites raises
                 cross-cutting issues that involve  a wide variety of organizations, programs, and
                 resources.    The  principle objectives  of the  Brownfields  initiative   are  to
                 encourage assessment, environmental  cleanup  and restoration, and  economic
                 redevelopment of those sections  of our nation most devastated by the decay and
                 associated economic losses caused by Brownfields, and to rectify concomitant
                 environmental inequalities and human health impacts that have evolved.

                   Brownfields Action Agenda - General Policy Areas
                      Brownfields Pilot Program Grants
                      Clarification of Liability and Cleanup Issues
                      Partnerships and Outreach
                      Job Development and Training
                 The efforts outlined in the Brownfields Action Agenda were designed to help
                 identify and clarify approaches to these objectives by focusing on four general
                 policy areas.
                 Brownfields Pilot Project Grants - designed to develop and test redevelopment
                 models,  direct efforts toward  removing  regulatory barriers, and to facilitate
                 coordination among public and private organizations at the  Federal, state, and
                 local levels.

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CHAPTER  1
INTRODUCTION
                  Clarification of Liability and Cleanup Issues - intended to clearly state EPA's
                  decision when  to use its enforcement discretion, and to collaborate with states
                  and localities to develop and issue guidance regarding liability associated with
                  these sites.

                  Partnerships and Outreach - committed EPA  to building partnerships with
                  Federal, state and  local representatives  of organizations in order to develop
                  strategies for promoting public  participation and  community involvement  in
                  Brownfields  decision-making.

                  Job  Development  and  Training  -  geared  toward  fostering  workforce
                  development through environmental  education  programs,  recruiting students
                  from disadvantaged communities, providing worker training, and  creating job
                  opportunities for local residents near Brownfields  sites.

                  Concurrent with implementation of the Brownfields Action Agenda, two other
                  key initiatives and campaigns were rapidly developing that spurred new ideas and
                  approaches directly related to Brownfields economic  redevelopment.   These
                  were the  United  Nations  Agenda 21,  a global action plan for sustainable
                  development, and President Clinton's  Community Empowerment Agenda, that
                  established the National Urban Policy to promote sustained national  economic
                  growth.   These  national  and  international  initiatives are  promoting the
                  development of  an all-encompassing  framework of values,  policies,  and
                  processes to help  guide communities  in their Brownfields redevelopment and
                  community revitalization efforts.

                  The EPA's Brownfields Economic  Redevelopment Initiative, as outlined in the
                  Brownfields  Action Agenda, is designed to assist  states, communities,  and other
                  organizations or individuals in assessing, cleaning  up,  sustainably  reusing and
                  preventing future Brownfields. The EPA recognizes that a major impediment to

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CHAPTER  1
INTRODUCTION
                  enduring  environmental  and  economic  health  is  the  inability  to  achieve
                  sustainable redevelopment.  Therefore, the ultimate success of the Brownfields
                  initiative   is  contingent upon  a  project's  ability  to  stimulate  sustainable
                  environmental restoration and economic development.

                  As part of the national Brownfields initiative, the EPA has "awarded cooperative
                  agreements to states, cities, towns, counties, and tribes  to demonstrate Pilots
                  that test Brownfields assessment models, direct special efforts toward removing
                  regulatory barriers without sacrificing protectiveness,  and facilitate coordinated
                  public  and private efforts  at  the  Federal,  state and local  levels"  (USEPA,
                  1996(a)).    These Pilot Project grants  are  intended  to be a catalyst to  the
                  sustainable redevelopment  of  Brownfields  sites.   This  is accomplished by
                  providing public funds to stimulate local government organizations into creating
                  the impetus  and maintaining control of the  project process and  outcomes,
                  providing technical support during the  early stages of a project, and inducing
                  private capital investment. By addressing these  crucial needs through a series of
                  demonstration Pilot Projects, the agency is striving to develop the knowledge,
                  experience, and  public  confidence  required  for continued implementation of
                  future Brownfields projects at the local community level.

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CHAPTER  2
ANALYTICAL APPROACH
                                                                         ANALYTICAL
                                                                          APPROACH
                                                                         Method of Analysis
                                                                         Description of Analysis
                                                                         Analytical Limitations
                                     This study is designed to analytically construct  a  conceptual
                                     model     framework    for    sustainable    Brownfields
                                     redevelopment projects.  This first phase, or Task 1, uses a
                  series  of data  sources  to  clarify  key  concepts such as  sustainability and
                  sustainable  development,   and  to   identify  the parameters,  elements  and
                  characteristics (PECs) indicative  of sustainable,  urban and  rural Brownfields
                  redevelopment projects.
                  In general, Task 1 of this study employs a theory testing approach (see Figure
                  2.1) to examine the  conceptual proposition that Brownfields redevelopment is
                  sustainable.   To accomplish this, the study seeks to "operationalize"  the key
                  concepts  of sustainability and Brownfields redevelopment by collecting and
                  analyzing relevant data through descriptive and exploratory research methods.
                  The research data will be used to identify and define those PECs, or factors, that
                  contribute to sustainable redevelopment of Brownfields, determine  why those
                  factors are important, explain how they support the  basic theory, and describe
                  what factors inhibit  sustainable Brownfields redevelopment.  These  factors are
                  then verified by correlation with existing projects in  order to validate the basic
                  theory, or identify corollaries to it.

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CHAPTER  2
ANALYTICAL  APPROACH
Figure 2.1: Basic Theory Testing Approach
       VALIDATE
     PROPOSITION
            THEORY:
       Sustainable Brownfields
         Redevelopment is
            Successful
                                         THEORY
       MODIFY
THEORY/PROPOSITION
                              ANALYZE
                                DATA
  TESTABLE
PROPOSITION
                  COLLECT
                   DATA
                       Elements &
                      Characteristics
                   TESTABLE PROPOSITION:

             Three parameters of sustainability are common
               to all project elements and characteristics
                       •   Ecological
                       •   Economic
                       •   Social

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CHAPTER  2
ANALYTICAL  APPROACH
                  fundamental theory of sustainable Brownfields redevelopment.
  Figure 2.2: Conceptual Model Framework for Sustainable Brownfields Redevelopment
                                                    Sustainable Brownfields
                                                      Redevelopment
  Description of
 nalyses Performed
     Primary
   Data Sources
    Secondary
   Data Sources
   Pilot Project
   Case Studies
              Tipnon of Analyses Performed
                  The analytical objective  is to obtain information  from the
                  various  sources  of data  to identify,  define,  and  where
                  reasonably  possible, quantify those  PECs  deemed  to  be
                  indicative  of sustainable Brownfields  redevelopment.  The
                  analysis  is  intended  to  describe  the  PECs as  they are
                  associated with a  sustainable  Brownfields  redevelopment
                  project  and  to  differentiate  between  rural  and  urban
community projects, where applicable.
                  The study originally focused on a series  of data sources that were specifically
                  prescribed by the EPA.  The  source  data list was refined through the use of
                  several  screening criteria.   These  include  the  timeliness,  availability,  and

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ANALYTICAL  APPROACH
                  applicability of the information; the pertinent roles that designated individuals
                  contributed to  the  Brownfields   process;  and  the  general  ability  of the
                  information to cover a broad  range of variables, as opposed  to an  in-depth
                  analysis of any single one.  As  the research progressed, additional data sources
                  had to be included in order to obtain sufficient data to cover the full range and
                  objectives of the study.
2.2.1   PamatyDataSoufOES
                  The primary data sources consist of structured personal interviews and on-site
                  data collection. Interviews were conducted with designated EPA officials from
                  various  Headquarters program offices and regional Brownfields  coordination
                  offices;  senior officials from five  Federal agencies participating in the National
                  Action  Agenda Partnership   (DOD,  DOT, DOE, HUD,  GSA), and local
                  stakeholders actively involved  with Brownfields  redevelopment efforts in Cape
                  Charles  (VA), New  Orleans  (LA), Boston  (MA), Chattanooga (TN), and the
                  State  of Rhode  Island's Pilot Project in  Providence.  In addition,  eight
                  municipalities were surveyed by telephone interview for verification of the data.

                  Based on reviews of secondary data sources and the EPA Pilot Projects database
                  (IRM, 1997),  a preliminary list of questions to guide the interview process was
                  developed by members of the project team. The list entailed pertinent issues
                  ranging  from abstract concepts to specific applications in order to identify:  1)
                  recurring  elements   and  characteristics;  2)   variables  in  the   element's
                  characteristics  caused by case-specific factors or an individual's perspective and
                  context;  and  3)  those  concepts  and variables  that  would require  further
                  definition.  These questions were initially tested  and refined to  facilitate the
                  actual interview process.  The questionnaire was  further refined to tailor the
                  interview  process  toward  categories  of  information most  pertinent  to the
                  interviewees'  area  of specialty or role in  the  Brownfields  program/project.
                  Interviews were generally conducted by two or three project team members and
                                             10

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CHAPTER  2
ANALYTICAL  APPROACH
                  were either in person or by telephone, depending on the person's availability and
                  proximity to the Washington,  D.C. metropolitan  area.   Each interview  was
                  planned to last for one  hour.   Detailed notes  were prepared following each
                  interview or site visit.  From the detailed notes, a summary  of the personal
                  interviews for all the EPA and Federal  officials was prepared and is included in
                  Appendix E.   Summaries of  personal  interviews with  local representatives
                  developed from the site visits are included in Appendix F.

                  In addition to the interviews of local project participants, background literature
                  was collected and analyzed to clarify or support interviewee's  comments.
222  SeomdatyData. Sources
                  Secondary  data  sources  consist  of Brownfields  program information  from
                  government and private literature  and database  materials;  and  published
                  literature pertaining to international projects, eco-sustainability, socioeconomic
                  planning, and  sustainable development efforts.  A list of the EPA-prescribed
                  program information sources  used is  contained in Appendix  D.  Additional
                  literature sources were added  during the research in order to supplement the
                  program information sources and are included in the Bibliography.
223   PHotPtojectCase Studies
                  Pilot Project case studies were derived from a review and detailed analysis of 15 of
                  EPA's 157 Brownfields Assessment Demonstration Pilots.  At the time the study
                  was conducted, the total number of Pilot Projects was 115. This group represents
                  the baseline for the analysis.  An additional 42 grants have been awarded by EPA
                  since the data for this study were compiled.  The existing portfolio of the EPA "Pilot
                  Projects"  was considered  initially as one of the primary sources of data for the
                  analysis proposed as a part of this report.  The information pertinent to each Pilot
                  Project was to be obtained through the EPA Brownfields Management System that
                                             11

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CHAPTER  2
ANALYTICAL  APPROACH
                  incorporated reports submitted by each Pilot Project.  Experience developed during
                  the design and implementation of these projects was considered to be important for
                  the purpose of identifying and defining the characteristics, elements, and parameters
                  indicative of successful and unsuccessful Brownfields.

                  Unfortunately, it was not possible within the budget and time constraints  of this
                  report, to conduct a detailed analysis of all 115 projects existing at the time of
                  this study.  It was found necessary to select from this larger group,  a subset that
                  represented specific examples of successful cleanup, environmental restoration,
                  and economic vitality. To select these specific projects, a screening process was
                  developed  to identify those  Pilots that had the greatest potential for providing
                  information on the broadest range of Brownfields issues and concerns.

                  Ideally, the selection process for  this analysis should be based on a random
                  sampling of the 115 existing Pilots.  This would increase the probability of
                  capturing the largest possible subset of variations in program approach and
                  outcome.   However, since this  review  of  existing  EPA Pilot Projects was
                  exploratory in nature and concentrated on identifying specific characteristics and
                  confirming their association with successful Brownfields redevelopment projects
                  and their  correlation with project sustainability, statistical reliability was less
                  important  than  analytical  validity.   As  a  result, the  selection criteria for the
                  projects to be studied are more qualitative than statistical in nature.

                  As the study plan was  established, a smaller group of 25 Pilot Projects   (both
                  national  and  regional)  was  selected from the  total  number of  115  projects
                  through a multi-step screening process. This group  of 25 Pilots was then further
                  screened for relevance to the analytical objective with 15 of those projects finally
                  selected  for detailed study  and inclusion in this  report.  The result  of this
                  screening process is that for this  study,  25 Pilot Projects,  or 22%  of the total
                  Brownfields Economic Redevelopment  Initiative awards as of November 1997
                                              12

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CHAPTER  2
ANALYTICAL APPROACH
                  were the subject of extended review.  Fifteen of those projects, or 13% of the
                  total, were screened for detailed analysis.

                  Because four of the five  projects designated for site visits:  Cape Charles, VA;
                  Boston, MA;  the  State  of Rhode Island;  and New  Orleans,  LA,  are  also
                  Brownfields Pilot Projects  (Chattanooga, TN is not),  they  were automatically
                  included in the final list of 15 projects  in advance of the screening process. This
                  ensured consistency of data elements and characteristics collected from among
                  each of the project-related data sources.

2.3

                  In order to meet the  goals  and objectives  of the  study within the constraints
                  established  by its  scope,  a  set of study limitations was recognized and  certain
                  controlling assumptions were necessary.

                  In building a model framework, the ultimate validity and accuracy of the model
                  framework will  be directly  dependant  upon identifying, to  the greatest extent
                  possible, all scenario variables  and the full range of interactions among those
                  variables.   The broader  the survey of data,  the  greater the  probability that
                  potential "outlying variables" are considered.  Likewise, the greater the detail of
                  data that  is available  for analysis,  the better the interactions, functions and
                  predictive outcomes will be understood. Because Task 1 is an exploratory study,
                  the emphasis of the data  collection techniques employed is to capture as much
                  information as  possible  regarding the broadest range of variables  that  may
                  influence the success or sustainability of a Brownfields redevelopment analysis.
                  The intent is to maximize the  likelihood of identifying all the possible outlying
                  variables.
                                              13

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ANALYTICAL APPROACH
                  Although the method of data collection is systematic in approach, the selection
                  of data sources and subject sites  for analysis is  not the result of a  statistically
                  random sample.  Therefore, there is no statistical basis for the generalization of
                  these characteristics to the entire population of Brownfields  sites as a whole.
                  Hence,  individual  characteristics  can   only   be  associated  with   project
                  sustainability, and not statistically correlated.

                  Because goals and objectives are unique to each program or project, no standard
                  set  of criteria  were  defined  for  successful  and  unsuccessful Brownfields
                  redevelopment.   Each project's progress will  vary according to the  various
                  organizational goals, property location, economic market conditions, existing
                  legal and regulatory contexts, timeframes established  in which  to  achieve  its
                  objectives  or  milestones,  and  other  factors  often  beyond  the  project
                  management control.   Therefore, it is assumed that the degree to which a
                  project may be  sustainable is the basis for associating the project's relative degree
                  of success. In short, a project must be sustainable to be successful.

                  In addition,  although  a  number  of characteristics  are associated with  the
                  sustainability of a project, they are evaluated only in terms  of their presence or
                  absence from the overall program or project.  The level of success achieved, the
                  skill  with which  project participants have carried out a particular program or
                  project, and the affect that priorities, timeframes  and delays associated with
                  various activities have  on  sustainability, have not  been included as variables
                  under consideration in this study.

                  The  determination of direct  cause and  effect for  the association between
                  sustainability and the  inherent  elements and   characteristics  of Brownfields
                  redevelopment  discussed   here   is  also  limited.    Because the  individual
                  communities involved in Brownfields redevelopment cannot  be  isolated from
                  the influences of the larger socioeconomic structure of American  society and its
                  larger ecological  context, certain macro-structural variables may  also influence
                                              14

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ANALYTICAL  APPROACH
                  the development of sustainability.  In defining sustainability at the community
                  level and subsequently at the  project level, this  study assumes  that all other
                  extraneous variables are held constant in order to  identify specifically those that
                  may be under the influence and control of Brownfields project participants.

                  Further,  for the purposes of this study, sustainable Brownfields redevelopment
                  has been defined as redevelopment and growth maintained over  the long-term
                  and occurring within the limits of the environment so that the current needs of
                  citizens are met without compromising the ability of future generations to meet
                  theirs.  However, no data exists to evaluate the ultimate degree to which projects
                  have impacted the  limits  of their environment, met the citizens  immediate
                  needs,  or may have impaired the abilities of future generations.  This is because
                  of the very  limited duration (typically less  than five years) in  which all the
                  projects  studied have occurred, and because most of the projects have not yet
                  progressed to completion. Therefore,  an empirical basis for direct correlation of
                  subject  projects  with  the  defined  criteria  for  sustainable  Brownfields
                  redevelopment is not possible, within the timeframe and budget limitations of
                  this study.  Instead, it is assumed that a direct or indirect association of the
                  elements and characteristics of Brownfields redevelopment with the theoretical
                  principles and  factors  of sustainability  and  sustainable  development at the
                  community and project levels can serve as a reasonable basis for analyzing the
                  potential for  sustainability of any given project.

                  Finally, because Brownfields projects  are  at varying stages of development, the
                  consistency and level of data available  differs  from one site to another.   The
                  absence  of  documentation  on  the  activities  of several  of the projects  is
                  considered a  severe limitation on the project.
                                              15

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ANALYTICAL
               APPROACH
                                        16

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CHAPTER  3
SUMMARY  OF  DATA SOURCES
 SUMMARY  OF
DATA  SOURCES
                                                                                Overview of the
                                                                                Sustainable Development
                                                                                Concept
                                                                                Overview of the
                                                                                Brownfields
                                                                                Redevelopment Process
                                    This section describes the study's research and data collection
                                    relating to the sustainable redevelopment of urban and rural
                                    Brownfields  sites.  Section  3.1 provides a  general overview
                  of the concept of sustainable development as  it is presented in the literature.
                  Section 3.2 summarizes key development and planning concepts associated with
                  the  Brownfields  redevelopment process  that  have  been  developed  from
                  secondary literature sources and  personal interviews. This information forms the
                  basis for development of the key elements and  characteristics of  sustainable
                  Brownfields redevelopment discussed in Section 4.0.

                  The development  of background  and resource  information to  support this
                  analysis was  focused (although  not exclusively) on two primary subject areas.
                  The first  was the manner  in  which the  concept of sustainability  and the
                  associated process  of  sustainable development  have  been  described  and
                  understood both in literature  and in the general  perception of what is  sustainable
                  on the part of Brownfields  project participants and  the public at large.  The
                  second was  the  characterization of the Brownfields  redevelopment process
                  itself; concentrating on those structures,  activities, and issues that are common
                  to  the  process  in  differing   contexts   and  that  serve to  distinguish  the
                  redevelopment of a contaminated property from  other forms of real estate or
                  community economic development.

                  The approach adopted  for  this study was to collect and organize as much
                  information about Brownfields  projects as was possible within the  boundaries
                  set by budget and schedule.   The  information gathering techniques employed
                                             17

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CHAPTER  3
SUMMARY  OF  DATA SOURCES
                  included literature and database review, analysis of case studies, and structured
                  interviews.   These techniques were applied to a combination  of primary and
                  secondary data sources. A total of four sources of data were used to support this
                  analysis.   (1)  The  review  of current literature was  the major  source for
                  background  on the concept  of sustainable  development  and the Brownfields
                  process  itself, including approaches,  issues  and  outcomes.   (2)  Structured
                  interviews with  key government officials  (Federal, state, municipal),  project
                  principals, and representatives of stakeholder groups were used to  access the
                  knowledge and experience of Brownfields project participants.  (3) On-site visits
                  to  five Brownfields  project cities  were also  conducted for the purpose  of first
                  hand observation and interviews with  local  officials and community residents.
                  (4) Fifteen of the 115 Pilot Projects (see Section 2.1) were selected as part of a
                  screening review of existing case study literature on Pilot Project operations.

                  Although a systematic approach was employed in the acquisition and review of
                  information, no attempt was  made to  statistically test hypotheses related to the
                  causes or determinants of project success. Instead,  the primary  purpose of the
                  effort was to identify as  many of the  major factors as possible that influenced
                  the Brownfields  redevelopment process and to determine where these  factors
                  could be associated with sustainable environmental restoration and economic
                  redevelopment at the Pilot Project level.

                  Of concern  was the development of a working definition of the concept of
                  sustainability and its key  components through a review of existing literature on
                  the subject.  This approach was also used to develop the major components of
                  the Brownfields  process itself.   A  second  component of the  process of
                  information  gathering was intended to  capture the value of the  perspective and
                  experience  of those  actually involved in  the Brownfields  process, whether
                  government   officials,  community  participants,   or  private  agencies  and
                  developers.
                                             18

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CHAPTER  3
SUMMARY OF  DATA SOURCES
3.1   Overview of the Sustainable Development Concept
  Sustainable Development
     Oven/lew
     Sustainability
    Sustainabilityatthe
    Community Level
    Sustainabilityatthe
     Project Level
The perception that environmental issues are inextricably linked to other human
social issues  has  increasingly  played a  more important role in the economic
development and social planning processes of communities.  This notion has
found its most salient expression in the concept of sustainability.

Two  primary themes  pervade  the literature  on  sustainability:  1) economic
development predicated on ecological balance and 2) the equitable distribution of the
benefits and adverse impacts of development. Although the overarching goal is still
economic development, the objective is to find sustainable options that maximize
the net welfare of the  community  while  at  the  same time maintaining social,
economic, and especially natural resources  (Munaisinghe, 1993).  This leads to a
third  theme  embodied in the  concept of  sustainable development,  that  of
maintaining a sustainable scale,  or a level  of material and energy consumption that
does not erode the carrying capacity of the environment over time (Farrell, 1996).
                  Contained within these broadly defined areas, is the allied concept that sustainable
                  development requires not only a concern for the environmental component of an
                  individual project, but also  engages  the entire range  of community values  and
                  patterns that may both affect and be affected by the development (Rapport, 1997).
                  Thus, a single sustainable  redevelopment project is  also linked  to the overall
                  sustainability of the community as a whole.

                  Sustainability, itself, is not a new concept.  In its simplest formulation, it relates
                  to  a basic  historic  principle,  that of consuming the surplus  product without
                  diminishing the original  stock beyond the point where it can be reproduced. It
                  would be as familiar to a tenth century peasant or a seventeenth century farmer
                                             19

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CHAPTER  3
SUMMARY  OF  DATA  SOURCES
                  as it is to a present day ecologist.  What is new, is the importance of recognizing
                  that, because the earth and its resources are finite, the principles  of sustainability
                  extend to natural capital as well as to social and financial capital  (Kinsley, 1994).
                  (Also, see Section 3.1.2.1, Economic Sustainability).

                  Sustainability is, however, often believed to be a more definitive concept than it
                  really is.  Despite its growing use as a basic guideline for economic development,
                  the  term  does  not have  a  single, generally accepted  definition,  or  a
                  comprehensive set of activities that normally  associate  with it.  Depending on
                  the context or purpose of its use, sustainability (or sustainable development) has
                  "become a catch-all phrase that now refers to almost anything - from recycling
                  to planting trees to integrated policy analysis  to sustained growth of output to
                  the use of environmentally - adjusted national accounts or alternative indicators"
                  (Stallworth, 1997).

                  Correspondingly,  a sustainable  community  may mean many  things to  the
                  different people who live in it. To business owners, it means a healthy economy
                  so that their businesses  have a place in which to create and sell products  and
                  services.   To  conservationists, it means  limiting the depletion of natural  and
                  biological resources.  To parents, it means a safe environment in which to raise
                  children.  To residents in general, it means a secure, productive job market, and
                  the ability to meet the need for the services that support their quality of life.

                  In  order  to   consider  sustainability  in  the  context  of  the  Brownfields
                  redevelopment process,  it is  necessary to develop  a general understanding of
                  sustainability as  a  concept,   in  addition  to  formulating  an  operationalized
                  definition of sustainability in  the  form  of the  parameters and elements that are
                  associated with it. The intention is to connect sustainability to activities that are
                  relevant at the individual project or community program level.
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                  An important concern for sustainable Brownfields redevelopment projects is to
                  identify those  characteristics of sustainability that  are  accessible  to  project
                  participants  and can  be manipulated to  further the  success  of the project or
                  contribute to the overall sustainability of the community.  In essence, the effort
                  is  to  determine  how  the  direct,  immediate  activities  of a  Brownfields
                  redevelopment  project can  be  conceived and organized so  that  the  project
                  moves  toward sustainability and minimizes the potential to create a Brownfields
                  type situation in the future.
3.1.1   DeStation of Sustainabttity
Definition of
Sustainability


Parameters
of Sustainability
Sustainabilityas a
Normative Process
Sustainabilityas an
EvolutionaryProcess
Sustainabilityas
Context Dependent
Sustainability
and Development
Sustainabilityand
Self-sustainability
Challenges to
Sustainability


                  Although there is an  extensive body of literature that addresses the concept of
                  sustainability, much of this work is abstract in nature and deals with sustainability at
                  the global or societal  level.   Several commentaries on the subject focus on  this
                  relatively  vague construction of the concept and point to the need for  a greater
                  precision  in defining what it means to be sustainable - or question whether a more
                  precise definition is either possible or, in fact, desirable (Farrell, 1996; SCGPN, 1996).

                  A second body of literature recognizes the need for the development of a working
                  definition of sustainability.  This definition would be "operationalized" to the extent
                  that it can be  applied to specific problems and  used  as a mechanism to develop
                  qualitative or quantitative  measures (indicators)  of sustainability  (Herkert,  et. al,
                  1996).
                  There are a number of ways in which to represent or define sustainability. As a
                  conceptual framework, sustainability can be expressed in terms of the policies or
                  principles that guide the redevelopment effort.  Sustainability can also refer to a
                  set of evaluative criteria based on the ultimate goal of  creating a sustainable
                  community.   Or, it can be incorporated as an integral part of the development
                  process itself.
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                  In  practice,  sustainability has  been applied to  issues ranging  from  global
                  economic  development  at the  macro level  to  green buildings and pollution
                  prevention at the micro  level.  It also represents a key component of the new
                  approach to  urban redevelopment  encompassing such issues  as urban sprawl,
                  inner city and Brownfields redevelopment, and socioeconomic equality.

                  Sustainability is as much  a reference to the process by which development takes
                  place as to the policy or perspective that informs  the  process, or to the final
                  outcome of the process.  Currently no contemporary community  has achieved
                  the goal of  being  completely sustainable.  A project, community, or culture
                  however, can incorporate the component values and practices of  sustainability
                  into its planning processes, community design, buildings, and collective patterns
                  of activity.   Sustainability can then best be expressed in terms of an  ongoing
                  process of development  or redevelopment that does not undermine its physical
                  or social systems of support.

                  The process  concept is incorporated in the definition advanced by the United
                  Nations World Commission on Environment and Development (1987)  - known
                  as the Brundtland Commission  - and later incorporated into the report of the
                  President's Council on Sustainable Development, "Sustainable  America, A New
                  Consensus"  (1993).  Here, sustainable development refers to development that
                  meets the needs of the  present without compromising the  ability of future
                  generations to meet their own needs. The Brundtland Commission goes on to
                  state  that, "in essence, sustainable development is a process of change in which
                  the exploitation of resources, the direction of investments, the orientation of
                  technological development, and institutional  change  are all  in harmony and
                  enhance  both  current  and  future  potential  to  meet  human  needs and
                  aspirations."
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                  Sustainability and the associated process of sustainable development then have,
                  at  a minimum,  two  primary  dimensions.   The first  is a  concern  about
                  environmental  degradation and  a long lasting  relationship between  human
                  beings and the rest of the natural environment.  The second implies  a core ethic
                  of social intergenerational equity, along with  an understanding  that future
                  generations are entitled  to at least as good a quality of  life as present ones"
                  (Herkert, et. al., 1996).

                  "Sustainable development is a two-sided relationship, as both the well-being of
                  mankind and society and that  of the  environment play a role in evaluating
                  development activities. Social well-being can be measured in terms of the extent
                  to  which needs are satisfied, and  the well-being of the  environment  can  be
                  characterized in terms  of the  extent to which environmental  functions, and
                  assets are left unharmed" (SCGPN, 1996).  It follows then that resources (both
                  social and ecological)  are  not  consumed or depleted  to  the  extent that they
                  cannot  be  replicated sufficiently  to allow for  a  new round of  production and
                  consumption.  And, that  the future creation of wealth  in the community  is
                  thereby less environmentally damaging, more just, more secure,  and  increasingly
                  focused on the more complex processes of development rather than on simple
                  growth or accumulation.

                  The concept of sustainability therefore, represents a true  paradigm  shift to the
                  extent that it reflects changes in the manner in which development is planned,
                  the organization of the social mechanisms that control and implement planning,
                  and the role of  the  community in  the planning process.  To some  extent,
                  sustainability redefines the nature of community itself.
3.1.1.1     PARAMETERS OF SUSTAINABILITY
                 The environmental impact of human activity is broadly characterized by: 1) the
                 size of the population involved; 2) the degree of prosperity or material welfare
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                  of the population; 3)  the environmental intensity of the consumption process;
                  and 4) the  environmental intensity of the production mechanism  (SCGPN,
                  1996).  Each of these  factors directly affect the potential sustainability of a given
                  process or activity.

                  The  process of sustainability itself,  or the process  of transforming human
                  activity from unsustainable to sustainable patterns, can be expressed in terms of
                  the quality of the relationship between these factors and the interaction of the
                  various elements and characteristics that are associated with them. Sustainability
                  is therefore a function of what activity is carried out; who performs the activity
                  and  how many  performers  there  are;  the  level  of  material consumption
                  incorporated as part of  the  activity; the  potential  environmental damage
                  associated with the manner in which the material is  produced; the manner in
                  which the activity is carried out; when and where the  activity is performed; and
                  who benefits from the activity.

                  The parameters that govern sustainability, then, can be related to these primary
                  factors,  and are grouped under  the  core systems  of  societal  structure  -
                  ecological, economic, sociocultural.   Any consideration of sustainability must
                  take into account the complexity, integration and interdependency of these three
                  systems.  "Solutions that target one area, such as the economy, often cause more
                  problems in  other areas because the links are neglected"  (Hart, M., 1997(a)).

                  The difficulty inherent in developing an understanding of each of these systems
                  is that each  can be seen as a component part of the  others while, at the same
                  time, each is also  defined  as  containing the others as  component parts.  For
                  example, the ecological system provides  the context  in which the  other two
                  systems, social and economic, function.  The activity of the other two systems
                  cannot deplete  ecological  resources  to the extent  that  they  are no  longer
                  available or are too expensive to acquire.
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                  Simultaneously, the ecology represents the source of the natural capital that is
                  the basis for the economic system.  The economic system is nothing more than
                  a  mechanism for employing  human resources  (social  system)  in the task of
                  transforming  physical resources (ecological system) into  resources that are
                  socially useful.  In turn, the larger social system both  contains the other two
                  systems and is  also constrained by their capability.  The society as a whole,
                  cannot place demands on  either of the two systems that exceed their capacity
                  (productive capacity in the case of the economy, carrying capacity in the case of
                  the environment).
3.1.1.2     SUSTAINABILITY AS A NORMATIVE PROCESS

                  The  definition  of  sustainable development  articulated  in the  Brundtland
                  Commission report establishes two dimensions  of concern for sustainability; the
                  continued satisfaction of human needs and the maintenance of the environment.
                  But this definition does not specify which human needs are to be met, at what
                  level, and who will  be  responsible for  determining the mechanisms  by  which
                  these needs are met.   It further  implies that  the needs of  future  generations
                  could somehow be anticipated by the current generation.  With respect  to the
                  maintenance of the environment, the criteria to be used in measuring the  extent
                  to  which ecological functions and assets are  left unharmed  are  also not
                  addressed (SCGPN,  1996).

                  Sustainability is therefore not based  on some objectively fixed characteristic of
                  the  development process, but  instead must consider a normative component.
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                 Attitudes  and perceptions  of what  is sustainable, what the requirements of
                 human social systems are, and how those requirements are to be met will change
                 from one  context to another, and evolve over time.

                 In this context sustainability must, in itself, be considered as a social process in
                 which certain decisions and trade-offs between immediately perceived human
                 requirements, the perceived needs of future  generations and the determination
                 of environmental harm must be made.  For example, if confronted with a 30
                 year supply of a limited natural resource, the current generation can decide to
                 conserve the entire supply, determine that some portion of it must be reserved
                 for the benefit of future  generations,  or assume that future generations will
                 develop new patterns of activity or innovative technologies and will no longer
                 require the resource at all.

                 From the  perspective of the role of sustainable development in the Brownfields
                 process, these questions emphasize the importance of the consideration of the
                 social dimension in the development process. "Without proper analysis of social
                 conditions and consultation in determining priorities,  the services provided by a
                 project may not be the ones that the ultimate beneficiaries find the most useful,
                 or  that they will  help sustain  by contributing to  critical  operations  and
                 maintenance" (Kaji and Koch-Weiser, 1997).
3.1.1.3    SUSTAINABILITY AS AN EVOLUTIONARY PROCESS

                 "No industry or development activity can be considered "sustainable" in and of
                 itself (Northampton, Co., 1994).  It is clear that sustainability is not, a priori, an
                 objective  feature  of the  development  process,  but is  incorporated  as  a
                                            26

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                  component element  of planning; deciding what is to be done; and  how the
                  development  is  to  be implemented.    Sustainability is  not  a fixed,  static
                  classification,  but is rather an evolutionary process that  depends not only on
                  what is done, but also on how it is done.

                  The process of sustainable development is an iterative one.  Because the number
                  of stakeholders  and their  individual perspectives will be  sufficiently diverse,  a
                  number of rounds of  planning and discussion will be required to reach the
                  delicate  and appropriate balance  of the three parameters of sustainability for
                  each community.

                  Although there are no existing communities in the United States that  have
                  achieved an ultimate sustainability in terms of a comprehensive process that can
                  be maintained across  multiple  future  generations,  communities are moving
                  toward sustainability and more sustainable practices. In this sense, sustainability
                  is also  a learning process  as  communities begin to recognize what industries,
                  activities, and practices contribute to the long-term benefit of both  the human
                  population and the environmental resources on which that population depends.

3.1.1.4     SUSTAINABILITY AS CONTEXT DEPENDENT

                  What is sustainable in  one community may not be so in another community.
                  Sustainability is a function of economic and ecological resources  and processes,
                  balanced with a number of community factors. Therefore, the balance itself and
                  the form the  process will take depend on a  number of factors  unique  to the
                  individual interests, needs, and culture of the community.

                  Although no  single approach to sustainability will satisfy all situations  in all
                  communities,  it is possible to identify certain  common elements  of the process
                  that will be part of any  community effort. A sustainable approach will involve a
                                             27

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                  long-term,  integrated  procedure  to  harmonize  resource  use,  investment,
                  technological development, and institutional change.  This must be done while
                  recognizing that economic, ecological, and social issues are integrated and must
                  be addressed  together.  For  example, a  strong sense of community and the
                  building of a consensus among stakeholders  who share  a common vision of
                  what the sustainable community should look like  are important elements, as is
                  the  ability to  formulate  operational plans and  develop  indicators by which
                  success can be  measured (Lachman, 1997).
3.1.1.5     SUSTAINABILITY AND DEVELOPMENT
                  Much of the constituency  for  sustainable  development  in  the  United States
                  comes from local efforts to create more sustainable  communities (Goldman,
                  1995).  The primary goal of a  sustainable  community effort is  to meet basic
                  needs in a manner that can be  continued into the future.  In some instances,
                  sustainability is  viewed as  a technical issue related to the  manner  in which
                  humans interact with the rest of the natural environment  (ecology), while other
                  perspectives are  focused  on the  social or political issues  surrounding social
                  equity, human rights, and community redevelopment.

                  The sustainable component of the development process relates more  to the
                  manner  in  which development is  approached  and  carried  out than to the
                  particular issues addressed.  Sustainable development implies that the solutions
                  to  existing problems should  be  addressed  by  means  of a comprehensive
                  approach.   Sustainable development therefore,  is a  reflection of community
                  desires and values, and should positively sustain the community in the manner in
                  which it wants to be supported.

                  As it  relates to  the Brownfields  redevelopment process, this perspective of
                  sustainable  development implies that a Brownfields project  should, in addition
                                             28

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                  to addressing the problems of contamination and underutilization at a given site,
                  also contribute in some manner to the general  socioeconomic future of the
                  community.   In this sense, Brownfields projects  can serve as a catalyst to the
                  ongoing process of sustainable development in the community.

                  However, the pursuit of sustainability can also place a significant  burden on a
                  Brownfields  redevelopment  project.  It is important that sustainability should
                  not impede   the  redevelopment  process, or  place an unrealistic burden  on
                  Brownfields  redevelopment that is not required for other similar type projects.
                  "Sustainability does not mean that businesses never fail, or that people never go
                  hungry, or that pollution never happens" (Hart, M., 1997(a)).  To require that
                  these  criteria be assured by the Brownfields  development process can  be an
                  inhibiting factor that reduces development possibilities (such as interim use
                  based projects) and encourages  undesirable greenfield sprawl development in
                  communities.  Therefore, sustainability should further the Brownfields effort,
                  not hinder it by  imposing  strict requirements that can actually  decrease the
                  chance for success.

3.1.1.6    SUSTAINABILITY AND  SELF-SUSTAINABILITY

                  From the perspective  of achieving  sustainability at the individual project or
                  community  level,  the determination  of sustainability can  be  differentiated
                  between  those projects that will be  self-sustaining,  and those that will require
                  some  infusion  of  outside assistance,  whether public  funds  or  some  other
                  support mechanism.  A self-sustaining activity can be  identified as one that is
                  capable of generating sufficient resources (both  economic and natural capital)
                  to  support itself without depleting those resources.  Economic support here
                  would be defined as return on  investment or profit to private developers or
                  revenue (taxes and fees) to the  supporting public entity that is sufficient to offset
                  initial  and subsequent costs.  Correspondingly,  activity that is not also self-
                                             29

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                  sustaining would require some input of public resources (labor, funding, natural
                  resources) to offset the difference between revenue and expense.

                  In this sense, sustainability can be seen as a continuum moving from the most
                  extreme condition  of self-sustainability at one end to the opposite extreme of an
                  environmentally   sustainable   project   that,    although    successful   and
                  environmentally friendly, depends totally on public support.  The level  of self-
                  sustainability, therefore, would vary according to the level of public support
                  required.

                  For  the most  part,  Brownfields  projects  will  not, at least in  their early
                  development stages, be self-sustaining. "Local communities  are not looking to
                  soon become closed loop, to change their energy supplies to more renewable
                  methods, or to shorten their supply lines.   For the  time  being, they need
                  development options that simply bring more  money into their area  to create or
                  maintain jobs,  and to provide tax revenues to support local schools and other
                  governmental functions" (Stallworth, 1997).

                  Communities engaged in Brownfields redevelopment must, at some point during
                  the development process, reduce the  level of government support  provided to
                  individual projects.  Ideally,  Brownfields projects would be  able to maximize
                  leverage of the public and private  endowment funds available  to  develop the
                  project to its fullest, then strive for a consideration of self-sustainability.  The
                  idea of a local government - private enterprise partnership is one mechanism for
                  organizing this type of structure.

                  The key issue for self-sustainability is defining that point at which public support
                  gives way to private  enterprise.   This  presumes that  the ultimate goal of a
                  Brownfields redevelopment project is a fully supportive, for-profit entity.
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                  However, in many cases, the highest and best use of a redeveloped property may
                  not be a commercial enterprise, but may be public in nature, such as a greenway,
                  inter-urban park,  or a rails-to-trails  project.  In  these cases,  the  permanent
                  support of some public entity may be necessary for the long-term sustainability
                  of the project; the project may never become directly self-supporting. This does
                  not mean that the project does not contribute to the overall sustainability of the
                  community.   The potential for increased land values surrounding the  project,
                  increased revenue from taxes, concessions, or user fees generated by the project
                  contributes value to the  community.    These can be  balanced against  the
                  ongoing project costs to demonstrate  a variation  on self-sustainability that is
                  derived from indirect revenues.
3.1.1.7     CHALLENGES TO SUSTAINABILITY
                  "Uncontrolled  growth  is   probably  the  greatest  obstacle  to   sustainable
                  development  in  the  United States. Building on  new  untouched  sites  always
                  destabilizes natural systems  and  can mean  losing  valuable  agricultural  or
                  forestland.  Access to new development requires more  roads, more trips, more
                  extensions of the urban infrastructure; in other words, more natural resources
                  consumed and more pollution created" (Barnett, 1993).

                  The growth of Brownfields sites and the subsequent decay of inter-urban areas
                  and  rural  industrial  sites   are  a  major  component  of  the  unsustainable
                  community.  This is a further expansion of the "use  and discard"  attitude that
                  characterizes much of the economic development climate of American society.

                  A serious concern for the development of sustainable practices as a part of the
                  development effort is that there are a number of alternative options which are
                  not necessarily sustainable,  but which, from a  business standpoint may  be
                  preferable.  In terms  of cost effectiveness, development of greenfield sites is
                                             31

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                  often  preferred   to  using  existing  Brownfields  sites.    The  sustainable
                  redevelopment of Brownfields sites is often seen as more costly, especially in the
                  short-term.    Therefore, best  practices  from  an  environmental  or  social
                  standpoint are often competing with best practices from a business management
                  standpoint.  A rational business decision  then is  often  to do something else
                  rather than follow a "sustainable development" strategy.

                  For  communities  as well, what is considered good practice, or vital for the
                  maintenance of the community's continued existence, may interfere with the
                  concept of  sustainable growth  and development.  As Michael Kinsley (1994)
                  notes,  the  normal response  to  the  recognition  of  declining  economic
                  circumstances is industrial recruitment; an attempt to identify any new outside
                  sources of employment  and  income  that  may want to  move  into the
                  community. But most of these business recruitments are unsuccessful because
                  outside businesses are  seldom  inclined to  invest in problem  communities.  In
                  order to attract new businesses, inducements and incentives are often so  great
                  that the result is a net loss to the community.

                  Growing  communities  often  have  some  significant  feature   or valuable
                  commodity  (e.g. exploitable natural resource, waterfront property,  quality of life,
                  etc.)  that tends to support growth.  But, in many cases, the resource runs out,
                  demand for the resource decreases, or  the growth itself tends  to overwhelm the
                  attractiveness of the community.  Inevitably, this leads to efforts  to  control or
                  limit growth in communities that have become victims of their own success.
3.1.2  SustaJtmbHityatlhe CommunityLevd
      Economic
     Sustainability
     Sociocultural
     Sustainability
      Ecological
     Sustainability
"Today's local economies are no  longer  'local' and certainly not 'closed loop'
because they are  increasingly  enmeshed in the larger  regional,  national,  and
international economies.   As  a  result, it  is  very  difficult to  assess  the
                                              32

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                  'sustainability'  of production  and consumption  processes when  sources and
                  sinks related to that local area span the entire globe" (Stallworth, 1997).

                  Sustainability at the project or community level then is difficult to  determine in
                  absolute terms. The externalities (exogenous variables) are too influential - the
                  macro  economy, for the most part, drives local issues.   However, by holding
                  constant these external variables, it is possible to examine  those elements of a
                  successful redevelopment process that are themselves evidence of sustainability
                  and that also contribute in a small way to the overall sustainable development of
                  the larger community.

                  Although a discussion of sustainability at the community level cannot address all
                  of the  attributes  or  characteristics of sustainability evident  at  the societal  or
                  global  level, incorporating  sustainable  concepts into the local  development
                  process does represent  an  alternative to existing unrestricted growth patterns.
                  Increasingly, many communities have come to believe that environmental and
                  other community development problems cannot  be addressed in isolation, but
                  must be part of a more comprehensive development approach (Lachman, 1997).
                  This approach also recognizes  the importance of communities as innovators and
                  change agents in the process of achieving sustainability.

                  It is relatively easy to identify a community that is not sustainable  - fewer good
                  jobs  at family wages,  increased poverty, homelessness, general deterioration.
                  However,  determining the reverse, what makes a  community  sustainable, is not
                  as  obvious  (Hart, M., 1997(a)).   As  previously  noted,  there  is no  single
                  comprehensive approach to sustainability that is appropriate to all communities.
                  Every community will be unique in defining what is sustainable. However, there
                  are some general conditions that are common to sustainable communities
                   Sustainable Community - General Components
                                             33

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                      Economic Security
                      Ecological Integrity
                      Quality of Life
                      Empowerment and Responsibility
                  Some general components that are critical to a sustainable community (Kline,
                  1996) include:

                  Economic  Security  -  a level of  economic  activity  that provides  both
                  employment and spending opportunities within  the  community and increases
                  the amount of money that is  retained within  the  community; by providing a
                  variety of businesses  that are  environmentally  sound,  financially viable, and
                  provide  training, education and other forms of assistance  to adjust to future
                  needs.

                  Ecological Integrity - in harmony with natural systems by  balancing system
                  functions with resource thresholds, reducing and  converting waste into non-
                  harmful  and beneficial purposes,  preserving  valued physical  and  biological
                  resources, and by using environmental resources  to fulfil human needs without
                  reducing their ability to function over time.

                  Quality  of Life - a more sustainable community recognizes and supports a sense
                  of well-being, a sense of place, a sense of self worth, a sense  of safety, a sense of
                  connection with  nature, and the provision  of  goods and services  which meet
                  their needs both as they  define them and as can be accommodated within  the
                  ecological integrity of natural systems.

                  Empowerment  and  Responsibility   -   people   are empowered  and  take
                  responsibility based on a shared vision, equal opportunity, and the ability to
                                             34

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                 access expertise and knowledge for their own needs; and are able to affect the
                 outcomes of processes that affect them.

                 Also important is an open and inclusive planning and decision making process
                 focused   on  communication,  cooperation,  and  compromise  by  multiple
                 stakeholders in an effort to build consensus.  "A sustainable community needs
                 to be  developed by the people who make up  the  community. It cannot be
                 designed by a  consultant. It cannot be implemented by experts hired specifically
                 for the project.  It needs to be implemented every day by the people who live
                 and work in the community" (Hart, M., 1997(a)).

                 From  these basic elements, a number of essential principles can be derived to
                 represent a generic core of characteristics of sustainable communities.
                  [
                   Sustainable Community Characteristics
Limitations on Growth
                      Adaptability to Change
                      Encouragement of Economic Self-sufficiency
                       Creating a Vision
                      Equalize the Benefits and Burdens of Growth
                      Develop a Sense of Place
                      Protect and Enhance Quality of Life
                      Community Reorganization for Sustainabilit
                 Limitations on Growth - a sustainable community recognizes that growth must
                 occur within some boundaries and is ultimately limited by the carrying capacity
                 of the ecological environment.  Important to this  concept is the limitation of
                 sprawl development and the adaptive reuse of existing, already developed land.
                 Adaptability to Change  - evidenced by the understanding that change  is
                 inevitable and unpredictable, an effort to try to understand the behavior of the
                 natural systems that sustain the community, and a willingness to make decisions
                                            35

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                  that are consistent with the natural direction of  change in the  ecosystem
                  (Bernard and Young, 1997).

                  Encouragement of Economic Self-sufficiency - through the fostering of local
                  ownership and  the efficient  and  effective  use  of local  natural,  social,  and
                  financial resources to meet local needs, sustainability is enhanced by retention of
                  resources within the community and the minimization of external linkages.

                  Creating a Vision  - reaching out to a large group of residents to determine
                  what they will support or what their concept of the future will hold (Beatley and
                  Manning, 1997).

                  Equalize the Benefits and Burdens of Growth - development that benefits all
                  income levels and neighborhoods rather than benefiting only the wealthy while
                  leaving the burdens of growth  to the lower  income groups.   Equity is  a
                  fundamental requirement for sustainability (Burlington, 1997).

                  Develop a Sense of Place -  community members must become shaped by their
                  place,  by knowing their common history, geography  and natural cycles and feel
                  rooted (Bernard and Young, 1997).

                  Protect and Enhance Quality of Life - placing quality of life issues such as
                  education,  aesthetics, safety, the built environment, greenspaces, and distinctive
                  community character at the forefront of policy and planning decisions.

                  Community Reorganization for Sustainability  - organize to  address  together
                  the  economic, social,  and  ecological issues that are  the most  pressing  and
                  important;  governance  and  management  issues   such  as  fairness  in  the
                  community, fairness in the sustainability process, basic management logistics for
                  the process, and how it all fits into the existing community structure.
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3.1.2.1     ECONOMIC SUSTAINABILITY
                 The primary question for the consideration of economic sustainability is: What is
                 to be sustained?  One criterion is the requirement that economic development
                 introduce income (in the form  of jobs  or  expenditures)  into the  community
                 (Goodland, 1994; Stallworth, 1997). This also provides a form of stability to the
                 local community through the social value of employment,  and the maintenance
                 of long-term residence  and attachments  to  the community.   If a  community
                 does not have a strong economy, then it cannot be healthy and sustainable over
                 the long-term.  (Lachman, 1997).

                 In addition to good jobs and good wages, economic sustainability also considers
                 stable   businesses,  energetic  business   activity,  appropriate   technological
                 development and implementation, business development, etc. An economically
                 sustainable development generates at least a part of the income necessary for its
                 self-maintenance, contributes revenue to  support  the  community infrastructure
                 and services consumed, and includes the controlled distribution of the beneficial
                 and adverse impacts of development (political economy).

                 A community  can develop  itself without resorting to runaway  growth in the
                 scale of its economy.  Michael Kinsley (1994), the Director for  the Economic
                 Renewal  Program of  the  Rocky Mountain  Institute,  suggests  four basic
                 principles: 1) increasing energy efficiency decreases the leakage of money from
                 the community in the form of money spent out of town for various forms for
                 fuel; 2)  supporting  existing local  businesses by  identifying items purchased
                 outside of the community  that could be  provided locally with the  resultant
                 retention  of money  and  jobs  in  the  community;  and  3) encouraging  the
                 development of new local business by the exploitation of underutilized local
                 assets.  These first three  are believed  to  increase the  attractiveness  of the
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                  community to investors, which leads to the fourth principle; that of recruiting
                  compatible businesses that are in line with local conditions, and the goals of the
                  community.

                  These four principles represent solutions that are sustainable over time and are
                  appropriate  no  matter the  condition  of the  local  economy.    Sustainable
                  development,  from the  perspective of the economic system, requires  that
                  resources  not be consumed at a rate faster than  they  can be  renewed  or
                  replenished.  Also, the ecological threshold  (or the point at which an ecosystem
                  can no longer continue to be damaged or altered without permanent failure)
                  must be recognized, along with the recognition that the carrying capacity of any
                  given area can sustain only a certain number of people  (Kinsley, 1994).

                  The key  requirement  of the  approach to sustainability is that some form  of
                  income and economic growth be maintained. However, a sustainable approach
                  implies  that  along  with  the goal  of maximizing the  net welfare of  the
                  community, its stock of economic, ecological, and sociocultural resources must
                  also be  maintained  over the long-term.  This is a  departure from the more
                  classical economic theory, which  is concentrated on a linear growth model
                  focused on  quantitative  enlargement,  rather  than  development.   Qualitative
                  development  implies a different set  of assumptions and a different approach
                  than does the more traditional approach  of quantitative growth  (Goodland,
                  1994).

                  Traditional economic analysis has concentrated primarily on the output end of
                  economic production with little consideration for the sources of natural capital.
                  Historically, investments were made in  the  form of capital that was in shortest
                  supply — human-made  capital  or  the  tools,  machines, infrastructure  and
                  technology that are necessary to production.  Social capital (i.e., the workforce,
                  its capacity levels, the general knowledge  base, and the  social and cultural
                                             38

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                  institutions of society) along with  natural capital  (e.g., the resources  of the
                  natural world) were generally  available  in  abundant  supply.   However, the
                  increasing demands of modern society on the natural environment have made
                  natural capital  as significant  a  limiting factor  on  growth  in the modern
                  community as was human-made capital, historically (Goodland, 1994).

                  Economic  development  then  becomes  a normative  trade-off between the
                  requirements  and demands of the community, the  limiting  factors  of the
                  productive capacity of the economic system, and (more increasingly) the limiting
                  factors of the ecological  environment (SCGPN, 1996).  A new approach to
                  development  is  required that  recognizes,  "A  community  can develop  itself
                  without growth.  It can create housing, and jobs, expand cultural  and educational
                  opportunities, improve health, and protect public safety" (Kinsley, 1994).  The
                  long-term impact of a development project for the sustainability  of a community
                  becomes  a  process  of  maximizing  the  qualitative  improvement  of the
                  community while  recognizing  the  critical  interplay of economic, social and
                  environmental factors.

                  The economic implications of a project, then, will  be primarily related to the
                  interaction of a number of different factors including the project characteristics
                  (e.g., the level of potential  employment,  the size of the initial  investment
                  requirement,  the  proposed use, etc.),  the  characteristics  of the site and the
                  particular area in which the project is to be accomplished  (e.g. infrastructure,
                  surrounding land uses, tax structure), and the implications  for the social and
                  ecological environment in which the project is located. Additional considerations
                  are related to the distribution of project-related costs and revenues, and the risks
                  to which local government may be exposed because of uncertainty related to the
                  project's future, or the nature of its impacts (Leistritz, 1994).
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                  Therefore, there are four key considerations for the determination of economic
                  sustainability.  These include the extent to which the project contributes (either
                  directly or indirectly) to the income of a community; the community's ability to
                  gauge the  degree to  which the  project  can expand its  resources  through
                  increased development, rather than growth; the community's ability to preserve
                  these resources for future development through efficient consumption; and the
                  community's  ability  to expand  employment and  improve  the  quality of life
                  without placing undue  economic risk on current and future populations.  Both
                  the  environmental (natural capital) and social (human  capital) implications of
                  development must be  considered  along with  the  more traditional  concept of
                  increased economic output.
3.1.2.2    SOCIOCULTURAL SUSTAINABILITY
                  Although  sustainability  is  usually  focused  on  concerns  related  to  the
                  environment (specifically  to  the environmental  carrying capacity  of a given
                  community)  and  economy,  the social  components of  sustainability  are  also
                  important.  "Although we often see it as a source of conscience that is free of
                  the pollution of social interests,  nature is inescapably social" (Bell, 1997).  The
                  manner in which we understand and act upon nature is as much defined  by the
                  culture of a community, as it is by the limitation and quality of nature itself. Like
                  nature, the concept of sustainability is a social construct  (i.e., purposely created
                  out of human  cultural  knowledge  and experience as  well as the process of
                  balancing human  values and  needs with human  perceptions of the ecological
                  environment).

                  In order to be sustainable, then,  a community must balance the new conception
                  of a need for the preservation of natural capital in  the development process with
                  new elements of  social, political and  institutional organization, and new social
                  values.  These include  changes in such areas as the  relationships  between
                                             40

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                  potential  users and stakeholders,  the  role and  responsibilities of owners, the
                  existing authority systems, existing forms of public-private partnerships, and the
                  overall belief and value systems of communities.  In short, there must be a new
                  way of looking at  development as a mechanism of social change as well as a
                  mechanism for conserving the environment.

                  Central to social sustainability then is the general enhancement of the quality of
                  social  life by improving the mechanisms by which community needs are met
                  through  appropriate  facilities  and  services  that  enhance  and  reinforce
                  community values.  Two critical elements of this process are the creation of new
                  forms  of organization that enhance the individual  social actor's  capacity to
                  coordinate  social  action  and empower them as agents of the development
                  activity (Cernea, 1994), and the equitable distribution of the risks and benefits of
                  development.   Sustainable social  objectives  include  enhanced  community
                  participation  in the  decision and planning  processes,  social  empowerment,
                  increased community cohesion, stability, and diversity, and the establishment of
                  intergenerational, regional, and socioeconomic equity (Goodland, 1994).

                  There  is no benefit to development that does not have a  basis of support in the
                  community.  In  order to  contribute to the  sustainability of a community, a
                  project must contribute to socially critical elements of that community.  There
                  must be  compatibility between the  proposed  project and  the community it
                  serves.  People and the  social  systems they create  are at  the center of the
                  development process.   It  is the  people  of the community  that are both the
                  actors  causing development to happen and beneficiaries of the consequences of
                  development.  Whether they are  beneficiaries  of  development or  its victims
                  depends  on the  degree to  which the  development  reflects  the needs of the
                  community.
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                  Social sustainability is therefore based on the concept that individuals within the
                  community will participate in  determining what the needs  of their community
                  are, which needs  take priority and how those needs are to be  satisfied by the
                  proposed development.  The development of a design appropriate to the values
                  and needs  of a  community is  facilitated  by  the active involvement of the
                  community  at  all levels  of the  decision making  process, from  the initial
                  community assessment to the implementation of the final design.

                  Similarly, new forms of social organization are required to meet the challenges of
                  development, especially where Brownfields redevelopment is concerned.  The
                  potential risk of  contamination  requires that,  in addition  to determining the
                  levels  of risk and potential reuses  of a contaminated property,  the community
                  also participates actively as a partner in the development process.  Traditional
                  private  development  approaches, while potentially  useful  for some highly
                  desirable parcels,  may not be appropriate  for more  problematic sites.  New
                  forms of public-private partnership and development will be required in addition
                  to a new understanding of the rights and responsibilities of ownership.  There is
                  a growing interest in the  importance  of communities and  community-based
                  initiatives in the  development process, especially in the rebuilding of urban
                  environments (Kingsley, et. al, 1998).

                  Another significant component of social sustainability is the concept that any
                  development that does not incorporate equity is inherently unstable. In order to
                  maintain stability and continuity into  the future, a sustainable development  must
                  recognize a sense  of equity or justice. Simply, a sustainable  development should
                  not enhance one segment of the community at the expense of another.

                  This   involves   consideration  of  regional  as  well  as  intragenerational,
                  intergenerational,  and  socioeconomic  equity.   Regional  equity  implies  that
                  development be genuinely new for a  community and not simply a relocation of
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                  an activity from one community to another.  Similarly, intragenerational equity
                  emphasizes the importance of  addressing  sustainability in the present as  a
                  prelude  to  the  consideration  of intergenerational  equity  in  the  future
                  (Goodland, 1994).  Environmental justice  or equity  for cultural minority and
                  socioeconomically disadvantaged groups continues to  be a prime social concern
                  and a major element for the consideration of sustainability.
3.1.2.3    ECOLOGICAL SUSTAINABILITY
                  The primary question for the consideration of ecological sustainability is: How can
                  the ecological systems be sustained?  One approach for sustainability is the concept
                  that a community should fit within and nurture its ecological home. The ecological
                  home  being  the  biological, topographical, climatological,  and  geohydrological
                  conditions and the interconnected natural processes within which the Brownfields
                  property, city or community is located and which influenced it. The concept implies
                  that the community should strive to complement its surrounding environment by
                  functioning as,  or as part  of, an ecosystem (Beatley and  Manning, 1997).   An
                  ecosystem described  in simplest terms is "an interconnected community of living
                  things, including humans, and the physical environment within which  they interact"
                  (IEMTF, 1995).  E.P. Odum, the renowned Harvard University ecologist described
                  an ecosystem as "any area of nature that includes  living organisms and non-living
                  substances interacting to produce an exchange  of materials" so that "a  flow of
                  energy leads to a clearly defined [natural system]" (Odum, 1959 and 1971).

                  Odum's definition is important because it presents the basic principles  of "exchange
                  of materials" and "flow of energy" inherent to  an  ecosystem.   A sustainable
                  ecosystem must meet four criteria. It must have the tendency to generate materials
                  that can only be exchanged with other system components.  The generation of the
                  aforementioned materials must be  limited based on the carrying  capacity of the
                  resource(s). The system's waste products must be minimized so as not to impair the
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                   flow of energy.  The system must contain a rich diversity of living organisms and
                   non-living substances  that provide the  flexibility necessary to adapt to changing
                   external conditions.  To fit into the ecosystem, therefore, a community needs to seek
                   a balance between its physical, material, and emotional needs and these principles.

                   No one model can exist for determining where this balance occurs, nor will the state
                   of balance be  static.   The balance must make good  sense for the individual
                   community based on its current ecological, economic,  and sociocultural profile, as
                   well  as  its common  vision  for the future.  Therefore,  the balance  should  be
                   continually evaluated and reconsidered.

                   Ecological sustainability  also  considers the broad-scale, long-term  (or spatial and
                   temporal scales) ecological consequences of a redevelopment project.  This  can only
                   be accomplished if the  community understands the complexity,  diversity and
                   resilience of its  own natural systems and appreciates the interrelationships  that link
                   every member  of  the  community to  their  surrounding  environment.   This
                               Ecological Sustainability Components
                       1 Natural Forces & Hazards • Physical & Biological Diversity D Greenspaces
                  understanding and appreciation should focus on three key areas.

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                  The natural forces and hazards that affect the community resiliency - or how
                  the community  attempts  to  live and grow  within  them.   Hurricanes, floods,
                  droughts,  sand dune migration, soil  erosion,  and other natural  forces represent
                  unique limitations on sustainable development.  Sustainable communities seek to
                  avoid or reduce their exposure to these and other similar hazards  over a period of
                  time by controlling the development,  or  even  "retreating from high-risk areas"
                  (Beatiey and Manning, 1997).

                  The  diversity  of biological species  and  uniqueness  of physical features
                  affected by the community - Endangered species as well as common species of
                  plants and animals  represent key indicators  of an ecosystem's  health.  Habitat
                  areas  for  these  community  residents and  unique physical  features  of the
                  landscape  such  as  watersheds, wetlands, shorelines,  prairies,  mountains, and
                  canyons are all valued assets that require consideration for use, restoration or
                  protection in ecologically sustainable development.

                  The importance of greenspaces to a community's psychological and emotional
                  well being,  as well as  general health; and greenways to  the health and
                  adaptability of local plants and animals - Ecological sustainability protects, creates,
                  and enhances greenspaces  and in  so  doing, increases the aesthetic and economic
                  value of the urban landscape.  Greenspaces "make important ecological processes
                  more visible or apparent to [a community's] residents"  (Beatiey and Manning, 1997).
                  By creating urban greenspace, sustainable  development provides  accessibility and
                  visibility to the natural  processes,  which is critical to increasing the community's
                  understanding and appreciation for the ecosystem.   In  addition, greenways help
                  reduce fragmentation of natural habitats. This  increases the natural ability of plants
                  and animals to respond or adapt to changes in the ecosystem (Labaree, 1992).
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                  A  rapidly growing approach  being employed by  Federal  land management
                  agencies and non-profit conservation groups to achieve sustainable communities
                  is the concept of ecosystem management. According to the Ecological Society
                  of America,

                      "Ecosystem management assumes intergenerational sustainability as
                     a precondition for management rather than an afterthought. Thus,
                     the manager accepts responsibility up front for managing in such a
                     way as  to  ensure provision  of the  opportunities  and   [natural]
                     resources we  enjoy   today  to  future  generations.    Sustainable
                     strategies for the provision of ecosystem goods and services cannot
                     take as their starting  points statements of need or want  such as
                     mandated timber supply, water demand, or arbitrary set  of  harvests
                     of shrimp and fish.   Rather, sustainability must be the  primary
                     objective, and levels of commodity and amenity  provision  adjusted
                     to meet the goal" (ESA, 1996).
                  As evidenced by its guiding principles below, ecosystem management can serve
                  as  an effective  framework  for  planning and  decision-making  in  sustainable
                  development at the community level.
                      Table 3.1: Principles of Ecosystem Management (IEMTF, 1995)
                          A shared vision of the desired ecosystem condition
                          Coordinated approaches among all stakeholders
                          Ecological approaches to restore or maintain biodiversity
                          Incorporate sustained economic, sociocultural, and community goals
                          Respect and ensure private property rights
                          Recognize that complexity, dynamics, and heterogeneity are constantly
                          changing over space and time
                          Use adaptive management
                          Integrate best scientific information and techniques into decision-making
                          Establish baseline conditions for measurement and monitoring of
                          ecosystem functions and sustainability

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                  Another approach to ecological sustainability that can enable communities to
                  pursue sustainability through transition  periods is the  concept of interim use.
                  The  practice  of designating  individual  sites, clusters  or riparian  areas  as
                  greenspaces, on an interim basis, can provide unexpected value by increasing the
                  attractiveness  of a community.   This  contributes  to  the quality of life  of
                  neighborhood residents and to the value of their properties. In addition, it can
                  sustain wildlife habitat while providing food and  recreation to the community.
                  Examples  of interim uses  of greenspace are urban parks, gardens, and rails-to-
                  trails type of recreational spaces.
3.1.3   SustaJimtililyatlhePtojectLevd
Sustainability at the
Project Level

-


Characteristics


Sustainability of the
Redevelopment Process


Indicators of Sustainability



                  Although sustainability should be considered at all levels of decision making -
                  local,  regional,  national,  and global - the primary focus  of the  Brownfields
                  redevelopment  effort is at the local or community level.   This  is the primary
                  focus  of action for most stakeholder groups engaged in the Brownfields process.

                  In this case, local refers to the immediate environment in which the social actors
                  function.   This  environment  could  encompass  their  home,  work,   and
                  recreational setting (e.g. shopping, restaurants, etc.).  This may be a rural district,
                  neighborhood,  small town or a  major metropolitan center, depending on the
                  focus  of the active community.
3.1.3.1    CHARACTERISTICS OF PROJECT LEVEL SUSTAINABILITY

                  In order to translate the abstracted concept of sustainability into an operational,
                  project-level definition  to serve  as  the  basis for  a model of  sustainable
                  redevelopment, it is necessary to identify those attributes or characteristics of
                                             47

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                  sustainability  that can  be observed  and associated with  sustainability  at  the
                  project level.   Because the number of characteristics that can be associated with
                  sustainability  is large, these characteristics are grouped according to the three
                  primary systems or parameters (economic, ecological, social) that comprise  the
                  basis of human society.

                  At the project level, each of the societal systems serves to define  or provide
                  direction for  the redevelopment process.  The site profile (ecological system)
                  determines what can be done with the site  physically.  The community  profile
                  (social) defines what uses will be beneficial to the community and  saleable or
                  marketable to the developer.  The local economy (economic system) identifies
                  available  resources  for  development and  the  extent  to which  the local
                  community can support the development.

                  The important issue is to connect sustainability to activities at the project level.
                  The intention is not to impede the project, but to assist the  project in identifying
                  what sustainability really is  and which already  existing project activities will
                  support sustainability.

                     "The most successful projects have three characteristics in common:
                     First, the community created a  vision  of its future that  balances
                     economic, environmental and social needs. The community viewed
                     its future  in the long-term -  not  on the order of years, but  on  the
                     order of decades or generations.  Second, the vision incorporated the
                     views of a wide  cross-section  of the  community.   Third,  the
                     community figured  out how to keep track of its progress in reaching
                     that vision" (Hart, M., 1997(a)).

3.1.3.2    SUSTAINABILITY OF THE BROWNFIELDS REDEVELOPMENT PROCESS
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                  There  is a distinction between a successful  Brownfields Pilot Project  (i.e., a
                  project that meets its original goal of redeveloping a site that otherwise might
                  not be developed) and  a sustainable Brownfields  project.  The latter meets
                  criteria defined for  sustainability that may  not  be a  prerequisite  for  the
                  immediate success of the Brownfields project itself.

                  Although the determination  of sustainability  at  the project level  is somewhat
                  tenuous,  nevertheless, there are identifiable aspects  of sustainability, which  are
                  evident at the project level and which can be determined.  The remainder of  this
                  report will specifically focus on two basic components of the model framework: (a)
                  how the concepts of sustainability and Brownfields redevelopment are perceived  and
                  approached on the local level; and (b) the determination of the major elements  and
                  characteristics  of Brownfields redevelopment projects that can be associated with
                  sustainability in the redevelopment process.
3.1.3.3     INDICATORS OF SUSTAINABILITY
                  Apart from presentation of the framework of sustainability at the community level, a
                  review of the existing literature also indicates that many communities are developing
                  their own indicators of sustainability.  Although these are in part a function of the
                  unique goals and conditions  of individual communities, some general themes in
                  terms of what represent "good" indicators can be identified.

                  Employment related indicators are  considered significant measures  and include
                  calculation  of the concentration  of  employment; that is the portion of the  total
                  employment of a community that is carried by the largest employers. The lower the
                  concentration of employment, the greater the diversity of the community and hence,
                  the greater the potential for long term sustainability (Hart, M., 1997(a)).
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                   Other salient economic indicators include the actual rate of real unemployment, the
                   distribution of jobs and personal income across community residents, the percentage
                   of money retained within the community (leakage), and the total amount of money
                   available to the  community to  finance new development.    Lifestyle economic
                   measures are  often presented as potential indicators of  sustainability and  might
                   include the level of work required to fulfill basic needs as measured in hours of work
                   at the average community wage required to pay for the basic requirements (Hart, M.,
                   1997).

                   Social lifestyle, levels of education, and other community factors  also contribute to
                   the  long-term  sustainability  of a community and  are generally recognized in the
                   formation  of  indicators  of sustainability.   However,  these indicators  are  not
                   necessarily subject to the same precision of measurement that is characteristic of
                   economic measures  and are more likely to depend on criteria that are unique to the
                   specific community.  Some examples  include:  measures of cultural diversity, the
                   degree  of community  cohesion  and attachment to  the community exhibited by
                   residents, the level of access to cultural  and community defining events, the level of
                   urban sprawl development as opposed to development in core districts, etc.

                   A number of specific indicators of ecological sustainability have been defined by the
                   literature and are also the subject of discussion as to which are the most reliable or
                   applicable measures. In addition to standard indicators of environmental health such
                   as air and water quality, biodiversity, natural  resource consumption and thresholds,
                   and hazardous chemical  use, some additional indicators related  more directly to
                   sustainable development have also been identified. These include human population
                   growth and distribution, the amount of greenfield acreage consumed, the percentage
                   of sensitive habitat or endangered plant and animal species potentially threatened,
                   natural habitat resistance and resilience, changes in the modes of transportation used
                   or the length of  trips  made by residents, and energy consumption levels (Vogt,
                   1997).
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3.2  Overview of the Brownfields Redevelopment Process
  Secondaiy Data Sources
   Primaiy Data Sources
   Agency Interviews
  Primary Data Sources -
    Case Analysis
In order to develop a perspective on the Brownfields process itself, information
was developed from two primary sources.  The first was a review of secondary
literature, including information available as a part of electronic web  sites that
have  been  created  either by  the Pilot Projects  themselves,  or  by  other
organizations interested in environmental restoration, urban affairs, or economic
development. The results of this effort are presented in Section 3.2.1.  A second
source was developed through  structured interviews  with EPA, other Federal
agencies, local officials and project stakeholders.   The results of the  EPA and
Federal agency  interviews are  summarized in Section 3.2.2.   Section  3.2.3
presents the results of interviews with local officials and  project stakeholders
that were a part  of the on-site visits.  In addition,  a summary of each  of the 15
Pilot Projects that were selected  for extensive review is provided in Section 3.2.4.
32.1
                 The collection of secondary source data was concentrated on the most recent
                 literature available on the subjects under study. As the approach to Brownfields
                 redevelopment is  relatively recent,  it  was  assumed that the  most  current
                 materials would be fully developed and therefore more supportive of the analysis
                 proposed.   In addition to a general survey of articles published in print form
                 such as database information and selected  conference proceedings, sources of
                 data also included a review of the numerous electronic publications available on
                 the internet (see Appendix D for a summary of electronic sources consulted).
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                 The review of secondary sources incorporated a perspective that covered the analysis
                 of the Brownfields process from sources both external to, and integrally a part of,
                 the Brownfields process.
                 Apart from the real or perceived presence of contamination at a Brownfields site, a
                 number of key characteristics have been addressed in the literature that are applicable
                 to the sustainability of a Brownfields redevelopment effort.

                                Key Characteristics of the Redevelopment Process
Current and Future Land Uses
Historic Character
                                                          Pedestrian Orientation
                                                          Regional Open Space System
                   GIS Inventory
                   Regional Development Model
                                       Urban Growth Boundaries
                                       Transfer of Development Rights
                   Natural Processes
                   Multi-modal Transportation
                                       Transit Development
                                       Sidewalks, Walkways, and Bikepaths
                   Jobs-housing Balance
                   Affordable Housing
                                       Conservation Easements
                                       Land Trusts
                   Comprehensive Plan
                   Investment of Public Capital
                                       Purchase of Development Rights
                                       Urban Forestry
                   Sprawl Development
                   Density of Development
                  Current and Future Land Uses - Current land use is one of the factors to be
                  considered in determining the reasonably anticipated future land use of a site.
                  One of the tools for achieving sustainability is a Land Use Action Plan, (USEPA
                  "Green Communities", 1998) which considers both existing and future land uses
                  in the community.  The  Institute of Responsible Management's (IRM, 1997)
                  matrix of key Brownfields variables  also includes prior use  of target sites as a
                  component element for consideration.

                  In this context, land use planning is one of the most important tools available to
                  planners in influencing the pattern of development occurring in an area. Land-
                  use design and control  is one mechanism for implementing farsighted designs
                                            52

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                 that promote the sustainable city.  Designs for clustered development, higher
                 densities,  and live-work communities move toward a similar balance between
                 economy and the environment.
                 The challenge for land use planning is to obtain such a balance. In addition, a
                 sustainable development that aims to achieve social justice must also find ways
                 to avoid land-use development of the type that promotes housing segregation,
                 unequal property-tax funding of public schools, jobs-housing imbalance,  the
                 spatial imbalance of economic opportunity, and unequal access to open space
                 and recreation.

                 Historic Character - The town of Manchester, VT,  (Krohn,  1997) has  a
                 planning and zoning program that works to create guidelines that are consistent
                 with the town's  sustainable development vision.  It aims to preserve the town's
                 "village" atmosphere, protecting its  scenic, historic and natural beauty.  One of
                 the essential features of  the  IBA  Emscher Park project  in Germany is  the
                 preservation and re-use of its historic legacy.  Planners, architects and artists are
                 attempting to harmonize  the industrial  elements from the past with the entire
                 environment.   New  economically  viable uses  for nineteenth and twentieth
                 century architectural  and technological  monuments  and buildings  are being
                 sought.

                 GIS Inventory - A Geographic Information Systems database can prove to  be a
                 very valuable tool in the Brownfields redevelopment process. Hennepin County,
                 Minnesota Commissioner  Randy Johnson (1997) has said that GIS is one of the
                 most promising  innovations in new technology for local governments.  It allows
                 local  planners to analyze  and  manipulate large volumes  of data in remarkable
                 new ways, all within a geographic framework. GIS is a tool that is revolutionizing
                 local  government planning from urban design and zoning to environmental
                 management and economic development.
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                  The city of Baltimore (Leavy & Paull, no date)  is nearing completion  of a
                  comprehensive  GIS  Inventory of vacant  and underutilized commercial and
                  industrial sites.  This inventory details over 25 fields of information on each site,
                  including the location, acreage, ownership, proximity to transportation modes,
                  etc.  Public  information  regarding environmental conditions  and regulatory
                  status  will  be  part  of the database.   The  inventory will feature  digitized
                  photographs of many of the sites and will be used both for planning purposes
                  and to market and promote sites to private investors.

                  Integration of Brownfields into a Regional Development Model - One of the
                  best ways for communities to generate new  investment, business  expansion,
                  employment, and  income growth  is  through  metropolitan  cooperation  by
                  developing  regional approaches  for economic growth,  environmental quality,
                  and social equity.  HUD Secretary, Andrew Cuomo, (1997)  has  said, "the heart
                  of the  metropolitan economic strategy is the recognition that metropolitan
                  regions are  fundamental building blocks of the nation's economic prosperity in
                  the globally competitive marketplace."

                  In his article titled, "In America's Cities", John J. Dijulio, Jr.  (1997) has said that
                  community institutions need to place their neighborhood strategies in a regional
                  context,  understanding how  government  policies  interact with  the larger
                  economy, and engaging where appropriate, in  metropolitan issues and decision
                  making.  The new challenges of persistent poverty, economic restructuring and
                  demographic transition now require communities to reach out to a regional  level
                  of decision-making.

                  The Joint Center for  Sustainable  Development  (1997) states  in its  progress
                  report  to the  President,  "If we  are  to  become  a  nation  of  sustainable
                  communities in  the 21st century, we must develop new strategies that enable city
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                 leaders to work together with their counterparts in surrounding suburban  and
                 rural jurisdictions."

                 Integration  of Natural  Processes  into  Community  Infrastructure  -  In
                 "Recommendations  for Action Planning,"  (EPA,  1998), EPA has proposed
                 encouraging  industrial land developers to  preserve natural  amenities and to
                 incorporate natural  features and  environmentally  beneficial landscaping into
                 their development proposals.

                 Multi-modal Transportation - ISTEA - The Intermodal Surface Transportation
                 Efficiency Act (ISTEA) promotes the concept of multi-modal transportation. It
                 introduced  a comprehensive  approach to  planning,  one  that  removes  the
                 incentives for building highways rather than other transportation modes, such as
                 mass transit  and even bike  paths.  It also encourages  transportation decision-
                 makers to better integrate the transportation facilities and systems already there.
                 In  order to qualify  for ISTEA funds,  decisions must be made in a way that
                 makes the most sense for the long-term  economic, social, and environmental
                 vitality of the community.  This is also essential to the building of sustainable
                 communities.

                 Jobs-housing Balance -  One of the factors  contributing to  a sustainable
                 community is the degree to which people working in a community live near their
                 place of work. It is important to strike a balance between the  two kinds of uses,
                 residential and commercial/industrial, to achieve a healthy, vibrant community.

                 The Maryland Department of Housing and Community Development (May
                 1997)  is developing  a "Live  Near Your Work" (LNYW) program to encourage
                 employees of Maryland's  businesses and  institutions to buy  homes near their
                 workplace.   The goal of  this  initiative  is  to stabilize the  neighborhoods
                 surrounding  the State's major employers  by  stimulating homeownership in
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                 targeted communities.  The LNYW program would provide a minimum $3000
                 cash grant to homebuyers moving to targeted neighborhoods. The State would
                 contribute $1000 per homeowner, which would be matched by contributions
                 from both the local government and the employer.

                 Affordable Housing -  Social sustainability implies equal  access to adequate
                 services and  employment by all members of a community. As noted  by the
                 Center of Excellence for Sustainable Development (1997), in examining housing
                 opportunities in a community, it is important to determine what percentage of
                 housing is designated for low  income  earners, and how the  needs   of the
                 different sectors of the community are being met. One of the important criteria
                 is the percentage of households that have below average income and spend less
                 than 30 percent of their income on housing (including utilities).

                 The Clinton  administration has  embarked on an ambitious plan to demolish
                 some 100,000 public housing units  -  about one-twelfth  of the  entire  public
                 housing stock - by the year 2000.  Creative replacement efforts are under way in
                 many cities,  with greater emphasis  on smaller-scale, economically integrated
                 affordable housing developments.

                 Existence of Comprehensive Plan -  The primary purpose of a comprehensive
                 plan is to enable local government officials and citizens to anticipate and to deal
                 constructively with the  changes  occurring within their community.  The plan
                 includes an analysis of past trends and development, existing conditions,  as well
                 as goals and objectives for the  future and  proposals  for accomplishing these
                 goals, objectives, and policies.

                 The Baltimore City (Maryland) Department of Planning  is now engaging in the
                 creation of  a  new citywide Comprehensive  Plan.    Key topic  areas  and
                 subcommittees of Plan Baltimore (Leavy & Paull, No Date) include Community
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                 Economic Development, Housing, Transportation, Public Facilities, and Urban
                 Design.  Brownfields revitalization  is an explicit part of both the Community
                 Economic Development and the environmental elements of the plan.

                 The primary  end product  of the  city of Seattle's  Sustainable Development
                 Initiative,  "Toward  a Sustainable Seattle,"  is  a  comprehensive plan framed
                 around making  the  city  sustainable  into  the 21st  century.   Chattanooga
                 (Tennessee) also has produced two comprehensive "visioning" plans,  Vision
                 2000 and Revision 2000, as well as various specific  plans for individual projects,
                 as a guide for its sustainable development initiative.

                 Public Capital Investment - Public  capital investment and the manner in which
                 a governmental entity patterns and times such investment can be an important
                 tool in the development and redevelopment of land; and a major determinant of
                 land value. The increased land value realized by public capital largely determines
                 the intensity of development.  The type and amount of investment precludes
                 development options and intensities, shaping the amount of development and
                 the way development takes place.

                 For example, in the Washington, D.C. metropolitan area, the construction of a
                 subway stop can create millions of dollars in land values due to the accessibility
                 now afforded the location. Subway accessible locations often become nodes of
                 future development.   The mere unveiling of such public capital investment at a
                 certain location is sufficient to increase real estate speculation for  a radius  of
                 several blocks around the site (Levy, 1994).  The development and  design of a
                 whole region  can be  shaped by public capital investments in highways, public
                 transportation,  parkland,  and water  and  sewer  capacity.   A  community's
                 estimated  or  projected  future  needs  can  be  compared  to  the  present
                 infrastructure  to determine  needed  modifications or augmentations to foment
                 development.
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                  Public capital investment and land use controls, the principle methods by which
                  communities can affect development/redevelopment, should be coordinated to
                  reinforce each other.  It is important for a community to outline  its  needs and
                  synchronize these methods with the comprehensive plan to ensure fruition of
                  those needs.

                  Avoidance/Prevention of Sprawl Development - Sprawl is a pattern of physical
                  development characterized by the decentralization of land uses. It is caused by
                  the separation of land uses brought about by zoning.   The need  for single-use
                  zones was  primarily  in response  to the conditions  created by the  mix  of
                  polluting and unhealthy industrial uses in residential areas. Modern zoning since
                  the late  1920s  has essentially  involved such a separation of uses.  The resulting
                  sprawl development requires the use of a private vehicle  to  move  from one
                  single-use zone to another.  The success of this development has  destroyed the
                  pedestrian way of life and the support for mass transportation.

                  The  Maryland Senate passed a bill  (State Bill 389,  1997)  aimed  at channeling
                  State infrastructure  to designated growth areas.  This is  the Smart Growth
                  initiative that  seeks to guide development away from rural and environmentally
                  sensitive areas and  toward  those with the necessary infrastructure to support
                  growth.  The bill would channel State spending to areas  inside the Baltimore and
                  Washington, D.C. beltways, incorporated cities and towns, and  certain industrial
                  and commercial areas  chosen  by county governments.

                  Density  of Development - Sprawl has proliferated in many areas  due either to
                  current  land use policies, or  their absence.  There has traditionally  been little
                  focus on  controlling  growth.    Low-density  sub-urbanization  has  been
                  encouraged by Federal tax deductions and mortgage guarantees for single family
                  residences.  Not all the  direct costs of servicing low-density developments are
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                  passed directly to the homeowner; some of them are hidden. In his study of the
                  fiscal  costs of low-density housing, J.  Dixon Esseks  (1998) has  noted that in
                  addition to the increased safety risks associated with longer response times for
                  public safety  services, the tax revenues generated from sprawl development in
                  urban  fringe  areas failed  to cover  the cost per mile  for  the increased roads
                  required to service the communities.

                  Greater density can be encouraged by municipalities in many ways.  Residential
                  infill development allows builders to construct buildings on abandoned or vacant
                  lots in between existing structures.  Residential conversion can be achieved by
                  subdividing dwelling units to  create additional  units,  such as basement flats.
                  Infill  and  conversions  make greater  use  of  infrastructure and services  and
                  thereby increase efficiency in  residential environments.  Cluster development
                  which  involves grouping housing units tightly together in  a landscape so  that
                  they share servicing structures, while leaving the rest of the site for open space
                  and recreational areas, protects the prevailing features of the landscape.  Cluster
                  development  also provides the economic  and social  benefits of high-density
                  settlements while conserving landscape  function.

                  Pedestrian Orientation - Many communities are using light rail and pedestrian
                  friendly design to change  the negative  impacts  of the  automobile.   The West
                  End Neighborhood of Vancouver, British  Columbia (Durning, 1997)  provides
                  one of the answers to creating a sustainable and environmentally  sound way of
                  life. It is  a model of good  urban design, which creates a public realm that is safe,
                  inviting, and  conducive to the community.  The road intersections  have raised
                  concrete  planters that  are landscaped  with trees and  shrubs.   The traditional
                  street  grid is broken with such diverters that provide smoother traffic flow  - by
                  foot, bicycle and even car - than the sprawl model of cul-de-sacs, feeder roads,
                  connector roads, and highways.  The neighborhood's small blocks and narrow
                  lots not only  make walking more interesting, but slow traffic, as drivers tend to
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                  adjust their velocity  based on available road  space, not  posted speed limits.
                  Parked cars in the curb lane make pedestrians feel safe from traffic, while a row
                  of street trees and grass, and landscaping between  the sidewalk and buildings
                  further encourages walking. Smaller setbacks from the street give a human scale.
                  Regional Open  Space  System  -  One of  the  significant goals of the  IBA
                  Emscher Park Project in Germany was the  establishment of a green corridor,
                  connecting  17 cities, using existing water-courses and greenspaces  - Emscher
                  Landscape Park. A common element found in  many comprehensive plans in
                  various parts  of the world is the  retention  of a system of greenspace that helps
                  to  ensure a continuum from a  low-density rural periphery to  a high-density
                  urban core.

                  Besides providing parks, recreational fields and trails in a metropolitan area, such
                  a greenspace  system  also plays  a major role in  shaping development patterns
                  throughout the region.  By  developing a  comprehensive  system of parks and
                  trails,  the greenspaces of a region can be used to serve as a boundary between
                  urban and rural  areas,  and can  steer new development away from the urban
                  fringe.  The  benefits of greenspace  plans for managing the  growth of urban
                  regions include: efficient allocation of public infrastructure, preservation of open
                  space  resources, and reinvestment in central cities.

                  Urban Growth Boundaries  - Urban growth boundaries  are sets of planning
                  tools that manage growth around urbanized areas to  promote high densities and
                  prevent sprawl development into outlying areas.  Urban growth boundaries can
                  be a  valuable tool  in  making  transit service  more  effective  and targeting
                  development  along transit-oriented designs.

                  The   Buckingham  township   project in   the  Metropolitan  Philadelphia
                  (Pennsylvania) area is promoting  municipal land use regulation that increases the
                  density  in some spaces while protecting  open  space elsewhere (Greenspace
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                  Alliance,  1997).   To accomplish this goal, one of the  mechanisms that  the
                  township is considering is the creation of urban-growth boundary lines. This is
                  a type of comprehensive greenspace planning, known as greenbelt planning.

                  The primary benefit of greenbelts is the preservation of a ring of open space at
                  the urban/rural fringe.  While defining a  boundary for growth, greenbelts help
                  to foster easier circulation among densely  developed areas while maintaining the
                  rural character of areas beyond.  The presence of greenbelts effectively prevent
                  the extension of public investment in infrastructure and transportation to a wide
                  area  of low-density, single  use  development  of the type often  considered
                  synonymous with urban sprawl.

                  Transfer of Development Rights - Transfer of Development Rights  (TDK), or
                  the  sale of one  parcel's development rights to  the owner of another  parcel,
                  allows  more development on the  second parcel and  reduces or prevents
                  development on the originating parcel.   Under such  a program, development
                  rights are severed from  a lot designated  for protection (sending area) and  the
                  severed rights are transferred to a lot in an area where additional development is
                  permitted (receiving area).

                  Montgomery County, MD has used the device of TDK to preserve agricultural
                  land  (Johnson & Madison, 1997).  The county chose  growth areas that already
                  had infrastructure in place, as receiving areas, allowing them a  higher density
                  through the use of TDRs.   Receiving areas should allow sufficient  density to
                  attract developers, yet the housing density allowed must also be compatible with
                  existing development.

                  High-density Development with Well Integrated Transit  Development - While
                  auto-oriented transportation infrastructure is associated with sprawl, the reverse
                  effect can  be achieved by land  use  planning focused  on attaining  higher
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                  densities, along with well-integrated transit development.  A study of major cities
                  around the world (Center for Renewable Energy and Sustainable Technology,
                  no  date)  concluded  that,  based  on  auto  access,  a  city's  center could
                  accommodate an approximate maximum of 120,000 jobs.  Beyond  that point,
                  office space must be sacrificed for additional parking and road space.   Instead,
                  providing access to the city center by mixed modes of road and transit can allow
                  a city to grow beyond that point while remaining attractive and livable.

                  Transit can induce high-density commercial development because it represents
                  to developers  and employers an investment in fixed facilities that will  be in place
                  for a long time.  Other studies have shown that well  planned transit systems can
                  concentrate housing and urban  amenities around  transit  lines and  stations,
                  reducing reliance on cars.  Total travel demand in regions that have successfully
                  integrated high-density and  transit may be four to  eight times lower than  in
                  other areas.

                  Network of Sidewalks, Walkways, and Bikepaths - One of  the priorities of the
                  town of Manchester, VT, as outlined in its Community Vision, is to maintain an
                  efficient and safe park-and-walk environment. It proposes to have a network  of
                  sidewalks, walkways, and bicycle paths  connecting  all parts  of town, linking
                  residential areas with recreation, commercial, government, and essential services.
                  The goal is to have  parking areas  that will be attractive and well integrated into
                  the walkway system.

                  Conservation Easements - The Smart Growth and Neighborhood Conservation
                  initiative of the State of Maryland also includes the  Rural Legacy Program that
                  will establish greenbelt areas throughout the State. It will redirect existing State
                  funds  into  a focused and  dedicated  land preservation program  specifically
                  designed to limit the adverse impacts of sprawl on agricultural lands and natural
                  resources.
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                 The program will reallocate State funds to purchase conservation easements for
                 large contiguous tracts of agricultural, forest and natural  areas in open space
                 where public access and use are needed and are generally subject to development
                 pressure and fee interests.  Local governments and private land trusts will be
                 encouraged to identify Rural Legacy Areas and to competitively apply for funds
                 to complement existing land conservation efforts or create new ones.

                 A similar program in Routt County,  CO (1987) resulted in the setting aside of
                 over 10,000 acres as perpetual ranch land through conservation easements.  The
                 county  approved  a  tax-increase  initiative  specifically for  purchasing  such
                 easements.

                 Land Trusts - The town of Dunn, WI (Gausman, 1997) has created a land trust
                 to  permanently protect  farmland  and  environmentally sensitive areas.   The
                 Community Land Trust model  creates and  maintains affordable housing by
                 separating the cost of housing from land costs.  The land is purchased and held
                 in  trust by a non-profit organization.   The  Lopez  Community Land Trust
                 (LCLT) is one  such land trust on the island of Lopez, one of the hundreds of
                 islands  making up the San Juan Archipelago.  People interested in  owning an
                 LCLT home lease the land and purchase their home.  As  a result of volunteer
                 labor, costs are kept down due to the  involvement of the LCLT.

                 Purchase  of  Development  Rights -  Through  this   mechanism,  willing
                 landowners  sell their property's  development rights  to  an "easement  holder"
                 such as a land trust.  This was one  of the recommendations made  in the plan
                 for  Routt County  (Colorado) to maintain the  viability  of  agriculture in  the
                 county.     The county  citizens  voted  to  approve  a local  ballot initiative
                 authorizing  a one-mil property tax increase for the purchase  of development
                 rights.
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                  The town of Dunn, WI is also preserving environmentally sensitive areas from
                  any future developments by purchasing development rights. The town recently
                  began purchasing the development rights to permanently protect farm and open
                  space lands from development with the help of citizen contributions. The town
                  will be prevented from selling the development rights to a future developer by
                  the very nature of this transaction.

                  Urban Forestry -  The planting  and maintenance of trees  within  a  city or
                  community is called  Urban Forestry.  It  is an important strategy for reducing
                  both  carbon emissions  and energy expenditures for urban heating and cooling.
                  According to the August/September 1991 issue of Urban Forests  magazine,  "as
                  much as  15 times the amount of carbon can be  prevented from entering the
                  atmosphere through the energy-conservation effects of an urban  tree as can be
                  retained through carbon storage alone."  In addition, the studies cited indicate
                  that energy savings from trees planted near homes and buildings range from 10
                  to 50 percent for cooling and from 4 to 22 percent for heating.

                  Planning Tools for Achieving Sustainable Community Development - Planned
                  Unit  Developments  and  cluster  developments are one  form  of large site
                  development wherein housing units  are clustered  together rather  than  evenly
                  distributed  across the landscape,  so  that a contiguous  area of  open space is
                  preserved.  This  very often is the area where environmentally sensitive land is
                  located, such as  wetlands.  Public facilities are also made more efficient as a
                  result of such layout of development, as opposed to the old single-lot-by-single-
                  lot approach.   San  Luis  Obispo  County  on  California's  central coast uses
                  clustering as a positive planning tool.

                  Performance zoning is  a technique in which project specific criteria are set  for
                  such  factors as noise, access to sunlight, pedestrian access, and the emission of
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                  pollutants. This is different from the traditional, and still prevalent approach, to
                  set  zoning  standards  that  may  have  limited  relevance  to  the  site  or
                  environmental conditions.

                  Special areas  designated for  case-by-case review when  developers wish  to
                  proceed with projects  that meet the general plan's intent for those areas that are
                  known as special exceptions  or special land use districts.  This tool permits
                  greater flexibility and  promotes innovative types of projects.  It maintains the
                  integrity of the general plan, but works only when it is not abused.

                  Bonus regulations allow the jurisdiction to permit higher densities, exceptions to
                  parking requirements, or other bonuses if the project in  turn provides public
                  improvements, helps preserve open space or achieves other planning goals.

                  Impact fees  are  a systematic,  comprehensive way of funding the new capital
                  facilities required by new development.  The fees are assessed against developers
                  by a determined measurement of the impact the new development is presumed
                  to impose on the community.  The cost of new public facilities is estimated and
                  attributed to  new  and  existing  developments  in  an area.   A prescribed
                  formulation  allocates  the  appropriate  proportion  of  the  cost  of  each
                  development.   The  community  covers  the  costs  attributable  to  existing
                  developments, while  developers must bear the associated  costs  of the  new
                  development.  This method allows local governments to fund  improvements
                  where it is most appropriate and when it is most convenient.

                  Inclusionary Zoning requires developers building more than a specified number
                  of housing units to set aside a certain percentage for low- and moderate-income
                  households.  The inclusion  of low- and moderate-income households,  in this
                  case, is not discretionary and provides a way to fill a housing void while reducing
                  the burden on the local government to provide for low-income families.
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                  Subdivision regulations are a governmental tool that  controls the manner  in
                  which  tracts  of land  over a certain size may be subdivided or converted into
                  buildable lots, and regulates the provision of infrastructure.  The regulations will
                  also stipulate what improvements must be made before  building lots can be sold
                  or building permits issued.  This form of regulation often ensures the extension
                  or provision  of sewer, water, and drainage facilities, and the alignment  of roads
                  with the municipal street network.
3.2.2
     Suslainabiilyand
     Perception of the
                                                  Wlhffl
                  The structured interviews proved to be the most valuable source of quality data
                  for relating the concepts of sustainability with Brownfields redevelopment at the
                  community  and project levels.  Information collected through the structured
                  interviews with EPA,  other  Federal agencies,  and on-site Brownfields  project
                  stakeholders was  current and directly relevant to the exploratory nature of this
                  phase  of the  study.    Wherever feasible,  declarative  statements by those
                  interviewed  were validated with at least one other source  familiar with the
                  project or program.
                  The structured interviews  focused on  identifying  key elements of sustainable
                  Brownfields redevelopment and their  characteristics  by exploring topics in a
                  consistent format with all officials.  This approach not only helped to verify the
                  data as it was being collected,  but it also provided insights to how differently or
                  similarly Brownfields projects  and sustainability are perceived across a relatively
                  small sampling group.

                  The following is a summary of key concepts and themes identified through the
                  interview process with EPA and other Federal agency officials.
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3.2.2.1     SUSTAIN ABILITY AND SELF-SUSTAINABILITY


                  In general,  many conceptual interpretations  of these two  terms  exist.  The two
                  underlying issues found were: a) where is the focus placed; and b) from where is the
                  focus  financially supported?   The focus  should  be  on  how a Brownfields
                  redevelopment can  contribute to the ecological, economic, and  social sustainability
                  of the community,  rather than on how to sustain the Brownfields redevelopment
                  process. A corollary to this point is not whether the Brownfields redevelopment is
                  sustainable,  but whether the community can  sustain  the  resulting development.
                  Brownfields   redevelopment  can   become   self-sustainable  as  the  primary
                  organizational, technical, and funding resources evolve from predominantly Federal
                  government involvement to the local government level.  The goal is for ultimate
                  evolution to a community and/or free market driven process with minimal or no
                  Federal  involvement. In  either  case, sustainability  as  it relates to Brownfields
                  redevelopment is viewed more as an evolving continuum, with long-term closed
                  loop  self-sustainability   and   short-term   environmentally   sound   economic
                  development at the  two preferred extremes.


                  Several  officials pointed  out  how  important it is that  the  elements  of
                  sustainability  should enhance the  Brownfields  efforts and  not hinder  it by
                  imposing a rigid set of requirements early on in the effort that may diminish a
                  project's chance   for success.    Basically,  the community  must  determine
                  sustainability.  What ultimately constitutes sustainable development will vary with
                  each community.  It must reflect the community's current and future values and
                  principles, maintain involvement of the community members in order to adapt
                  to changes, foster a sense of pride  and responsibility  among the  residents,
                  provide opportunities for social and economic growth, and foster improvements
                  in the overall quality of life without impairing that quality for future generations.


3.2.2.2         PERCEPTION OF THE  BROWNFIELDS INITIATIVE
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                  Overall,  the  officials interviewed shared  common views  of the  concept of
                  Brownfields redevelopment. It should not be viewed as a component of the Federal
                  CERCLA program for cleaning up abandoned hazardous waste sites.  Rather, the
                  redevelopment  of Brownfields  properties is  essentially a  real estate transaction
                  and/or land development process that includes, as a critical component, the need to
                  assess and manage the potential risk to the neighboring public and environment that
                  any hazardous chemical  contamination may pose at  a site.   As such, Brownfields
                  redevelopment  is a  different  paradigm  from CERCLA and RCRA regulatory
                  programs.

                  Every site is unique because of its location, extent and nature of contamination,
                  redevelopment  potential  or   marketability,   political,   and  socioeconomic
                  considerations. Site restoration requires a locally driven approach as opposed to
                  being driven  by a Federal or State agency. Due to the number of stakeholders
                  with different objectives and the varying stages at which they become involved,
                  implementation is  no  longer  a single  process  or  standardized procedure.
                  Instead,  it represents an iterative progression of an assortment  of processes,
                  occurring either in series or  parallel to each other, and each requiring its own
                  unique  management capabilities, technical  and  financial expertise, resource
                  requirements, and technical tools.

                  Brownfields should be considered as one component within the broader context of
                  economic development since they represent viable assets to the community to create
                  jobs, enhance the community's appearance, and counteract urban sprawl and loss of
                  greenspace. In many cases, they represent the seeds for long-term restoration of the
                  community's quality of life. However, a major concern expressed by several  officials
                  is that an emphasis on Brownfields redevelopment efforts should not cause a shift of
                  existing commercial and industrial businesses from one location to a new one within
                  the  same  or neighboring communities,  thereby  creating  a new  Brownfield.
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                  Brownfields,  therefore,   should   be  addressed  within   a   regional  economic
                  development plan as well as local municipal planning efforts.  Emerging  "smart
                  growth" or "controlled growth" policies and planning initiatives, such as those in the
                  State  of Maryland, Portland, Oregon and the Twin Cities complex in Minnesota
                  represent strategies that seek to address these issues.

3.2.2.3     DISTINCTION BETWEEN URBAN AND RURAL BROWNFIELDS

                  Many  of the Federal officials  interviewed identified the major difference between
                  urban and rural Brownfields redevelopment programs as related to the extent of the
                  resources  available at  the  local  government  level.   For the  most part, rural
                  governments do not have the organizational infrastructure that larger metropolitan
                  governments do.  Therefore, it may be beneficial for rural projects to be integrated
                  into regional or State-coordinated strategies in order to access  the broader range of
                  full-time staff resources  needed  for organizing,  planning, assessing, marketing,
                  negotiating, and monitoring site restoration.

                  On the other hand, a few Federal officials indicated that the two types of projects are
                  completely different; all of the important factors change between the two.  Specific
                  examples include:

                  •   taxes are higher in the urban area;
                  •   most cities have antiquated zoning restrictions;
                  •   there is often  less public opposition to development in rural areas;
                  •   cost scales for development and project management in urban areas are typically
                      higher;
                  •   the process to get development approved is subject to more requirements in the
                      city as  opposed to the suburban fringe where it is  usually a much speedier
                      process
                      (and the rural "greenfield" represents the easiest and fastest of the three);
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                  •  local governments are less willing to subsidize infrastructure development in the
                     center  city,  but will  allow  extensive local  subsidy  for  new  infrastructure
                     development on the fringe or rural areas;
                  •  urban sites are more vulnerable and interconnected to changes and influences in
                     the surrounding community, which is typically less stable than rural areas, due to
                     increased population mobility, growth, and ethnic composition; and
                  •  urban sites are often small parcels of land that are either scattered  throughout
                     the community or in a patchwork within an existing development area.

                  A considerable amount of data was collected and analyzed from the structured
                  interviews  of Federal Agency officials  that relates to the specific  elements and
                  characteristics of sustainable Brownfields redevelopment.  These are discussed in
                  Section 4.0 of this report.  A detailed summary of EPA and Other Federal Agency
                  Data Sources is included as Appendix E.
323    PfimatyDa.ta. Som^—StcuxtWKdJtitEfviews \vith On&teMunidpal Officials andPfcject
       Stakehddets
Primary Data Sources -
On-Site Interviews


Dudley Street -Boston

Cape Charles -VA

Chattanooga -TN

New Orleans -LA

State of Rhode Island


                  Structured interviews  were conducted with a variety of stakeholders from four
                  ongoing EPA Pilot Projects and one ongoing Brownfields redevelopment that is not
                  part of the EPA initiative.  The stakeholders interviewed onsite represent a  cross-
                  section of municipal officials, community leaders, private developers, and others that
                  have key roles  in local redevelopment efforts.   The  following summaries  are
                  presented by municipality and highlight major concepts and themes  that are  not
                  incorporated into the discussion of specific parameters, elements and characteristics
                  presented in Section 4.0.  A detailed summary of the on-site interviews for each
                  project can be found in Appendix F.
3.2.3.1     THE BROWNFIELDS ECONOMIC REDEVELOPMENT INITIATIVE'S (BERI) DUDLEY
           STREET NEIGHBORHOOD REDEVELOPMENT, BOSTON, MASSACHUSETTS
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                  The primacy focus of Boston's BERI is the Dudley Street Neighborhood. There are
                  over 1,300 vacant lots in the neighborhood; accounting for 9% of the State's listed
                  contaminated sites.  The Pilot Project's objective is to address these Brownfields as
                  part of a multi-dimensional revitalization strategy for the Dudley St. neighborhood.
                  The EPA Pilot Project Grant was awarded in September of 1995.

                  The Dudley Street  corridor  is a major  urban thoroughfare  running through the
                  Roxbury section of Boston to Dorchester. Roxbury and Dorchester have borne the
                  brunt of Brownfields creation during the past 20 years.  The overall vision for this
                  redevelopment was  the creation  of a "Dudley Urban Village" — a self-sustainable
                  community  within  the  city.  To  achieve  this  vision,  the Boston  Brownfield
                  Partnership  Task Force  was  created.   It  is the  primary organizational  body
                  responsible  for  planning, coordinating, and implementing the  redevelopment
                  process.  The BERI Task Force is a public/private partnership between the City, the
                  Boston Redevelopment Authority and several diverse neighborhood organizations;
                  and is coordinated by a member of the City's Environment Department.

                  Sustainability — Several respondents agreed that a project is sustainable if it satisfies
                  the goals and criteria that the community defines for it. The focus on sustainability
                  in Boston has  been limited primarily to completing site assessments and preparing
                  the individual  sites for  the  next  phase  of redevelopment,  and  encouraging
                  redevelopment ideally  by a closed-loop type  of sustainable industry or at the very
                  least by environmentally conscientious businesses.  The greatest barrier that BERI
                  encountered to achieving their sustainability goals was obtaining private property
                  owners'  participation  in  the  Brownfields   project.    Without  private  owner
                  participation, sites could not  be properly assessed for environmental contamination
                  and  integrated into community planning efforts.   Hence, efforts  to  identify
                  sustainable industries were also impeded.  The resulting opinion of most respondents
                  was  that, although privately  owned  Brownfields  have  the same  potential  to
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                  contribute to sustainable redevelopment in the community, the likelihood of success
                  is much less than with publicly owned properties.

                  Perception of the  Brownfields Redevelopment Concept - The  Brownfields
                  process  is seen as an open forum for providing private  property  owners and
                  developers with advice and technical assistance from the community and regulatory
                  agencies.  As such, it is not considered a process as much as it is a "tool kit" from
                  which needed  information and resources  can  be obtained through community
                  leverage.  In Boston's case unfortunately, some private property owners  either would
                  not respond or were unwilling to participate with BERI. In another point, members
                  of the community apparently developed a misconception of Brownfields and created
                  unrealistic expectations of what the Pilot Project could accomplish.  This emphasizes
                  the importance of providing effective community outreach and education early on in
                  the project.

                  The  respondents  all emphasized the importance of empowered leadership  in
                  sustaining a Brownfields redevelopment project.   They recommended centralized
                  control  of the project under  a local  public/private partnership or non-profit
                  organization.  If the local municipality must take the lead, the municipal project
                  coordinator should be designated  at the office director level and located within the
                  economic development section  of the local government,  be given a clear mandate
                  and authority for decision-making and expenditure of public grant funds, and receive
                  the full commitment and support of the local government.

                  The Pilot Project also demonstrated the importance of community involvement in
                  formulating a common vision for the neighborhood and in obtaining community
                  acceptance of  projects.  In addition,  it pointed  out  the  essential requirement to
                  provide public  education to community members early in the project.  This enables
                  the community to understand the nature of risks posed by chemical contamination
                  and technical aspects of site assessment and cleanup processes.  It also  makes them
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                 aware of how the real estate  development process occurs, what the role of the
                 coordinating organization is, and the constraints and economic forces at work on the
                 project.  Without a proper understanding of these factors, community participation
                 can actually hinder progress.

3.2.3.2    THE PORT OF CAPE CHARLES SUSTAINABLE TECHNOLOGIES PARK, TOWN OF CAPE
          CHARLES AND NORTHAMPTON COUNTY, VA

                 The Pilot Project site is the Port of Cape Charles Sustainable Technologies Industrial
                 Park (STIP). This site is proposed for the town of Cape Charles, VA as a means of
                 creating sustainable economic development for this rural community and the County
                 of Northampton as a whole. The Brownfields Pilot Project Grant was awarded in
                 September of 1995. This project has been  selected by the President's Council  on
                 Sustainable Development as a demonstration project.

                 Much of the  Brownfields  site is  a former  refuse dump, railroad  yard, and
                 abandoned industrial operations area. A Phase I survey has  been completed.

                 The master plan for the redevelopment includes creation of operating standards
                 for the STIP that have been embodied in a set of covenants recently approved
                 by the town council.  The Town of Cape Charles has acquired part of the land
                 designated  for  redevelopment,  a portion  of which is leased to the Industrial
                 Development Authority for use as the first phase  of the project,  which is the
                 eco-industrial park.   On completion, the  park  will become part of a larger
                 redevelopment  project that includes expanding the  eco-industrial  park itself, a
                 restored wetland area and nature trail, an environmental education facility, and a
                 tertiary sewage  treatment facility.  Additional development of a recreation area,
                 including  the  potential  construction  of golf courses,  and  a residential
                 condominium is planned for an adjacent site.  A companion development along
                 a strip of underutilized retail and commercial buildings on the main street of the
                 city is also anticipated.
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                  All the local  stakeholders interviewed in the Cape Charles community were
                  participants in a community-based charrette designed to formulate a new vision
                  for the region and citizen commitment to sustainable development. As a result,
                  all  the  respondents   shared  common  perspectives   regarding sustainable
                  Brownfields redevelopment.

                  Sustainability — The concept of sustainable development is seen as a goal oriented
                  process, rather than a desired outcome, in which it does not matter what parameter
                  is  emphasized — ecological, economic or social — as  long as development efforts
                  strive for all three parameters to converge.  Thereby,  sustainability is the preferred
                  direction in which the development efforts evolve; is  based on community values;
                  and is driven by a vision, a plan, and the people of the community. In this concept,
                  what  is actually completed is  less  important  than  the  manner in which  it is
                  accomplished. The underlying principle is: "Does it make sense for the community?"
                  (Hams, 1998).

                  Based on this concept, sustainable development doesn't necessarily mean replacing
                  defunct industries with high tech businesses. A low-tech business may be preferred
                  if  it matches the needs of the local  labor  force.  The objective is  to  develop  a
                  diversified economy, matched to the workforce, which can  provide challenging
                  opportunities to promote  workforce growth,  both in  terms  of numbers and
                  knowledge levels.

                  Perception  of the  Brownfields  Redevelopment Concept  -  Brownfields
                  redevelopment is perceived as part of an economic development process  that is just
                  one component of an overall community improvement strategy.  The key to the
                  process  is to view the risks as  shared community responsibilities for  addressing
                  problems as opposed to one-sided liabilities. To accomplish this, the respondents
                  believe stakeholders must avoid categorizing issues, problems, and tasks, and instead,
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                  consider them as part of a holistic approach to a restoration process.  This strategy
                  should also include cooperation among organizations and jurisdictions by focusing
                  on how to make the project succeed rather than whose jurisdiction or responsibility
                  an issue may be. The Cape Charles community found multiple ways to promote this
                  cooperation.   They have integrated local Brownfields redevelopment plans with
                  comprehensive master plans for the town, county and region.  A common vision
                  and commitment have been promoted through community meetings and task force
                  charrettes.  They  have also  combined  town and county owned land to create a
                  groundbreaking, eco-industrial park that features state-of-the-art, solar technology
                  manufacturing; not only as its anchor industry,  but also  by incorporating the
                  company's solar panel technology into the facility design itself.

                  In the case of Cape Charles, the initial redevelopment  process  began with an
                  Enterprise Community effort focused on economic development — not Brownfields
                  redevelopment. The community created an Enterprise Community Strategic Plan
                  that included an emphasis on sustainable economic development. The plan did not
                  try to meet the abstract definition  of sustainability.  Instead, sustainability concepts
                  and an environmental consciousness were integrated into the planning process. The
                  Brownfields component was added  afterwards.   The impetus that initiated the
                  process, and sustains the momentum today,  is  recognition by both new and
                  longtime residents of the poor economic condition throughout the community and
                  the threat this condition poses to the lifestyles of all the residents.

                  Each of the respondents expressed concerns that limited staff resources and funding
                  pose the greatest barriers to this rural community's Brownfields redevelopment
                  efforts. The majority of the work accomplished by the community to date has been
                  due to leveraging of various Federal and State grants.  However, restrictions on how
                  each of the grants can be used, timeframes associated with grant spending, and the
                  minimal amounts of funding are limitations still facing the project. The respondents
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                  agree that public funding must transition to private financing in order to continue
                  with future phases of the project as planned.
3.2.3.3     SUSTAINABLE REDEVELOPMENT OF THE URBAN  CORE  OF A  MID-SIZED  CITY,
           CHATTANOOGA, TN

                  The current development project dates back to a 1982 initiative to redevelop the
                  downtown and riverfront areas of the city.  The initial  concern  was a growing
                  problem with poor air quality in the region, a deteriorating downtown core district,
                  and lack of public access to the river for recreation.   The original development
                  initiative was  combined with a 1986  initiative  aimed at the elimination of all
                  substandard housing in the city within ten years.

                  The first redevelopment effort was concentrated along the riverfront of the city
                  and is part of a larger 22-mile  riverfront  greenway  plan. With  substantial
                  progress on the waterfront development already completed, the  recent focus is
                  on redevelopment of a 640-acre tract on the south side of the  city  core. The
                  intention is to turn  this area into an  urban redevelopment zone.  But, the
                  planners want to avoid the "condemn  and  bulldoze" variety of development.
                  The  intention  is  to develop the  area in  line  with a mixed-use plan that
                  emphasizes reuse of existing  structures  wherever possible.   Another important
                  concept is that there will be  no municipal taking of owner occupied housing.
                  The  plan is   to  work with  residents  to  encourage  them to  stay  in the
                  neighborhood.

                  Brownfields redevelopment  is  a part of this  latest development initiative. Two
                  particular  sites  that  are   demonstrating  unique  approaches  to Brownfields
                  redevelopment are located in or near the southside development and the riverfront
                  development.  The Foundry Site,  a 100-year old  industrial  site with  soil and
                  subsurface contamination, is preserving the historic architectural character of the
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                  plant while integrating remedial technology into the design of the new development
                  — a football stadium and parking lot. The Cavalier Development project, formerly
                  the city's  largest multi-parcel industrial site,  is exploring  innovative ideas in land
                  ownership, use, and financing.
                  The study team also  looked at the Volunteer Army Ammunition Base, located
                  just outside of the City, which  is currently undergoing realignment and partial
                  closure under the DOD's Base  Realignment and Closure  (BRAC) Program.
                  This site has unique issues, elements and characteristics  that are associated with
                  Brownfields, as well as sustainable development.

                  It  is interesting to note that the level of sustainable redevelopment achieved so
                  far by the City  of Chattanooga has taken  over 16 years to accomplish.  The
                  progress  and timeframes required for  Chattanooga's  accomplishments  may
                  warrant consideration by other communities initiating an  EPA Pilot Project
                  within the brief two-year period  of the Pilot Project grant.  The Chattanooga
                  Brownfields redevelopment effort could serve as a guide in developing realistic
                  expectations  of what level of  progress  can  be  achieved  within certain
                  timeframes.

                  Sustainability — The planning and redevelopment efforts  in Chattanooga have not
                  sought to  adhere to a strict outline for sustainability, but rather, have sought to leam
                  from the past and ensure that what is done today makes sense for future generations.
                  For instance, the initial success of one project becomes the selling point to help
                  launch future projects.  Based on this experience, the respondents identified several
                  key  characteristics  of  sustainable redevelopment that will be  discussed further in
                  Section 4.2. Generally, these include: preserving the  natural assets of the region as
                  the anchor for future growth; designing and building for permanence so structures
                  can  easily be reused; and, sharing of resources and creating links  of dependency
                  among the community components — organizations,  businesses, infrastructure, and
                  green or open spaces.  These links of dependency between businesses, people and
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                  places will provide incentive to remain in a community, thereby increasing local
                  stability and the capability to adjust to changing market conditions, new technology,
                  and unfavorable costs.

                  Perception  of the Brownfields Redevelopment  Concept - Essentially, the
                  respondents  view Brownfields  as a social education  issue.  The community as a
                  whole needs  to gain a better understanding of the cause-and-effect interrelationships
                  within the community, the region, and on the broader scale.   This  requires  an
                  investment of time and money to educate the public and to recruit or retain its
                  knowledge base.  Several critical elements need to be included in this education. One
                  must take into account  the  actual  risks from pollution and  how Brownfields
                  transcend environmental issues to impact the community both economically and
                  socially.  There may be liability for property owners and a fear of the public taking of
                  land.  There will also  be a critical need for the private  sector to take the lead in
                  Brownfields redevelopment.

                  Hence, Brownfields should not be viewed as a single issue or process, but as part of
                  a larger perspective and multiple processes.   Decisions  need  to focus  on the
                  dynamics of these processes overall  and not become departmentalized.  If every
                  neighborhood in the community, and every community in the region, is encouraging
                  similar industrial development, then competition is created that results in industries
                  constantly moving to the next advantageous location - leaving Brownfields behind.
                  The  riverfront  redevelopment  effort  contributed   to   the  overall  city
                  development, but it was not intended to compete with the development of the
                  downtown district. Since the planned growth in the city was  primarily internal
                  (not dependent on suburban businesses moving in)  there was  concern that
                  building on  the riverfront might attract tenants  from the adjacent downtown
                  core where  the  existing office and commercial  centers are presently  located.
                  This would  have the potential  to create  more  abandoned  or  underutilized
                  properties downtown.  Through zoning changes, the  city was able to  enforce
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                  recreational uses for the waterfront area, thus not detracting from office and
                  commercial development in the core.

                  There  were  several  common  themes  inherent to  each  of  Chattanooga's
                  redevelopment projects. There was focus on the river as a key natural resource and
                  reusing facilities as assets. Site contamination problems were addressed as part of the
                  reuse  design.   The promotion  of regional development that does  not create
                  detrimental competition was achieved.  There was leveraging of public  and private
                  financing.  Finally, and maybe most important, a solid commitment by  community
                  leaders to achieve their vision of the community was met.

3.2.3.4         BROWNFIELDS SITE INVENTORY AND COMPREHENSIVE PLANNING -
              NEW ORLEANS, LA

                  The primary focus of the City of New Orleans' Brownfields program is to  leverage
                  the EPA Pilot Project.  This can be done in several ways including generating public
                  awareness of Brownfields; creating a community organization to  identify, categorize,
                  and prioritize Brownfields sites within the city; and ensuring redevelopment of the
                  sites is consistent with comprehensive strategic plans for economic development.
                  This effort is part of a larger effort intended to stimulate new jobs and improve the
                  environmental  quality  of  socioeconomically  disadvantaged communities.   The
                  Brownfields Pilot Project Grant was awarded in September 1995.

                  The project was proposed as a means of developing an inventory of Brownfields
                  to be used in  reclaiming land for industrial or business use. The effort includes
                  the  development  of criteria for  ranking the  sites in terms of their economic
                  development  potential. A  community outreach  plan has been  developed and
                  implemented for the purpose of obtaining neighborhood input to the process of
                  site identification and ranking.
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                 The New  Orleans  Brownfields  initiative is among the first of several major
                 projects  begun after  the  formation  of the Mayor's  Office of Environmental
                 Affairs, within the Department of Economic  Development.   The  Office  of
                 Environmental Affairs was  established  at the urging  of the Mayor and has a
                 strong commitment from the city management.

                 The formation of the New Orleans Brownfields Inventory Consortium was the
                 initial step  in getting the project started. The authority for the Consortium is a
                 charter by  the Mayor to operate through the Mayor's  Office of Environmental
                 Affairs. The Consortium is comprised of a diverse representation of community
                 stakeholders from  neighborhoods, churches  and synagogues,  academic  and
                 financial institutions,  the private business sector, and  municipal  leaders. Each
                 neighborhood  elected a representative  to  serve on the Consortium. Ground
                 rules were developed  for  how  the  Consortium would operate,  including
                 weighting criteria applied to  different stakeholders and the selection of delegates
                 with voting privileges.

                 Sustainability - A primary concern expressed by several respondents was  that
                 for  Brownfields  redevelopment to  be sustainable  it  had to  be part  of a
                 comprehensive and  continuous community  involvement and improvement
                 process.  The focus on the  planning process itself, rather than plan  output, is
                 considered key to the  project's sustainability because it  involves the community's
                 inhabitants. Thus, the plans are able to evolve and  adapt as the community
                 changes  over time.   On the other hand, it was pointed out  that community
                 involvement can  become a barrier to the  process.   This  occurs  because the
                 organization typically  deals with  and  responds  to  the  segments  of the
                 community that are most vocal.  This does  not always provide  a  true  picture  of
                 community needs, desires, and values.
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                  Another concern expressed by some of the respondents pertained  to  the  city's
                  ability to financially sustain the Consortium; and the administrative support needed
                  by the Consortium to  continue the community outreach, involvement, reporting,
                  and planning activities once the EPA Pilot Project grant ends.  A viable long-term
                  funding mechanism has not yet been identified.

                  Perception of the Brownfields Redevelopment Concept The Mayor's Office of
                  Economic Development sees Brownfields as  a critical  part  of the  overall
                  redevelopment of the city. The first priority is to sustain the viability of the city
                  as the core of a regional economy  and society.  Therefore, the  Brownfields
                  program serves as an incentive to focus on infill redevelopment.

                  Environmental justice is a major issue  in New Orleans.  Respondents stated that
                  socio-economically-distressed  minority  neighborhoods  are overburdened  with
                  environmental contamination problems  due to the  city's history as an industrial and
                  transportation center. Addressing environmental justice becomes a question of how
                  to respond to cleanup problems and to prevent future contaminated neighborhoods.
                  As such, redevelopment of Brownfields is not viewed so much as a process, but as a
                  focal point for community motivation and planning within an  overall community
                  cleanup, restoration, and economic development effort.

                  From a developer's perspective, it was noted that the  interest and motivation to
                  redevelop a Brownfields site is based on its profit potential,  as would be the case
                  with any other real estate development project.  The developer would  be interested
                  in a site despite  its Brownfields status, not necessarily  because of its Brownfields
                  status.  Therefore, a key incentive to sustainable redevelopment is determining how
                  the  Brownfields program can demonstrate that it has added value to a site.  In  other
                  words, what  does the  Brownfields initiative bring to  the table that  wasn't  there
                  before?
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3.2.3.4     SITE INVENTORY,  CHARACTERIZATION,  AND  DEVELOPMENT POTENTIAL  FOR
           COMMUNITIES IN  THE WOONASQUATUCKET  AND  BLACKSTONE  WATERSHEDS,
           STATE OF RHODE ISLAND

                 The goal of this EPA Brownfields Pilot Project is to return under-used contaminated
                 properties to  productive use, with particular emphasis on the reuse or recycling of
                 the multiple abandoned mill sites and structures  found along the Woonasquatucket
                 and Blackstone Rivers. Due to the geographical size of the project area, and because
                 multiple rural municipalities and urban cities are involved, the State of Rhode Island's
                 Department of Environmental Management has the  lead in project coordination.
                 The structured interviews focused on particular  sites within the city of Providence
                 that are part of a proposed plan to  create a greenway along the Woonasquatucket
                 River.  The Brownfields Pilot Grant was awarded in June 1996.

                 An objective  of the  Pilot Project is to create  a model plan  to  identify and
                 characterize  sites for  contamination and  market potential.   The  strategy
                 developed will  allow  for  accurate  determination  of  present  levels   of
                 contamination and accurate estimates of the  associated cleanup costs.  When
                 completed,   the   strategy  will represent  a transferable  model   for  site
                 characterization and remediation that could be used  by other communities.  The
                 project is  also  attempting to  leverage additional  resources  and support  to
                 continue to address Brownfields  redevelopment in the  affected communities
                 within the two watershed areas.

                 Sustainability — Because the project was  led by the State agency, it represented  an
                 opportunity to try a broad  strategy  for sustainable redevelopment of Brownfields
                 sites.   With  the  project focus  on  mill  sites  located predominantly within two
                 watersheds, an ecosystem-based  approach was employed.  One site that keyed  on
                 the river as an anchor  asset, if properly managed, could become a catalyst for
                 sustainable redevelopment of adjacent neighborhoods and make them places people
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                  would want to live  again.  Another site's vision was to develop a waterfront park
                  through the city that provides jobs, natural beauty, recreation, and restoration of the
                  watershed ecosystem.

                  The State,  municipal and  non-profit organizations  participating in the project are
                  operating primarily on various grant funds. Therefore, they are required to juggle a
                  number  of project  variables  to  meet differing timeframes, budgets, and  activity
                  restrictions of the grants.  This  limited basis of funding  currently hampers the
                  sustainability of the Brownfields redevelopment effort.   However,  recent State
                  legislation  has  created  two revolving  funds  that can  support   sustainable
                  redevelopment in the future.

                  Perception of the Brownfields Redevelopment Concept  - The Brownfields
                  initiative  is  viewed as an impetus to community development.  It consists of major
                  elements, each having their own systems and processes that vary on a site-by-site and
                  community-by-community basis.

                  One mechanism for the initialization of a project is to start by building a connection
                  to  the urban community.   Identifying central issue groups  that already have
                  connections to the community can be useful in terms of developing an identity and
                  establishing the proposed project's credibility with the community. The Brownfields
                  initiative  can be integrated into the larger plan/agenda of these local groups. The
                  project focus  can then be addressed with these groups to  make use of group
                  meetings and networks that are already established, thereby not imposing additional
                  demands on residents' time and commitment.

                  When municipalities   undertake   the   process  of  identifying  and   prioritizing
                  Brownfields properties for redevelopment, site ownership is a critical criterion. The
                  ideal Brownfields site has no private owner, or can easily be taken over by the
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                  municipality.  This municipal control significantly increases the potential  flexibility
                  needed to characterize, market, and direct the redevelopment of the site.
                  Urban versus Rural Brownfields Redevelopment - Two basic characteristics were
                  identified by the respondents.   Rural municipalities generally lack the resources
                  needed to undertake a  concerted effort to  address Brownfields sites all at once.
                  Although rural municipality planning departments may exist, they typically do  not
                  have   the  resources  or  expertise  to  address   economic  development   and
                  environmental contamination issues  associated with Brownfields.  Regional, State
                  and Federal agencies are needed to augment the rural communities with  technical
                  expertise, staff resources, and funding.
                  Also, members  of rural communities generally have a good understanding and
                  appreciation for natural resources, such as rivers and greenways, as  public assets.
                  Whereas  in   urban  communities,  especially  in  socio-economically  distressed
                  neighborhoods,  special outreach and public awareness campaigns are needed that
                  promote the values of such assets and are geared to reach the multitude and diversity
                  of the population.
32.4   BiownSddsPilotPfojectCaseAnaly&s


















Pilot Project
Case Analysis

-\ Boston, MA
-\ Bridgeport, CT
-| Buffalo, NY
-\ Burlington, VT
-| Cape Charles, VA
-| Charlotte, NC
-| Cleveland, OH
-| East Palo Alto, CA
-| Greenfield, MA
-\ Navajo Nation
-\ New Orleans, LA
-| Oregon Mill Sites
-\ Rhode Island
-| Trenton, NJ
L| WCMC

                  As part of the information gathering phase of this  project, 15 Brownfields Pilot
                  Projects were selected from the total of 115  projects awarded either national or
                  regional grants by the EPA prior to November,  1997.  Since that time, the total
                  number of pilot projects has increased to 157. These sites were the subject of a
                  more extensive review, based primarily on available information about the projects
                  contained in EPA's Brownfields Information Management System, or materials
                  produced and  published by the projects  themselves.   Of the  15 Pilot  Projects
                  selected for further review, four were also the  subject of on site visits to interview
                  project  personnel and collect additional information  available  from  secondary
                  sources.
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                  These four projects (Boston, MA; Cape Charles, VA; New Orleans, LA; the State of
                  Rhode Island) along with the eleven  other sites  are summarized briefly in  the
                  following Sections.  A more  detailed  summary  is provided in Appendix C.   A
                  summary of  the  interviews conducted during the on-site visits is  provided in
                  Appendix F.
3.2.4.1         BOSTON, MASSACHUSETTS
                  The city of Boston is a major industrial center and seaport with a metropolitan area
                  population of 575,000 of which, approximately 43% are minority and 18.7% are
                  living at or below the poverty level. The focus of the project is the Dudley Street
                  neighborhood, which  is known to  contain  some  1300  vacant (and potentially
                  contaminated) lots, of which six properties were  targeted.   The EPA has already
                  spent over $1  million at one of the  sites  (Modern Electroplating) to conduct a
                  removal action.  A site assessment is necessary to estimate the  remaining costs of
                  cleanup.  Phase I and Phase II assessments have  been either completed or are in
                  progress  at two of the other  sites.    Less  than cooperative  site  owners have
                  complicated the process of obtaining additional information about the actual hazards
                  posed by the sites.

                  The Pilot program conducted community outreach meetings to educate the local
                  population and solicit input on future site uses. The Dudley Street Initiative and
                  a number  of  other  community groups are working with  the  Brownfields
                  Economic Redevelopment Initiative to provide a forum for minority and other
                  community  participation.    The Pilot  has  developed  information   for a
                  Geographic  Information  System (GIS)  on  five  of the sites.   Qualitative
                  assessments  have been made for the marketability of some of the sites based on
                  location, presence of loading docks, availability  of transportation,  condition of
                  existing structures on the properties,  amount  of available land associated with
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                  the site, and proximity to waterfront areas and wetlands. Interested developers
                  have been identified for some  of the sites, and are  making  presentations on
                  proposed redevelopment alternatives to neighborhood groups.
3.2.4.2       BRIDGEPORT, CONNECTICUT

                  Bridgeport, with a population of 132,919, is the largest and most distressed city
                  in the  State, experiencing an almost 50%  decrease in manufacturing  jobs over
                  the past decade. The citywide unemployment rate is 8.6%. Significant suburban
                  greenfields development has  occurred leaving prime,  inner-city industrial real
                  estate abandoned.  The  objective is to return  contaminated inner city, derelict
                  land to productive  use and create a prototype  for other cities.  All tasks under
                  the original Pilot Work Plan have been completed.

                  A site inventory of 205 priority ranked sites was prepared; six of these  sites have
                  been targeted for concentrated attention with one site already planned for use as an
                  indoor ice-rink, ballpark, and  a  new museum.   The city is  involving  the local
                  community in the Brownfields decision making process.  The planning process also
                  includes "Team Bridgeport," a group appointed  to  develop a State action plan for
                  the redevelopment  of the  city.    Approximately  12  companies have  expressed
                  interest in sites the  city has  identified as having economic development potential.
                  Estimates are that approximately  200 jobs have been created thus far, but since no
                  facility is as yet operational, there is no increase in  the property tax base.

3.2.4.3       BUFFALO, NEW YORK

                  Buffalo is a typical northeastern city with a long history of dealing with hazardous
                  waste issues  (30  sites on  the NYS List, 60  sites  on  CERCLIS,  and  several
                  Brownfields  sites  along water  bodies).   HUD  ranked  the city  as the  4th most
                  distressed in the United States.   With a resident population of 328,000, Buffalo's
                  poverty rate is about 25%. The Pilot has focused on: developing a city-wide master
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                  list of potential Brownfields properties; prioritizing and assessing 10-20 sites from a
                  preliminary inventory  of 100;  creating a  GIS  database of site information; and
                  preparing  a Brownfields  Redevelopment  Manual, Community  Outreach Plan,
                  Developer Workshop/Showcase, and a redevelopment plan for South Buffalo.

                  The  Buffalo Brownfields Task  Force  (chartered  by the  Mayor)  includes
                  participation from government,  private industry, and general public entities  in
                  spearheading this diverse and progressive Pilot. The Pilot has leveraged a variety
                  of  Federal HUD  EZ/EC   &  NYS EDZ grants,  donations  from local
                  Development Corporations, and private company investments.  As of 1998, 100
                  sites have been identified and  screened.  Eleven sites have Phase I assessments
                  underway  or  completed.    The  City  Planning  Department  is  creating
                  comprehensive  development plans to integrate new business development with
                  recreational and greenspace areas.  Redevelopment strategies and approaches are
                  tailored to the specific qualities and location of each site. A unique "First Source
                  Agreement" requires  businesses  receiving city assistance to give first hiring
                  consideration to local residents.  The city also  has agreements with new industry
                  and  other private  redevelopments  to maximize the  hiring  of women and
                  minority subcontractors.
3.2.4.4        BURLINGTON, VERMONT
                  With a population of 39,127, Burlington is among the poorest cities in Vermont
                  (about 19% below poverty) and has been designated as a Federal Urban Enterprise
                  Community. The Pilot targets 17 properties consisting of 40 acres of land within a
                  3-mile radius of Burlington's central business district. Most of the sites are in or near
                  disadvantaged neighborhoods. The Pilot's goal is to develop an integrated approach
                  that incorporates ecological zoning strategies,  pollution prevention, and sustainable
                  development.  The emphasis is on  creating a transportation corridor between the
                  city core and  its waterfront, cleaning-up and  redeveloping the waterfront, and
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                  creating an eco-industrial park at the largest urban site. The objectives of the project
                  include developing a comprehensive Brownfields Plan,  achieving a high degree of
                  citizen participation and support, and creating a redevelopment model for other
                  small  cities  to replicate.   The project is also pursuing a DOE research grant to
                  evaluate innovative technologies such as a prototype high-strength waste-to-product
                  technology process such as fish food and fertilizer manufacturing, and is researching
                  bioshelter design and construction and value-added food production.

                  The  Project Coordinator works  for the City's Community  and Economic
                  Development Office, and coordinates with  an advisory committee task force
                  and contracted  firms  to help identify marketable properties, strategies,  and
                  potential purchasers. The city is addressing private developer fears  over liability
                  by using  various municipal instruments to acquire Brownfields  sites, clean them
                  up, then sell  or lease  them back to private developers.   In addition, deed
                  restrictions,  environmental covenants, and good  site  management practices are
                  employed.  The city plans to involve disadvantaged neighborhood citizens in all
                  stages of the planning process allowing the community to assess the level of risk
                  they are willing to accept.  The  community will  also  participate in  determining
                  any future  land use options.  The  city  relies heavily on community advisory
                  groups  (e.g.,  the  Barge   Canal  Coordinating  Committee),  local  business
                  associations, and local  neighborhood planning assemblies to maintain public
                  awareness of issues and to identify  alternatives.
3.2.4.5         CAPE CHARLES, VIRGINIA
                  The Town of Cape Charles is located on the southern tip of Virginia's Eastern Shore
                  on a narrow strip of land between the Chesapeake Bay and the Atlantic Ocean. A
                  small community, Cape Charles  has a population of 13,000,  47% of which are
                  African-American with 27% below poverty level.  The Pilot targets a 155-acre site
                  that includes a former dump, a railyard site and the remains of abandoned industrial
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                  operations.  The goal of the Pilot is to assess the extent of contamination at the site
                  and to design a remediation  strategy that will allow for the creation of the Cape
                  Charles  Sustainable  Technologies Industrial Park (STIP),  a  restored wetlands, a
                  nature trail, an environmental education facility, and a  tertiary sewage treatment
                  system.  Phase I surveys are completed and Phase II investigations are planned to
                  determine the extent of any contamination at the  site.

                  The design of the project was  developed through a consensus building effort
                  and  an  architectural  design  charrette,  or  interactive  workshop  process.
                  Participation from minority and low-income populations  within the community
                  was emphasized.  The first  tenant for the proposed STIP has been identified.
                  The jobs being offered will increase the individual earnings  potential of many
                  local residents.  Other efforts by the Pilot at the site include managing some of
                  the adjacent  coastal  marshes and dunes as  a habitat  preserve  for selected
                  endangered species, and the  restoration of wetlands to add to the attractiveness,
                  usefulness,  and overall  sustainability of the proposed project.  The Pilot has
                  developed a Master Plan and Comprehensive Design and Operations Standards
                  for the  STIP.   Based  on these  documents,  the  Cape  Charles  Planning
                  Commission adopted  a new STIP zone and the town council  has rezoned the
                  property.
3.2.4.6       CHARLOTTE, NORTH CAROLINA
                  The city of Charlotte is an urban center with a population of 395,934, approximately
                  34% of which are minority, with  10.8% living at or below the poverty level.  The
                  proposed  project target  includes  the  city's  oldest  industrial  area,  the  South
                  End/Wilmore district, parts of which date to the latter portion of the 19th century.
                  The  goal of the project  is to  return properties to productive  use.  The  city is
                  establishing guidelines for appropriate cleanup  levels on selected sites.  Although
                  physical improvements have been made to the target area in the form of private
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                  redevelopment of several mills to retail, entertainment, or residential uses; a number
                  of sites remain to be redeveloped.

                  A  core  site  team  consisting of representatives  from  four  neighborhood
                  associations, as well as other  stakeholders, participated in the  site selection
                  process.  The Pilot  Project's Environmental Committee developed the  criteria
                  for selecting sites  and determining the amount of funding for site activity. The
                  community has sought to avoid creating a list of Brownfields sites for fear of the
                  potential stigma the sites may attract, thereby inhibiting the  site  marketing.
                  Already redeveloped textile mills and factory sites have been used  for restaurant
                  and retail space, upscale housing and a working trolley line. Other sites  will be
                  purchased  for use as flex space or to expand  existing manufacturing facilities,
                  office and  recreational space.  Grant funds  have been used to negotiate a final
                  agreement   for  one  site,  the  first such  agreement under  the  State's new
                  Brownfields Act.  The developer  will spend $14.5 million on the site, creating
                  approximately 400 jobs.
3.2.4.7        CLEVELAND, OHIO
                  The Cleveland Pilot was the first Pilot grant awarded by the EPA.  Cleveland is
                  located  in north central Ohio on the shores of Lake Erie and is Ohio's second
                  largest city with a population of over 490,000 in the urban center and surrounding
                  areas.  There is extensive industrial and commercial development throughout the
                  city. A total of four sites has been identified as part of the Pilot. The objective is to
                  prepare  for  the future reuse of the chosen sites, to ensure that  decisions about
                  cleanup and redevelopment are consistent with the  needs and expectations of the
                  community,  and  to ensure  that minorities  and the disadvantaged are  able  to
                  participate in the Brownfields redevelopment efforts.
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                  The Cuyahoga County Planning Commission (CPC), working with the Cuyahoga
                  Community College (Tri-C), has formed a community/business task force, to
                  ensure broad participation. Together this task force has: held a forum to discuss
                  risks  posed by  Brownfields; assisted with  the  development of high school
                  curricula on  environmental issues; initiated the  development of programs to
                  provide trained capable workers to support Brownfields  redevelopment efforts;
                  and conducted outreach  activities  to  recruit and train  inner-city residents to
                  perform work needed to remediate Brownfields sites.  The project efforts have
                  been  successful  in attracting several  new businesses to  the area,  producing
                  additional employment  and tax revenue  for the city.  In addition, an extensive
                  GIS  database has  been developed to  provide developers, lenders,  and others
                  with comprehensive profiles of sites throughout the region.
3.2.4.8        EAST PALO ALTO, CALIFORNIA
                  East Palo Alto is an ethnically diverse community with a population of 25,000 living
                  within a 2.5 square mile area. According to the 1990 census, the local population is
                  approximately 86% minority. The city was incorporated in 1983, but it inherited an
                  inadequate infrastructure, low sales and property tax  revenues, no central business
                  district and a total of 166 acres of Brownfields areas. The Pilot goal is to redevelop a
                  large  portion  of  the  130-acre  Ravenswood  Industrial  Area,  create  new  job
                  opportunities for residents, and increase the city's  tax base, thereby  improving
                  community services.   The  Region  IX  EPA office and the U.S. Department of
                  Housing and Urban  Development  have joined  together to  provide Federal staff
                  liaisons to work with Brownfields and other economic development issues. They
                  will conduct community outreach and education meetings and coordinate Federal
                  and State programs to meet city needs.  They will also identify assistance programs
                  for which the city qualifies.
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                  The Ravenswood Industrial Area is made up  of 59 properties that overlook a
                  wetlands area and the San  Francisco Bay.  East Palo Alto is working with the
                  California Regional  Water Quality Control Board to conduct a screening level
                  investigation of soil and groundwater contamination associated with the site.
                  The Pilot has also established the Ravenswood Industrial Stakeholders Group to
                  develop land use and alternative redevelopment scenarios, and define a process
                  for implementing the redevelopment plan.  The  Pilot has  plans to hold  at least
                  three  seminars  for  community personnel designed to inform residents about
                  environmental factors affecting their neighborhoods.  Students from Palo Alto
                  have also participated in a job-training program including 90 days of on-the-job
                  training with a local environmental  company.  Potential full-time  jobs are
                  available for some  of these  students.  Attempts are being made to increase
                  outreach efforts to  potential employers in the South Bay area, and to  expand
                  this training program for the area surrounding the site.
3.2.4.9         GREENFIELD, MASSACHUSETTS
                  Greenfield is a small community with a total population of 18,026. The town has an
                  unemployment rate of about 5.4% and has been designated as an Economic Target
                  Area by the  Commonwealth of Massachusetts.  The town has experienced a 37%
                  loss in manufacturing jobs between 1980 and 1990.  The Pilot Project is focused on
                  an abandoned 145,000-sq. ft. machine tool manufacturing plant  covering 13 acres
                  along the Green River.   The goal  of the project is to evaluate the  environmental
                  concerns at the site; explore an innovative cooperative model for site assessment;
                  create redevelopment opportunities; and plan for the restoration of the  site as an
                  asset to a blighted neighborhood.

                  The project will develop a cooperative partnership among the local government,
                  State  environmental agencies, private consultants,  and  students from  the
                  University of Massachusetts.  Activities planned as part of this  Pilot include site
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                  investigation and remedial planning and determining future land-use options for
                  the site. Several possible uses for the site include a cultural center, office space,
                  and a cultural museum. The project is focused on developing model approaches
                  to reducing assessment and cleanup costs that could be replicated for other
                  Pilots.  Redevelopment of the site could provide needed space for local business
                  expansion.
3.2.4.10        THE NAVAJO NATION
                  The Navajo Nation site is located in a rural section of northwest New Mexico.  The
                  area has approximately 2,293 residents who are predominantly of Native American
                  ancestry. About half the area population is impoverished with few local employment
                  options. The Pilot focuses  on a 10.5-acre property  containing the former Navajo
                  Forest Product Industries.  The mill complex shut down in 1995 resulting in loss of
                  300 jobs and annual sales over $20 million. The site contains 32 buildings, hazardous
                  and solid waste problem areas including PCB-contaminated transformers, capacitors
                  and stained  soil;  discarded batteries; barrels  of acids,  solvents  and  petroleum
                  products; and a wash  trough with unidentified solvent. The Pilot  objectives are to
                  identify all hazardous substances on-site and in the groundwater; assess public health
                  and environmental risks; educate the community; develop  a remedial design; and
                  cleanup and revitalize the industrial complex.

                  The Pilot is  managed by  the Navajo Nation Environmental Protection Agency
                  in close cooperation with the Federal EPA Region  IX.  A full-time Pilot Project
                  Coordinator has  been hired.   When  tribal general funds are obtained,  The
                  Navajo Nation is planning a voluntary cleanup program, removal response at the
                  site.  Pilot funding will be used for site assessment and  developing a remedial
                  design  plan.  The Navajo  Nation is considering a lease  of all or  part of the
                  complex to a regional lumber milling company that will operate under a new 10-
                  Year Forest Management Plan.  A  community outreach effort is underway to
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                  identify local community needs and concerns  through an education campaign
                  conducted in  the Navajo language.   All  project activities are being  led  and
                  conducted by tribal members.  Local residents will  be trained by USEPA to
                  conduct site assessment and hazardous waste site cleanup.
3.2.4.11        NEW ORLEANS, LOUISIANA

                  New Orleans is noted for its cultural diversity with 65% of its more  than 480,000
                  population composed of residents with African American heritage.   The  city is
                  located adjacent to two major waterways, at the foot of the "chemical corridor."  Its
                  port, rail,  and  highway systems transport a high volume  of hazardous materials.
                  Since  1990, the city has  emphasized economic development planning to revitalize
                  major sections of the city and its neighborhoods. The Pilot goal is to develop an
                  inventory  of Brownfields  sites  in  the  city  to aid city planners, developers  and
                  investors in restoring the properties.  The immediate objectives are to  identify sites;
                  develop criteria to rank  the  sites in terms of economic redevelopment potential;
                  develop a basic cleanup process; and generate redevelopment strategies for 5 to 10 of
                  these sites. The Brownfields  program is coordinated with the city's other economic
                  development activities through the Office of Environmental Affairs  (OKA)  which
                  also  chairs  the  Brownfields  Consortium,  a  broad  representation  of state/city
                  agencies,  bankers, developers,  and citizen  groups.   A professional facilitator
                  coordinates the day-to-day activities and meetings of the Consortium.

                  Through  a  series of community meetings and  surveys of city public  works
                  components, 167 potential Brownfields sites were identified and screened. The
                  Pilot used EPA's mobile analytical lab to expedite Phase  II field characterization
                  for selected properties.  The Brownfields inventory and  redevelopment strategy
                  will be integrated into a  comprehensive city Master Policy Plan  and a  subset
                  Strategic  Policy  Plan, to provide a  framework to direct and  guide  future
                  development.  The OEA and  Brownfields Consortium have also  developed a
                  draft Brownfields Marketing Plan that outlines five phases of plans and activities
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                  for 1) community participation; 2) stakeholder involvement; 3) "collaterals" or
                  information management and presentation; 4)  marketing initiatives;  and 5)
                  public  relations.   A variety  of possible  reuses will be considered  based on
                  community involvement and property owner, developer, and lender discussions.
                  Two sites are being considered  by developers for residential or  low-income
                  housing.
3.2.4.12        OREGON MILL SITES
                  This rural area Pilot targets nine abandoned mill sites located in nine different towns
                  in  Oregon, with a combined coverage  of  550 acres.  Since 1988, cutbacks and
                  closures of lumber and wood product facilities in primarily timber-dependant rural
                  communities have economically devastated these areas by depressing mill property
                  values, reducing the tax base, creating abandoned infrastructure, decreasing family
                  incomes, and increasing the focus on greenfields development. The objective of the
                  Pilot is to rehabilitate the vacant and abandoned mills into productive industrial and
                  commercial  properties that will  enable  surrounding  communities  to  attract
                  businesses that bring new and diverse employment opportunities.

                  The project organization  is a public/private partnership managed  by a non-
                  profit  corporation  under  the  overall  coordination of the  State  Economic
                  Development Department. A project advisory committee has been formed with
                  representatives  from the partnership  groups as well as  others  with particular
                  expertise.  Local Action Committees (LAC) are  responsible for redevelopment
                  plans  tailored to each site  that consider land use, wetland mitigation, cleanup,
                  and redevelopment incentives.  Each LAC creates outreach plans to ensure
                  broad community input to  cleanup and redevelopment efforts.  Most sites have
                  completed Phase   I  and  Phase  II  assessments  combined  with wetlands
                  delineations.  The project is emphasizing community awareness programs to
                  address risk communication with local citizens.  The project is  also evaluating
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                  the potential for using generic cleanup options to help developers assess cleanup
                  liability, financing options  and development  risks;  and to  establish  cleanup
                  standards for similar abandoned mill sites.
3.2.4.13        THE STATE OF RHODE ISLAND
                  This project incorporates two urban cities and three rural towns in the north-central
                  portion  of the State  that historically have  been economically centered  around
                  industrial mills located along the region's rivers.  After decades  of heavy industrial
                  use, followed by a rapid decline in mill industries, many contaminated properties are
                  left to decay. The focus of the project is on 50 potential Brownfields sites located in
                  multiple  communities  within the  watersheds  of  the  Woonasquatucket  and
                  Blackstone Rivers. The goal is to create a model ecosystem-based program to return
                  sites  in these communities to beneficial use.  Objectives include coordination with
                  multiple  State  and  local  agencies,  providing a degree of certainty in levels of
                  contamination, and the  leveraging  of additional resources  for redevelopment.
                  Because  most of the  affected communities have  only minimal  organizational
                  infrastructure,  the Rhode  Island Department of  Environmental Management
                  (RIDEM) has the responsibility for coordination and implementation.

                  A regional survey was  conducted  for the  five municipalities resulting in the
                  nomination of 120 sites  as potential Brownfields.  Based on Phase I data and
                  other site characteristics such as community concerns, environmental threats,
                  and potential reuse, this  list was screened to produce  a final list of target sites.
                  The key to this process is regional coordination to identify, screen, and prioritize
                  sites.  RIDEM is  working with established community action groups  to involve
                  the local communities in the  planning and decision processes.  The project is
                  taking an ecosystem  management approach  to  redevelopment within  the
                  watershed. The focus is on creating employment opportunities and upgraded
                  affordable housing for low income residents in Brownfields neighborhoods.
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3.2.4.14        TRENTON, NEW JERSEY
                  The city of Trenton, located in west central New Jersey, was  a prominent 20th
                  century manufacturing center that has greatly declined, leaving a large number of
                  potential Brownfields sites. Unemployment levels have ranged from 15% to 25%,
                  with a poverty rate of about 18%.  A large percentage of the minority population live
                  in neighborhoods surrounding vacant industrial sites.  Trenton's Pilot Project focuses
                  on  15 Brownfields sites, covering a total of 23  acres.  It has also targeted potential
                  sites over more than  600 acres within an urban enterprise zone. The Pilot is seeking
                  to engage the entire community - especially affected neighborhoods - in identifying
                  the problems, opportunities and  resources associated with these  sites.   It  is also
                  important to identify  financial resources in order  to develop a  comprehensive
                  strategy for site assessment, cleanup, and reuse. The goal is to create a model for
                  institutional  change  in the overall  site  remediation  process  and to serve as  an
                  example for small, former industrial cities. The city's Department of Housing and
                  Development has the lead role with  several primary groups as partners including an
                  advisory council,  a  non-profit  community  development   corporation,   and  a
                  roundtable discussion group.

                  All 23 acres of Pilot Project properties have been assessed. Cleanup is underway
                  at  two  sites.   The  emphasis  is  on two-way  communication  and  citizen
                  involvement through community  advisory groups.  To overcome  developer
                  fears of liability and to kick-start restoration efforts, the city is taking aggressive
                  actions  to acquire the Brownfields sites through  tax foreclosures,  sale  of tax
                  certificates, condemnation, or eminent domain if needed. The city is  then able
                  to leverage State/Federal funds for assessment, cleanup  and reconstruction.   It
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                  can then enter into lease-purchase arrangements with private developers who
                  establish businesses on site. The city is working closely with private developers
                  and community development corporations to market the sites. Approaches are
                  tailored to individual sites depending on acreage, existing building capacity, and
                  location.  The city emphasis  is on Brownfields  sites in low  and moderate
                  income,  and  minority neighborhoods.   The project has  held community
                  meetings to  engage residents in the process,  seek their input, and educate them
                  on the nature of hazards and their potential remedies.

3.2.4.15        WEST CENTRAL MUNICIPAL CONFERENCE (WCMC)

                  The  West  Central Municipal  Conference (WCMC)  is a  regional council  of
                  governments comprised of 36 municipalities that cover a total area of 200 square
                  miles in suburban Cook County Illinois, just west of Chicago.  These are mature
                  "inner  ring"  suburbs that have recently  experienced  a steady loss of jobs and
                  population as businesses have relocated to "greenfields" in more rural areas, leaving
                  behind an increasing number of  abandoned  industrial sites, many of which are
                  contaminated.   The WCMC is  a  regional  organization that  is  comprised  of
                  representatives from the member municipalities.  The goal of this Pilot is  to select
                  two publicly owned sites and two privately owned sites for redevelopment. The Pilot
                  has created a Rapid Response Team to provide timely expertise and guidance to the
                  major stakeholders and create a strategy for strengthening community-municipal-
                  industry partnerships.

                  Before  a site is  selected for  the  project,  it  must have  some  inherent
                  marketability.  A total of four sites have been identified thus far, each of which
                  has different contaminants, and  poses different risks to public health  and the
                  environment.   EPA Region V used a  mobile laboratory to conduct  limited
                  surface soil  analyses to  assess  possible environmental problems at  selected
                  locations within the target area.  The Pilot is also actively investigating alternative
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                  financing mechanisms, especially public  sector sources to fund cleanup and
                  redevelopment.  The Pilot has  developed an  outreach program  that targets
                  municipalities,   businesses,  civic   groups  and   community   groups.   The
                  municipalities   that   comprise   the   WCMC  represent   ethnically   and
                  socioeconomically diverse populations. Community redevelopment activities are
                  designed to improve  the conditions in inner-city environments where minority
                  and lower-income populations are more concentrated.
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4.0 Analytical Results
                                                                        ANALYTICAL
                                                                          RESULTS
                                                                         Parameters, Elements &
                                                                         Characteristics
Verification of Identified
PECs
                                  The development of model  frameworks  to  depict how  the
                                  processes  of sustainability and  Brownfields redevelopment
                                  relate at the project level is predicated upon the identification
                 and correlation of the key parameters, elements and characteristics (PECs) associated
                 with successful, sustainable Brownfields redevelopment.
4.1   Parameters, Elements, and Characteristics (PECs) of
       Sustainable Brownfields Redevelopment
                 Through the review of the various data  sources, a comprehensive list of major
                 factors that contribute to sustainability and Brownfields redevelopment was created.
                 This list was categorized on the basis of a systematic analysis of when, how, and the
                 degree to which the factors are present and interact to influence the  sustainable
                 redevelopment of Brownfields. Through this procedure of identification, collection,
                 categorization,  and organization, each category was observed to be, in essence, a
                 process unto itself. The result is the set of ten key elements defined in this  section
                 and presented as sub-processes of the overall sustainable Brownfields redevelopment
                 process.  In addition, the characteristics associated with each element are described
                 as they relate to the three parameters of sustainability — ecological, economic, and
                 social — described earlier in Section 3.1.2.
PECs of
Sustainable Brownfields Redevelopment


Community
Profile
Comprehensive
Community Plan
Organizational
Focus & Structure

Site Identification
& Characterization
Risk
Management
Legal/Regulatory
Site Marketing
& Redevelopment
Technology
Applications
Project Funding/
Finance
Environmental
Justice


                 In certain cases,  factors have been identified through our research that are just
                 emerging as innovative and promising elements and characteristics of sustainable
                 Brownfields redevelopment.   Because these  are relatively  recent, little  data was
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                  available to properly analyze them.  Therefore the analysis of these factors and the
                  degree to which they occur within various processes need to be addressed in a future
                  study when more data is available and their application can be evaluated.

                  Consequently, this compilation of key elements and characteristics  should not be
                  considered as all-inclusive or final. Rather, it is a dynamically evolving list that will
                  change as more Brownfields projects mature and experience is gained over time with
                  individual PECs.
4.1.1    CctnmuniiyPtoSle
                  Community profiling is the critical process through which a community develops
                  self-knowledge of its social and economic history, its culture and collective character,
                  its  current  composition,  community assets,  and the  physical,  biological and
                  functional attributes of the natural ecosystem(s) with  which its members  interact.
                  The profile sets the context in which the proposed redevelopment will take place. It
                  becomes  the  benchmark  or  foundation from which all  community decisions
                  regarding Brownfields redevelopment and sustainable growth are derived. Hence, the
                  profile serves as  the  starting point  for  assessing a  community's direction and
                  measuring its success in pursuing sustainable Brownfields redevelopment.
                  The profile is the basis for community members  to  learn and understand  their
                  common history, geography, and the natural cycles which affect their daily lives.
                  This understanding enables members to feel rooted in the community and begins to
                  "shape their sense of place".  It enables the members to gain respect for all other
                  parts  of their community by understanding and appreciating the basic human and
                  land ethic:  "everything  is related to  everything else" (Bernard and  Young, 1997).
                  With  these  fundamental  principles identified  and  ingrained  throughout  the
                  community, the planning process, in  which the community looks to  the future and
                  decides what it should be and how to  achieve it, can proceed.
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                  The community  profile begins  from  the premise  that  the development  of
                  information about the community  is fundamental  to  the  understanding  of the
                  community's  needs,  problems, distressed  populations,  and how  the  proposed
                  development will ultimately affect the community.  In addition to providing critical
                  decision support information to community leaders, planners, other public officials,
                  and the community  as  a whole,  the community profile also  provides  potential
                  developers with a guide in the preparation of their proposals.  It can also serve as a
                  basis for interpreting and evaluating the effect of those proposals and establishing a
                  degree of community control over the project outcome.

                  The sustainability of a proposed development depends heavily on the degree of "fit"
                  between the intended future uses of the site and the community's understanding of
                  itself,  its quality of life standards and its  projected goals for  the future.  By clearly
                  understanding these aspects of itself, the community will have a basis from which to
                  direct its energies to those projects that support its future. The  identification of its
                  unique assets and qualities also provides support to the efforts of the community to
                  market itself to potential new residents, business entities and funding sources.

                               Profiling  Techniques that have been
                                 Effectively used by Communities
                •   Statistical data collection and analysis
                •   Historical overviews, surveys and evaluations to comply with the National Historic
                    Preservation Act (16 U.S.C. 470)
                •   Community surveys using standard questionnaires
                •   Interviews with community leaders and long-term residents
                •   Focus groups
                •   Design charrettes
                •   Public meetings
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                  For  example, by the early  1980's, Chattanooga, TN  had lost most of its  core
                  industry, unemployment was high, air pollution was the most critical public health
                  concern, and the community members had lost confidence in regaining the  quality
                  of life they  once  enjoyed.  A community profiling process  began  as part  of a
                  comprehensive urban planning effort.  This process enabled its citizen's to see how
                  attractive their community was before the pollution problems, to see the role its
                  industries had in shaping  the landscape and the population demographics, and to
                  realize the value of their two most distinct natural assets — the  Tennessee River and
                  Lookout  Mountain. This  knowledge  and  understanding  enabled community
                  residents to provide informed input as part of the community's   "Futurescape"
                  survey, essentially creating  the community's vision for the future. With this  planning
                  underway, initial redevelopment and environmental  cleanup began.  Following the
                  opening of a new Aquarium along the restored riverfront, community confidence
                  bubbled  and momentum  was  generated to sustain  further redevelopment  efforts
                  (Chattanooga Site Summary Section 3.2.3.3).

                  Use  of a  community profile can also assist planners and the  community in
                  determining how the existing resources of a community can be used to further the
                  economic sustainability. The conceptual basis  of a  community's  economy can be
                  categorized into the basic  sector, or those goods and services  produced for  export
                  outside the community, and the non-basic sector, or local trade and service activity.
                  To the extent that income to the  community from the basic sector is spent locally
                  for goods and services and does not leak back out, the output  of local businesses is
                  increased and additional rounds of spending will occur (Leistritz, 1994). The more a
                  community can maximize  the use of its own resources to meet its collective needs,
                  the more likely it will be able to  minimize the flow of money away from the
                  community and increase the sustainability of its economy.
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                  In another example, the Cape Charles Community was able to define five existing
                  industries  with immediate and ongoing potential for development as part of its
                  profiling process (Northampton,  1994).   These industries were considered to be
                  indefinitely sustainable if managed and developed wisely. By focusing on the existing
                  strengths of the community, developed through the community profile, the town of
                  Cape  Charles and Northampton  County were  able  to  focus  attention on fully
                  developing the sustainable potential of existing resources.
                    Key Characteristics of Community Profiling
                       Developing an Environmental Inventory
                       Estimating Natural Resource Consumption Limits
                       Identifying Landscape Features
                       Associating Ecological Assets with Community Values
                       Defining the Community
                       Developing a Sociocultural Understanding
                       Recognizing Attractive Community Features
                       Preserving Historic Resources
                  r-
Developing a Sense of Community Self-reliance
Characterizing the Community Economic Basis
Assessing Social Capital
Assessing the Investment Climate
                  Key characteristics of the community profiling process include:

                  •   Developing of a comprehensive environmental baseline inventory that includes
                      natural  and  biological resources,  pollution sources,  and potential areas of
                      contamination. The geographic scales should range from the surrounding region
                      down  to  individual  neighborhoods  and  open  or  greenspaces within the
                      community, to individual parcels.
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                   •   Estimating limits  of natural  resource  consumption use  and loss based  on
                      historical patterns.

                   •   Identifying significant landscape  features,  physical assets, sensitive  habitats,
                      endangered and keystone species, and unique areas to be protected.

                   •   Associating ecological assets with community values.  As communities develop
                      their baseline inventories, and identify what features they consider significant and
                      to what degree natural resources should be protected, they will also be clarifying
                      the value these assets have to the collective community. Knowledge of how the
                      community values its natural resources becomes critical in the  planning process
                      for determining priorities, especially in rural communities.

                   •   Defining the demographic  composition and general character  of a community,
                      including  the  number  and  mix  of residents,  residence  patterns, important
                      institutional  and  community  arrangements,  significant  community groups,
                      sources of internal conflict,  and anticipated population trends.

                   •   Developing a general understanding of sociocultural conditions that contribute
                      to  community stability or instability,  family cohesion,  crime,  and  social
                      institutions.    Stability  and,  therefore,  future  sustainability  results  from  a
                      combination  of stable employment in jobs that pay a living (or family) wage and
                      long-term residential patterns that create connections to the community and
                      between residents.

                   •   Recognizing  and understanding what features make the  community attractive;
                      the unique features of social life in the community, lifestyle patterns,  sources of
                      community  pride,  historical  or  cultural  identity,  special  capabilities  or
                      contributions of the community to the society at large , etc.
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                  •   Describing and  preserving  significant archeological and  historical resources.
                      Existing historic districts, buildings, places, and objects  serve as anchor assets
                      within communities.  These assets represent historic themes or architectural
                      designs that foster a sense of permanence within the community, and provide
                      continuity from one generation to the next. An example is found in the manner
                      in which the town of Cape Charles, VA has designated its core area as a historic
                      district to preserve the early American, maritime character of the community.

                  •   Identifying the degree to which the community has established a sense of self-
                      reliance and developed external linkages to social, business and ecological entities
                      that contribute to the maintenance and success of the community context and
                      strengthen its ties to the outside world.

                  •   Characterizing of the economic  basis of the community including the mix of
                      business and commercial activity, level of business activity, State and local tax
                      structures, the capacity of existing service delivery systems (infrastructure), the
                      levels of employment, income and poverty.

                  •   Assessing the formation of social capital in the form of the existing make—up of
                      the labor force, its skill and  education level,  and its availability to participate in
                      and support any new development that may be proposed.

                  •   Assessing the existing and potential future climate for investment both within
                      the community and in the larger society is important to the long term funding
                      capability for any proposed project. The capability of local governments to
                      borrow funds to  offset any short-term cash flow  problems  or meet any
                      uncertainties associated with a proposed project is also important.  These are
                      important components in determining the capacity of the community to address
                      the fiscal burdens that may be associated with any new development.
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                  Income levels  also play a part  in any  prospects for the success and long-term
                  sustainability of proposed redevelopment of a Brownfields site.  Especially in smaller
                  communities and particularly in rural  communities, the level  of  income  and,
                  specifically, the level of disposable income available in that community may have a
                  decisive influence on the community's decisions with respect to future reuse of a site.

                  With respect to decisions related to any proposed Brownfields redevelopment
                  project, the community profile provides  a static picture of the local community to
                  serve as a basis  to evaluate the overall effect of the action to be taken.
4.1.2  Compfdiensive Community Phn
Comprehensive
Community Plan


Public-Private
Partnerships

Community Role

Regional
Development Model

Planning
Considerations


                  The primary goal of a comprehensive approach to community planning is  to
                  integrate the Brownfields redevelopment process  into  a larger  community
                  development plan.   The process  of development  is a  public process  and
                  correspondingly, the planning of that process must include  not only narrow
                  sections of the public interest, but must also  be responsive to the community's
                  larger needs. Thus  neighborhood improvement plans are linked to community
                  development master plans that are in turn linked to county, regional or statewide
                  economic development plans. This  enables the community's  understanding  of
                  its future goals and the requirements necessary to meet those goals to become
                  integrated into all geographic and political scales and thereby helps sustain the
                  community over the long term.
                  The focus of community planning is placed on the planning process itself, rather
                  than on a single, specific outcome.  It is in the planning process that community
                  participants, including individual stakeholders, become involved and committed.
                  The plan itself evolves  as the community's needs change, thus enhancing the
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                 potential sustainability of the plan by maintaining a predictive balance between
                 needs and services — both in the near-term and long-term future.

                 The more directly the community is involved with the planning, the more likely
                 the plan will reflect the community's needs, requirements, goals, and vision of its
                 future. Correspondingly, the more the planning provides for the common good
                 of all its members, the more support from the community will be forthcoming.
                 The ultimate  sustainability of any planning  process rests  with  the long-term
                 support of the community.

                 The requirements, needs and goals incorporated into the planning process will
                 be unique  and specific to each community.   Brownfields program or project
                 based  planning is more likely to  make a  sustainable  contribution to  the
                 community if it takes these specific needs into consideration early in the process
                 and  maintains a community based planning focus  throughout the life of the
                 project.

                 A community based plan is also  focused  on defining who the development is
                 directed to assist,  where they are located  and what assets and liabilities of the
                 community are involved. Because  of the number of individual entities, agencies,
                 organizations  and  areas of professional  expertise  involved  in  a Brownfields
                 redevelopment process, the  comprehensive planning process  requires  the
                 forging and nurturing of relationships across several different institutions and
                 agencies.   The planning process therefore  becomes a  conscious, intended
                 collaboration  between  private  sector  organizations, public  agencies and  the
                 community as a whole.

4.1.2.1        A NEW UNDERSTANDING OF THE PUBLIC - PRIVATE PARTNERSHIP

                 One of the more productive strategies incorporated  into the planning process is
                 a revised conception of the role of public agencies in facilitating and supporting
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                  the  development process, including the redevelopment of private properties.
                  "The public sector can do things the private sector cannot do.  They can run
                  interference and set things up so that the private sector can move in and make
                  investments." (AAF, 1996)  In other words, the public sector can serve as the
                  stimulus, or  catalyst  to  causing change  in those  situations  where  private
                  companies would be precluded due to risks, costs, or market conditions.

                  The role of public-private partnerships in the planning and development process
                  (or private—public partnerships as one site respondent emphasized) was evident
                  in a number of the Pilot Project efforts studied.  Where such partnerships have
                  been created, the results have been reported as successful.  In a number of
                  instances, the distinction between public and private is  somewhat blurred as the
                  resulting  entity has  strong elements  of both  sectors.   Chattanooga is  one
                  example where these types of partnerships have been quite successful.

                  In   other  cases  non-profit  development   corporations  offer  an  increased
                  capability to address problems that may not be  amenable to treatment by for-
                  profit developers.  Because non-profit organizations are not limited to making
                  only those investments with a known rate  of return,  they are able to address
                  redevelopment projects that present a higher level of risk than is acceptable to a
                  private developer.   By addressing these properties, non-profit  developers can
                  add value to a property by decreasing the level of uncertainty that may be
                  associated with its cleanup and redevelopment. They also have access to sources
                  of money for planning and assessment that for-profit developers may not have.

                  The  nature  of the Brownfields  process also requires  a strong cooperation
                  between  public  entities  and private  developers both  in the  planning  and
                  implementation stages.  For several of the projects examined, the importance of
                  bringing public officials  into the planning process  early  and  keeping them
                  informed throughout the course of the Brownfields process was important to
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                 the continuing support and cooperation of the municipal government during the
                 implementation phase.  Conversely, the absence  of this kind of cooperation is
                 also  cited  as  a  major impediment  in  projects  that  have  experienced
                 disappointments.

4.1.2.2       THE ROLE OF THE  COMMUNITY IN THE DEVELOPMENT PROCESS

                 The  community   can  have  a  number of  influences   on the  Brownfields
                 development process. Some examples include the community's  master plan and
                 zoning  decisions   that dictate  outcomes.   The community  can  also  create
                 stipulations  with  respect to  the requirements  or  outcomes  of the planning
                 process that include design, function and acceptable  levels of cleanup and risk.

                 Almost all Pilot Projects investigated as a part of this study incorporated some
                 form of community involvement in their planning process.   This range  of
                 activity  includes the  formation of community advisory boards  to assist in the
                 development of selection criteria and the site screening process, as well as the
                 participation of community representatives in design charrettes to formulate and
                 review the design plans for proposed facilities, or site uses. Several communities
                 have  also relied on the past knowledge of neighborhood residents to develop
                 site  histories  and potential  contamination scenarios.   This  technique was
                 important to the New Orleans project, which was able to take advantage of the
                 personal memories of long-term neighborhood residents.  In almost all cases,
                 community residents were given the opportunity to review and comment on
                 proposed development plans prior to final implementation.

                 The challenge for sustainability, as noted in several interviews with project
                 participants  is to get the community to take responsibility for  the appearance,
                 vitality and marketability of the community as a whole, not just the specific site
                 or project in question.  It is  important to overcome the  "not  in my backyard
                 (NIMBY)" and "let someone else do it" mentality so that changes can be made
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                  locally.  This reduces the dependency of the community and at the same time
                  promotes the self-sufficiency of the residents.   It also serves  to  increase the
                  public's involvement and awareness  of the problems and  the  solutions being
                  implemented, making them  active  participants  rather than  simply  passive
                  beneficiaries, or victims.

                  The establishment of the project vision cannot be accomplished without community
                  outreach and the subsequent involvement of the  largest sector of the affected
                  resident population.  This involvement helps to define the standards to be applied to
                  any subsequent development, and facilitates public acceptance  of the effort.  A key
                  issue for the sustainability of the planning process is the tendency for the attention
                  and energy levels of the community to diminish over time.  (The Pilot Project will be
                  a long  process  from  the first  recognition of a problem through  the initial
                  organization and planning stage, to the final implementation of new development.)
                  This tendency to lose focus has  been  described as  a  cyclical process, "the issue
                  attention cycle" (Downs, 1972). The cycle has five stages:

                                 The Five Stages of the "Issue Attention Cycle"
                            D Pre-E vent/Problem
                            D Cost of Progress
                            • Post-Problem
• Event/Alarmed Discovery
D Gradual Decline of Interest
                     The pre—event or problem stage during which there is some recognition of
                     an undesirable social condition by a select few individuals but the problem
                     has not come to the full attention of the public as yet.
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                  •  The event or alarmed discovery stage at which point, there is a sudden and
                     general realization of the problem and its implications. This usually follows
                     some defining event or action  that brings the problem to the forefront of
                     attention.

                  •  The recognition of the cost of  significant progress stage usually following a
                     call for action and general mobilization.  At this  stage, there is recognition
                     that the costs associated with resolving the problem are high and that really
                     addressing the problem may require major commitments of time and effort.
                     Attention is gradually lost.

                  •  The gradual decline  of intense  interest stage follows the third stage  closely
                     and results in a sense of discouragement or boredom with the issue as other
                     issues emerge to attract attention.

                  •  The final stage in the process is the post-problem stage in which the issue
                     has  been fully replaced by  some  other concern and fades  from  public
                     attention and action.

                  One of the more frequently cited strategies for overcoming this  cyclical process
                  is to assure that the public is educated and knowledgeable of the requirements of
                  the process.  This can be achieved by fostering a culture for learning among the
                  community participants.  Learning attracts genius and knowledge.   Since  the
                  knowledge needed to make good decisions on behalf of the community  and its
                  future is always changing, the community's commitment to always remain open
                  to new ideas and information is required.   New ideas,  dreams and creativity
                  should be rewarded and nurtured throughout the  community (beginning at the
                  school age level) and  continued throughout the planning and  development
                  processes (Bernard and Young, 1997).  Sustainable communities  have developed
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                 processes to learn,  to  retain, and  to  share knowledge, and thereby  stimulate
                 greater momentum.

                 Another strategy is the incorporation of a  catalytic event that energizes  the
                 community  and keeps  the momentum of the process going while retaining a
                 high level of public support for the  process.  This  occurred in Chattanooga
                 when the city was  unable to attain its clean air goals  and was viewed  as  an
                 unhealthy place to  live and  work.   Outside  recognition of the project, in  the
                 form of grant awards or national attention, also serves to maintain a high level of
                 public attention to  the project.  The EPA Brownfields  Pilot Project grant and
                 the President's  Council on Sustainable Development's  Demonstration Project
                 Award to the Town of Cape Charles/Northampton County, VA have had such
                 an affect.

                 However, it  is not always certain that community involvement in the program is
                 essentially beneficial. The underlying problem with community involvement shows
                 itself when only those segments of the community that are the most vocal, or have
                 the time and energy to attend meetings  come forward.  This type of involvement
                 does not always  provide a true picture of the community's wishes.   The important
                 concern for the  planning process is how to get out into the community and begin
                 teambuilding efforts that include the broadest possible range of population segments
                 in order to get everyone on the same path.

4.1.2.3        INTEGRATION OF THE BROWNFIELDS PROCESS  INTO A  REGIONAL
              DEVELOPMENT MODEL

                 In  addition  to  locating  the  overall  project in the context of the surrounding
                 neighborhood and  the  host community, the inclusion  of a regional and/or
                 ecosystem perspective in the planning  process affords  the  benefit of linking the
                 project to a wider base of resources, natural  functions and personnel expertise. This
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                  is especially important for rural projects that have limited organizational resources in
                  the immediate community, but are rich in natural resources (The Rhode Island
                  model is a  good  example).   A regional  model  also contributes  to  the  overall
                  marketability of the area and increases the potential to generate new investment and
                  business expansion.
                  One of the more significant challenges to the redevelopment process is to address
                  the spatial mismatch between the location of new job growth and the location of the
                  people who will take those jobs.   A mixed  use, regional approach improves the
                  potential for co-location of workers  and their employment.

                  A regional approach also eliminates  the possibility of regional entities competing for
                  new industry, sources of funding, or in developing conflicting plans for the same
                  areas.  Several projects, including Cape  Charles  and Chattanooga,  found that
                  minimizing the potential for this type of conflict was a significantly positive step.

                  The potential for attracting new development in the form of relocating businesses
                  from existing  facilities in other communities to  newly  redeveloped  Brownfields
                  projects raises a question of regional equity.  As opposed to creating opportunities
                  for development from within the indigenous community, such relocation has the
                  potential to impact the sustainability of other communities  or development efforts
                  affected.  The Brownfields are simply moved from one community to another — not
                  eliminated.  This can affect existing economic bases, both within the region and in
                  other regions removed from the development site.

                  Development planning must  consider that any new  business or employment be
                  genuinely new  and  not  simply a  relocation from one community to another.
                  Otherwise, no  real development has occurred and  nothing prevents  the dislocation
                  of  employment again, affecting the potential  future sustainability of  the  new
                  development. The Economic Redevelopment Administration's regulations prohibit
                  the use of Public Works and Development Facilities program grants to relocate jobs
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                  from one area to another as does the Job Training Partnership Act (GAO, 1997).
                  In order to create new businesses, several communities have incorporated business
                  incubators into their economic development plans.

                  Similarly, a regional approach increases awareness of a possible oversupply of certain
                  types of land uses or activities in a given area; essentially the result of over-replicating
                  the same development model.  Regional planning decreases the possibility that a
                  development will have too much local competition (for example, an oversupply of
                  the same recreational  resource — like multiple historic old-town districts in nearby
                  communities)  resulting in  a  repeat of  the  under-utilization cycle.   A  regional
                  approach allows for the needs of a larger community to be met successfully and
                  increases  the long-term attractiveness of new development thereby avoiding new
                  Brownfields sites.
4.1.2.4
IMPORTANT PLANNING CONSIDERATIONS
                    rlanning considerations
                       Comprehensive "Holistic" Approach
                       Carrying Capacity
                       Urban Growth Boundaries
                       Surrounding Land Uses
                       Mixed Use Environment with Pedestrian Orientation
                       Economic Self-sufficiency
                       Community-Stakeholder Consensus
                       Uncertainty and Planning Options
                       Equal Benefits and Burdens of Brownsfield Redevelopme:
                  Several important socioeconomic and  ecological considerations of the planning
                  process were identified and related to sustainability.  Many of these characteristics
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                  represent  "best  practices"  of sustainable redevelopment, which are  growing in
                  community favor and implementation worldwide (EPA Interviews).

                  Comprehensive or "Holistic" Approach  -  Brownfields  sites  are  usually not
                  created in isolation. They become underutilized or abandoned sites as the result of
                  an interplay of multiple and complex forces.  These include both external factors
                  such as changes  in the national economy, in residential preferences for one region
                  over another, or local conditions such as the decay of a particular neighborhood or
                  region of a city.  In order to ensure the sustainability of the planning effort, it must
                  include a comprehensive approach to all of the concerns related to the Brownfields
                  site and the surrounding region. The focus cannot be  on just one problem  in an
                  area, but needs to address the area as an integrated whole and over both the near and
                  long-term future.  A focus only on attracting new business to provide immediate
                  employment, for  example, may ignore  some of  the fundamental  causes  of
                  unemployment (poor  skills, depressed economy, etc.) and therefore fail.   In the
                  planning process, it is important to capture additional layers of the problem and add
                  new participants  to assure that all issues are identified and all potential stakeholders'
                  expectations are included.

                  Carrying Capacity -  A  major  concern for  the  planning  process  is  that the
                  proposed  development consider not only  the carrying  capacity of the affected
                  ecological area, but also, the ability of the community to support the  proposed
                  activity. In short, is there a market for the proposed activity in the community, and
                  can  the  ecosystem support it?  The  most frequently cited urban  example  is
                  proposing to build luxury condominiums in a predominately low-income, working
                  class community.  Here, the levels of income  among the local residents required to
                  sustain the condominiums  are not balanced with the income base and lifestyle
                  components  of the  community.   The  socioeconomic  requirements   of the
                  development therefore  exceed the carrying capacity of the community, affecting the
                  success of the project.     In rural  areas, ecological  carrying capacity  must  be
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                  considered in the planning process.  An example is proposing to build a residential
                  development of single family homes in an arid location with a small, shallow aquifer
                  and predominantly  clay or rock substrates.  The ecosystem's clean water and soil
                  filtration capacities  cannot meet the  water use demands  and  septic discharge
                  requirements of a large number of homeowners.  This imbalance could adversely
                  affect the  success  of  the  development as  well as the health or quality of the
                  ecosystem within a short period of time.

                  Urban  Growth Boundaries  - One goal of Brownfields redevelopment is the
                  adaptive reuse of existing structures, features and available land in the urban center to
                  avoid the  continuing  loss of greenfield lands on  the urban  fringe.  This goal
                  recognizes  that, regardless of the rural or urban location, ecosystems, economic
                  systems and social systems each have varying tolerances and limits that cannot be
                  exceeded.  For example, parents place limits on what and where their children can
                  play; businesses set limits  on  certain types of costs  or market  conditions they can
                  accept,  and forests have limits to how much acid rain  and harvesting they can
                  tolerate before  their sustainable limit is permanently  exceeded.   The  community
                  needs to identify and establish limits to what it can reasonably support.  Without
                  established limits institutionalized through the planning process, the community has
                  no basis for saying  "no" to unacceptable, unbalanced, or  senseless redevelopment.
                  A community's maturity  in setting and maintaining limits is ultimately  the  true
                  measure of progress toward sustainability (Bernard and Young, 1997). Urban growth
                  boundaries represent one strategy that is being successfully implemented to increase
                  the density of development in the inner city, making use of existing infill possibilities,
                  and increasing  the efficiency of urban  public transportation  (Burlington, VT Pilot
                  Project).

                  Surrounding Land Uses - A key component  of the future sustainability of a
                  planned project is the  consideration of surrounding  land uses,  not only at present,
                  but also in the foreseeable future. This is another example of the value of linking the
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                  Brownfields redevelopment  effort to the overall community  plan.  A plan to
                  redevelop an industrial site into a  residential community will be problematic if the
                  surrounding land uses will continue to be used for heavy industry.

                  Mixed  Use Environment  with  Pedestrian  Orientation  - Another  recent
                  characteristic of the community planning process that furthers the sustainability of a
                  redevelopment  is the emphasis on  mixed-use  development  with  a pedestrian
                  orientation.  This idea is especially appropriate for development in inner city and
                  suburban neighborhoods. The proximity of jobs and services to residential areas will
                  decrease the reliance on one business or employment source and help minimize the
                  reliance on automobile transportation.  This should increase economic flexibility and
                  conserve energy demands on the environment. This concept is the focal point of
                  several European projects examined such as the Westergasfabriek in Amsterdam,
                  Holland,  and the IBA Emscher Park Redevelopment in Germany, as well as the
                  Chattanooga downtown redevelopment project in the United States.

                  Economic  Self-sufficiency  -  Development  must  be  undertaken with a good
                  understanding  of the structure and  dynamics  of  both the  local  and  national
                  economies.  One of the key factors contributing to the long-term sustainability of a
                  region is the  efficient use  of local resources.   Planning that emphasizes the
                  importance of reducing leakage, due to reliance  on external resources or imports,
                  increases  the  potential  flow  of money  into  the area  resulting  in  increased
                  employment and business opportunities.   Promoting local  ownership increases
                  accountability and  commitment to the overall success  of the community effort
                  (Burlington, 1997).

                  Community-Stakeholder Consensus - The ultimate success of the planning effort
                  depends heavily on the development of a consensus, or "buy-in", on the part of the
                  community and all relevant stakeholders.  This implies that although the planning
                  process must reflect the goals and  vision of the community, and especially of those
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                  residents and businesses in the immediate local areas, some measure of compromise
                  will be required in order to satisfy all participants. As noted by one respondent, once
                  there is more than one stakeholder, Brownfields redevelopment becomes an iterative
                  process.

                  Uncertainty and Planning Options - A fundamental concept of the planning
                  process is that  the primary  parameters  of sustainable development  - the  social,
                  ecological, and economic  systems of a community - are complex and only partially
                  understood.  (Rapport,  1997) (SCGPN, 1994).  As a result, the total impact of a
                  redevelopment project and its final outcome, both sociologically and ecologically are
                  difficult to predict.  Change is an inevitable and an unpredictable fact of life.  Thus
                  any planning process must account for variables and maintain sufficient flexibility to
                  allow for the maximum possible freedom in terms of ranges of acceptable options at
                  every stage of the planning and development process. This allows the community to
                  remain open and consistent with the natural direction  and tendencies of the
                  ecological, economic and social systems.

                  Equal Benefits and Burdens  of Brownfields Redevelopment - Sustainability
                  depends on the support of the local community.  A planning process that does not
                  account for the potential impacts of redevelopment  across all segments of society at
                  all socioeconomic levels  loses important segments of the affected community.
                  Planning that only benefits developers  and a  small segment of the community by
                  focusing on real estate with a  high market value diminishes the potential stability and
                  continuity of the community.

4.1.3  Organizational Focus andStcuctute of iheBiownfidds Pfqgtam
                  The  sustainability of a Brownfields  redevelopment  project incorporates two
                  separate and distinct components. One is outcome oriented and relates to the
                  sustainability of a specific Brownfields project or cluster  of projects, and the
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                  degree  to  which these  projects  make some  contribution  to  the overall
                  sustainability of the community.  The other is process oriented  and considers
                  the sustainability of the Brownfields program itself and the extent to which the
                  program contributes   to  a  process  of sustainable  redevelopment in  the
                  community.

                  Process orientation relates  to how  a community's Brownfields program is
                  integrated into the political and administrative structure of the metropolitan
                  government.   The ability  of the program to maintain itself  and  function  over
                  time and the  role the program plays  in the redevelopment and revitalization
                  process of the community are important concerns.   Therefore  organizational
                  focus and structure of the Brownfields program directly affects the sustainability
                  of the Brownfields program itself.

                  Because the Brownfields initiative is relatively new, the  optimal program model
                  has not yet been completely determined.  The successful organizational structure
                  of a Brownfields redevelopment project is still being defined  in a  pattern that is
                  different for each community.  The Brownfields process has been described as
                  an iterative  one in that a number of parallel  sub-processes, all  of which are
                  operating simultaneously  during the  life of the  project,  must be successfully
                  integrated.   The resulting set  of conditions and circumstances are  sufficiently
                  unique, and the available resources are  so multiple and diverse, that each project
                  and each community has to develop its own distinct approach to  the successful
                  effort.

                  Although  each Brownfields redevelopment project is  in many  ways distinct,
                  there are several characteristics of project organization and function  that can be
                  commonly  associated with  sustainability.   These  characteristics  include  a
                  community orientated approach, control of the program by local jurisdictions, a
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                  conducive  institutional  structure,  the need for extensive intergovernmental
                  coordination, and resource commitment.
4.1.3.1       COMMUNITY ORIENTATION
                  The Brownfields program is very much a grass-roots effort in that it depends
                  heavily on the initiative and participation of the local community.  A number of
                  projects have been, at least in part, successful because of the leadership skills,
                  vision, and concern of a number of key individuals in both official  capacities
                  with  local  and  metropolitan governments,  and  in  non-official  roles  as
                  community participants.

                  Conversely, where  project outcomes have been disappointing, some question of
                  the  effectiveness  of  individual project or  community  leadership is evident.
                  Although  this component of project  organization is not easily categorized or
                  necessarily quantifiable in terms of its contribution to sustainability, the qualities
                  of  project  leadership  (e.g.,  strength,  dynamism,  vision,  persistence,  and
                  dedication) are important and  frequently associated with the long-term success
                  or sustainability of the program effort.

                  The program also requires the  successful involvement of a number of people in
                  the community (stakeholders and other participants) to make the program work.
                  Brownfields Pilot Projects depend heavily on the presence of a strong Working
                  Group,  Advisory Group,  or Steering  Committee.   This allows  for  a  greater
                  diversity of participants and stakeholders to  be represented and sitting together
                  under one structure.   A  generic identification of these  key participants  and
                  stakeholders is presented in Figure 4.1.

                  It is important to  note that stakeholder identification  and association with a
                  particular group or issue is not fixed and may cross over into other groups or
                  issues as the Brownfields process moves forward.   The  identification  of an
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                 individual with a particular stakeholder or community group (or social category)
                 does not mean that the individual is also not simultaneously a member of any
                 other stakeholder group.  Individual stakeholders may be part of one or more
                 interest groups or categories simultaneously, and therefore will address an issue
                 differentially, at different times, and in differing contexts.  An individual may be
                 a resident at the neighborhood group meeting, a consumer at the community
                 association meeting, and an environmental activist at the town council meeting.
                 Multiple roles and multiple agendas on the part of individual stakeholders add a
                 potential for internal instability to the Brownfields organization.
          Table 4.1: Typical Stakeholder Configuration for a Brownfields
                               Redevelopment Program
                 Stakeholder  Interest
             Current Owner  »»» release from current liability
                             *»* income from sale or redevelopment
                              ' identify marketable property
Prospective Owner/
         Developer
                   Investors
     (Banking Organizations)
      Neighborhood Groups
   Municipal /State Agencies
   The Local Business Lobby
   (Chambers of Commerce)
reduce uncertainty/quantify risk
balance liability against return on investment
minimize development cost
maximize return on investment
avoid liability on potential foreclosure
provide needed facilities or services
remove hazardous, dangerous or undesirable conditions
increase employment
improve quality of life
carry out regulatory, funding, or redevelopment mandate
improve community image
increase level and  diversity of business activity
improve general condition or specific segment of  community
              Community or
            Citizens Groups  »»»  eliminate contamination / hazardous conditions
          Grassroots Groups
         Legal, Scientific and
         Technical Personnel
                        advance single issue agenda
                        clarify statutory/regulatory requirements
                        improve ecological quality
                        increase technical knowledge
                        improve or innovate new techniques
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     National Public Interest  *»*  support  agendas to be  incorporated as a  part of  proposed
                   Lobbies      development.
                 The sustainability of the Brownfields process depends on the development of a
                 working consensus among stakeholders with respect to  the understanding and
                 vision of the community, the articulation of the overall  goals or plan, and the
                 mechanisms by which to achieve them.  In order to be sustainable, the structure
                 of  the  Brownfields  program needs  to facilitate the inclusion  of all  relevant
                 perspectives presented in the community.  A structural mechanism for sharing
                 information  about  the  program  with  participants  and  for  exchanging
                 information among various component groups is a major component of this
                 process.

                 One such mechanism was  incorporated into the structure of the Chattanooga
                 project.  A common  conference  room  is  maintained  in the  offices of the
                 program's  non-profit  developer  to serve as  a central  meeting room  and
                 conference  facility for the downtown district.  Walls are  filled  with plan
                 drawings, pictures and artists renderings of proposed  and completed  projects.
                 Although the room serves as conference space for the firm, its primary purpose
                 is to be a central place for any and all issues, meetings,  and matters related to
                 downtown and the downtown  redevelopment.  This includes public meetings
                 and issue groups not directly related to the design process.

4.1.3.2       INSTITUTIONAL STRUCTURE

                 A key organizational factor for the  long-term success of the Brownfields project
                 is  the structural  relationship of the project  to  the host  governmental entity
                 (metropolitan  or state) and the  level  of responsibility and authority assigned to
                 the project. The sources for public authority for the Brownfields program are
                 normally derived from the municipal government or a state chartered agency.
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                  Although  a Brownfields  project is normally associated with its ecological and
                  human health components, the salient characteristics of the Brownfields process
                  lie in  its  relationship to  the  overall economic  development of  the  area,
                  neighborhood or community.

                  Several Pilot Projects noted that it was the economic development staff of the
                  respective host governments that were best  equipped to be of assistance to the
                  Brownfields effort  or to act as the  parent agency for the program.   This
                  recommendation was especially applicable in communities that relied on a large
                  number and variety of grants to fund project activity.  Other agencies, such  as
                  city planning departments and environmental agencies, although important and
                  responsive in many respects, were considered to be less prepared to deal with
                  the economic requirements.  The most likely pattern  for success and the long-
                  term sustainability of the project was to  assign the Brownfields effort to the
                  community's economic development staff as the lead or coordinating agency.

                  The level  of administrative authority assigned to the Brownfields organizational
                  structure varies  from project to project.  In some instances,  an independent
                  authority composed of both public and private interests was  created to manage
                  the process.  In others, the role was assigned directly to a specific agency.   In
                  either case, the  presence of strong project  leadership defined  in terms of the
                  level of authority and hierarchical position of the municipal coordinator was
                  considered critical to the  overall success of the project. There  are two specific
                  aspects important to this  role.  It should be assigned to a position high enough
                  in the municipal structure to be able to exercise power and prestige within the
                  government.  It  should carry  sufficient authority to  represent  to  the general
                  public  an  image of political importance  for the project  and  the capacity  to
                  compel decisive action to secure necessary approvals and initiate government
                  action.
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                  The strong support of the municipal government is considered essential to the
                  long-term survival and success of the Brownfields process.  It is also important
                  for local political leaders and government bureaucrats to define their roles with
                  respect to the project and their constituents early in the process. Several project
                  participants  reported  seeing  a  demonstrable  advantage  to  having  the  city
                  involved in the Brownfields process. Much of the land use work in which the
                  city is  engaged is  also Brownfields  type  development.    Municipally owned
                  Brownfields are often the most attractive  for redevelopment.  The city is  also
                  able to pass bonds to finance the assessment and cleanup process.
4.1.3.3       INTERGOVERNMENTAL COORDINATION

                  A central, coordinating authority and a single administrative entity are strongly
                  associated with the  success and ultimate sustainability of the process.  This is
                  because of  the number of individual and potentially overlapping or conflicting
                  government authorities  (e.g.  State  and Federal agencies,  regional  structures,
                  municipal departments, etc.) that may  play a role  in the Brownfields process.
                  Without a  centrally located mechanism at City Hall to act as a coordinator,
                  projects appear to falter.  There is a definite need to have a point person who is
                  connected to the city administration and who can act as a conduit to other key
                  players within the municipal structure to broker requirements and deals.

                  Another important factor identified in  several Pilot Projects is the reliance on
                  advisory  committees,  or task forces,  to  support local project coordinators.
                  These  groups are typically  comprised of private sector  and multiple level
                  government individuals  with  expertise directly associated  with Brownfields
                  redevelopment processes.  One  example is the Rapid Response Team (RRT)
                  concept used by the West Central Municipal Conference in Illinois. The RRT
                  membership includes  the Regional  EPA,  as  well as  the  state environmental
                  agency, the financial  industry, and  legal  representatives,  in  addition to  the
                  regional planner, and others  who are  available to address whatever  types of
                  issues arise at the project level.
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                  Similarly, the presence of multiple organizations charged with formulating and
                  implementing the development process may result in confusion and duplicated
                  effort.  The Brownfields process requires the coordination of civic groups and
                  other  private organizations related  to project planning, goal setting,  design
                  development and  decision  making.   Centralizing  all Brownfields  operations
                  under a single  structure increases the level of responsibility and accountability
                  associated with project operations.  Along with better communications, this
                  structure facilitates monitoring and coordinating project activity.
4.1.3.4       LEVEL OF  INVESTMENT/RESOURCE COMMITMENT

                  Important to  the long-term sustainability of the  Brownfields program  of any
                  community is the level or magnitude of the investment that it can make.  Such
                  investment is represented by a  combination  of public funds (i.e. allocated  by
                  budget); Federal and State grant funds, private  foundation or other  private
                  donation, and  private investment capital.  The available social capital  of the
                  community (or volunteer participation)  represents  another component.

                  The Brownfields program goals must be considered  in  the  context  of the
                  community's ability  to  provide support  to  the process, and  the  level  or
                  magnitude of the investment (in all forms) that the  program can expect.  The
                  proposed  program  must  be within  the fiscal  and social capacity  of the
                  community.   Miscalculation of the community's  ability  to provide  for the
                  requirements of this process, as well as to support the end product or use the
                  outcome of the process, is a serious consideration for the long-term success of
                  the  community's redevelopment process.  A program  that is too  ambitious
                  presents a challenge for  sustainability.  Similarly, the  under commitment  of
                  resources to a program is also frequently noted as  a threat to its  long-term
                  success.
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4.1.4  BtownSdds &teldeati£ca.tian, ChatactErizatiati andPriadtizatiati
Identification,
Characterization & Prioritization


Process
Implementation

Ecological
Consideration

Current
Site Status

Site
Prioritization


                 The single most fundamental characteristic that distinguishes Brownfields from
                 other types of real estate properties, to be developed  or redeveloped, is  the
                 presence or perception of contamination by hazardous substances.  Just as  the
                 presence of a historic property or wetland generates additional concerns and
                 processes  in  overall real  estate  development,  so does the existence  and
                 perception of chemical contamination.

                 The degree of knowledge regarding the presence, type, source, extent, and
                 severity of the contamination directly influences project success. This degree of
                 knowledge must  then  be  applied to the  project in  terms of marketing,
                 redevelopment,  financing,  and legal  or  regulatory strategies  and  options.
                 Therefore, the  early identification, accurate and effective  characterization, and
                 prioritization of  a site(s),  are  all  critical  steps  to  the  process  of achieving
                 sustainable  Brownfields  redevelopment.  The goal  is  to obtain  as  much
                 information through  an  integrated, streamlined  approach as  project funding
                 permits.  The more information obtained in this phase, the greater the potential
                 for success becomes.
4.1.4.1
PROCESS IMPLEMENTATION
                 The approach and  strategy required to  implement this element will vary on  a
                 site-by-site and project-by-project basis.  The first determination to be made is
                 who performs this element and under what authority. There are several possible
                 mechanisms to initiate the process, such as:

                 •   current  property owner  operating  responsibility  or  under  consent
                     agreements;
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                  •  prospective property owner/user operating under related state laws;
                  •  private developer and non-profit development organization also  operating
                     responsibility or under state laws; and
                  •  Federal, state, or municipal government agency operating under applicable
                     statutory or  delegated  authority  (e.g. CERCLA,  RCRA,  TSCA,  State
                     "Superfund", etc.).

                  The determination of which party initiates  and performs this element is critical
                  and must  be made  in  conjunction with  other  Brownfields  redevelopment
                  elements  or processes  because  of its resultant  bearing  on  property  value,
                  marketability, site cleanup, reuse, liability, and  financing. In certain cases, it is
                  advantageous  for different  parties to perform different  components of the
                  process, or to perform them together in a partnership.  Generally, it is best for
                  the property  owner, or  prospective  property owner, to  perform  the site
                  identification and assessment of individual  sites or properties.  However,  many
                  private owners and developers  fear this process,  believing they may only be
                  opening a Pandora's box.  In reality, the more that is known about the property,
                  the better able the owner is to  develop strategies  to successfully maximize its
                  potential use and value.

                  Our research has identified three scenarios occurring most frequently depending
                  on who takes the lead in performing this element. These scenarios form a  range
                  in  regard  to their potential  to promote  sustainability of the  redevelopment
                  effort.
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                      One
                      typicall
                                     irocess implementation scenarios
                                 n Local Municipal Gov't

                                 • Public/Private Partnerships

                                 n Owners, Developers, Financial Institutions, Community
                                  Organizations
scenario is most
y  found  with
                      the  EPA Pilot Projects.    This  scenario  involves  the  local  municipal
                      government taking  the  lead role in  site investigations.    Following  its
                      assumption of title to the Brownfields parcel,  a municipality, acting through
                      its environmental or economic development department or designated task
                      force, can proceed with the investigation. Ownership by the municipality is
                      established through tax foreclosure, condemnation, public taking, purchase,
                      or other instrument.   This  scenario has  been  very  effective in getting
                      abandoned Brownfields characterized and prioritized, and is a viable option
                      in initiating the overall Brownfields  redevelopment process.   However,
                      municipalities  usually  do  not  have  the financial or  technical  resources,
                      especially in rural areas, to  move  the site beyond characterization.  Because
                      of limitations  on the use of public grant funds for site cleanup, they are
                      faced with  the  difficult problem  of how to achieve cleanup or restoration,
                      after the site is characterized.

                      For example, in New Orleans,  the Consortium  has been very successful in
                      characterizing its top ten sites, which resulted  in some positive attention for
                      the  community. But the effort  has stalled, temporarily, until the city  can
                      market the  sites and move them into the cleanup  and redevelopment
                      processes.   This  approach  can be  effective  where  there  are multiple
                      abandoned or foreclosed properties that the  municipality can address as a
                      bundle or cluster.   Aggregate properties are  often more marketable to the
                      private sector  because  their combined size offers  the   developer  more
                      flexibility in the type of reuses possible.
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                  •  Another scenario involves public/private partnerships, usually in the form of
                     non-profit corporations, taking the lead and performing the  site assessment
                     and prioritization.  Non-profit  corporations  have certain advantages over
                     municipalities in terms  of applying innovative approaches, the allocation of
                     liability, and the level of uncertainty or risk that can be assumed from  the
                     outset. Although this approach still faces barriers in how various sources of
                     public funding  can be used,  it offers  more flexibility overall.   Also, a
                     partnership is more likely to obtain or incorporate the specific types of
                     information needed by  private developers to evaluate and design subsequent
                     site redevelopment or  restoration. An example  is the Foundry  Site in
                     Chattanooga where the local economic development  corporation,  a non-
                     profit partnership, has taken  the lead in leveraging various sources of
                     financing, both public and private, to characterize parcels and market them
                     as part of an overall urban redevelopment project.

                  •  The  third scenario involves  property  owners, developers, and  financing
                     institutions  that take the lead with support from  community organizations
                     and  municipalities.   This  includes  private  interest groups,  non-profit
                     foundations  or  developers,  and  local  community groups  although their
                     actions  are  somewhat more  limited by the group's economic or technical
                     resources.   The following  three variations on this scenario  were  identified
                     among the various interviews.

                     •   Owner/developer/lender identifies a Brownfields property and initiates
                         the  site characterization process then coordinates with the community
                         on plans for the site.
                     •   Owner/developer/lender  work  in  conjunction  with  a  community
                         organization to identify and characterize a site  that the firm is interested
                         in redeveloping.
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                     •   Owner/developer/lender  come  into the process after the  community
                         has  identified  a  number  of sites,  and   select  a  site(s)  from the
                         community's list for further characterization.

                  This approach, regardless of variation, offers several advantages. For instance, it
                  enables  the  owner to select the site and customize the information collection
                  and site characterization process.  This allows the owner to obtain the type and
                  extent of information needed, in the most cost-effective manner.  Specific risks,
                  site cleanup  and design requirements related to the  type of redevelopment being
                  considered are  also  addressed.   The financing of this process can also be
                  integrated into  the overall site  analysis  and master  plan  for the  site.   This
                  eliminates the need  for  separate financing to  perform the cleanup, which  is
                  much more  difficult  to obtain from a lender because it has high risk and little
                  likelihood of immediate payback.

                  The geographic scale and number of properties  can also determine the initiating
                  organization. Here, the  scope of  targeted sites can  range  from  a relatively
                  straightforward  site to regional, citywide,  neighborhood, defined cluster, and
                  complex single site.  For instance, in the case of the three rural and two urban
                  towns in Rhode Island, the State RIDEM took the lead because they were able
                  to address multiple properties of the  same type (former mill  sites). A similar
                  approach was successfully employed  in  Oregon where a private/public non-
                  profit partnership, serving under the  overall direction of the State's Economic
                  Development Department, conducted the identification and assessment of mill
                  sites scattered throughout nine rural communities. On a smaller scale, the City of
                  New Orleans, using a  variety of  techniques,  was able to identify  167 sites
                  throughout  its  downtown neighborhoods and screen down  to the  top ten
                  highest  priorities  for further assessment.  At  the  other end  of the range, in
                  Chattanooga, an urban redevelopment partnership is conducting Phase I surveys
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4.1.4.2
   on every parcel located in the Southside Project site, and a private developer is
   conducting the assessment of the Cavalier Development site.

ECOLOGICAL  CONSIDERATIONS
                  ,
                   Ecological Considerations
        Delineation of Site Characteristics
                      Representation of Nature of Contamination
                      Streamlined Site Assessments
                      Integration of Assessments, Audits, Inspections
                      Identification of Groundwater Contamination
                      Continuous Updating Procedure
                  l
                      Site Prioritization Schemes
                      Multi-level Screening Process/Prioritization Model
         Utilization of Available Technical Resources
   Regardless of who initiates and performs the site identification, characterization
   and prioritization process, a  number  of important ecological considerations
   contribute to the overall success and sustainability of the redevelopment effort.
   These include:
                 •   An  accurate   delineation   of  site   location,   boundaries,   historical
                     use/ownership, and physical characteristics with  regards  to  the  local
                     landscape, ecosystem, and municipal plat. This information can often be
                     obtained through the community profile, Phase I "Due Diligence" surveys,
                     "windshield  reconnaissance," and  previous  surveys. The  Phase I survey
                     should also  indicate whether or not the site is  on EPA's CERCLIS list,
                     making it a potential candidate for state or Federal enforcement action.

                 •   An accurate representation of the nature of the contamination including
                     type of contaminants, source(s), concentrations, location on site, extent and
                     potential for migration, pathways of exposure to the public health and local
                     biota, and relative toxicology or health threat. This information is developed
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                     through Phase  II site investigations.  It must be accurate, verified through
                     proven quality  assurance methodologies, and complete enough to develop
                     reliable remediation/restoration strategies and cost estimates.

                  •  Streamlined or  "targeted" site assessments using field screening technologies
                     and mobile analytical laboratories.  These have proven effective and cost
                     efficient in Rhode Island's and in New Orleans' site assessments. The EPA's
                     Road  Map  to  Understanding  Innovative  Technology  Options  for
                     Brownfields Investigation and Cleanup is a good initial source of ideas and
                     requirements to help implement these  assessments (USEPA, 1996(a)).

                  •  Integrating  Phase  I  studies  and  Phase  II   investigations with  other
                     environmental  audits,  including  wetlands  determinations/delineations,
                     stormwater runoff  management  assessments,   and  multi-media   facility
                     compliance inspections, all of which are needed to obtain the necessary site
                     development permits.

                  •  Identification   and   characterization  of  groundwater  contamination  is
                     especially   critical  due  to  the complexity  of  evaluating its  extent and
                     remediation options.

                  •  Integrating site characterization information into the community profile  to
                     create  a  continuous  updating procedure.    Computerized information
                     management technologies such as Geographic  Information Systems  (GIS)
                     are very  effective  and efficient  methods  for  recording,  managing and
                     evaluating these multiple levels of site data.

                  •  Developing site prioritization schemes that include  ecosystem management
                     criteria that reflect community goals and values, natural resource  assets, and
                     the benefits/impacts of redevelopment.
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                 •   Utilizing  a  process  such as EPA  Region I's  prioritization model which
                     classifies  sites according to  two  criteria — nature and  extent of  site
                     contamination, and inherent redevelopment potential or site marketability.
                     New Orleans has developed a multi-level screening process based on a series
                     of criteria determined by community members through the Consortium.

                 •   Utilization of technical resources available to small communities and private
                     owners/developers through  Federal  agencies,  academic institutions, and
                     private consultants, if necessary, because characterization of contaminated
                     sites can be complex.
4.1.4.3
CURRENT SITE STATUS
                 Although the characterization  of a number of factors  is important  to  the
                 potential sustainability  of site redevelopment, two  are of primary importance.
                 They are the level  of site contamination  and the inherent redevelopment
                 potential of the  site.  Several project participants have  suggested that a gross,
                 preliminary  conceptualization of potential Brownfields  sites can be based on
                 these two factors.   Essentially a matrix, this  characterization establishes two
                 polar extremes with  high contamination in a bad market at one end and low
                 contamination and a good  market at the other.  EPA Region I has employed
                 this  model  to characterize and  screen the  range  and  variability  of potential
                 redevelopment projects.
              Figure 4.2: Matrix Characterization of Brownfields Sites
                                   Low Contamination           High Contamination
High Redevelopment
Potential
                 Existing High Potential for
                 Private Development
Potential Brownfields
Candidate Site
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Low Redevelopment
Potential
Potential Brownfields Site
Candidate
Cleanup and Closure — No
Potential
                  In the first instance, the combination of high potential and low contamination
                  usually means that a site will be very attractive to outside, private developers and
                  will not  be a high priority concern for a Brownfields program, since it will most
                  likely be redeveloped by other mechanisms.  At the other extreme are sites that,
                  even if cleaned up, would still not be suitable for redevelopment usually because
                  of a poor market or an undesirable location. These are not the  most promising
                  in terms of  the success  and  sustainability of a Brownfields project.   The
                  remaining sites  represent  varying levels  of  contamination  combined with
                  different degrees of marketability.  These sites represent the largest portion of
                  sites, and therefore the major focus for a sustainable Brownfields redevelopment
                  program.
                                    Long-term Success Factors in Brownfields Sites
                       Land Uses & Adjacent Landowners
                       Current Ownership
                                  Transportation & Infrastructure
                                  Significant Features
                                                                 Current Economic Conditions
                  Other factors that may be important to establishing the current status of the site
                  and therefore  its potential  long-term success as a Brownfields redevelopment
                  project are:

                  •  The site's relationship with surrounding land uses and adjacent landowners. The
                     context of the site is important to the final determination of future reuse and is
                     probably the most important consideration in terms of the site's marketability.
                     Failure  to  address  this  characteristic  can  delay  or  inhibit  the  overall
                     redevelopment process.
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                  •   The current ownership is important to determining the time and level of effort
                      involved in  acquiring the  site and implementing any  final plans  for  its
                      redevelopment.  Absentee owners, resistance on the part of current  owners
                      based on fear of contingent liability, problems identifying site ownership - in the
                      case of abandoned sites - and delays in public taking for tax or other reasons can
                      all present lengthy delays in the process.  This results in a corresponding loss of
                      momentum and  increased potential  for failure of the project.   In general,
                      municipally-owned and Federally-owned properties present the least resistance in
                      terms of current site ownership.

                  •   The potential cost of remediation is  a major factor that  has  the potential to
                      impact  both  the final  decision  on future site  uses  and   their potential
                      sustainability.  Use of a risk-based remediation strategy and the potential for use
                      of institutional controls may result in a decreased cost.   This improves the
                      potential for redevelopment of some sites that are close to the extreme in terms
                      of contamination or current marketability.  Also important is the  potential for
                      the adaptive reuse of existing structures on the site. This is especially important
                      for sites in historic districts, and also has a significant cost reduction as well.

                  •   The socioeconomic  context presented  by the  surrounding  community is a
                      critical factor in determining existing site conditions and how they will later be
                      related to any proposed new development.  The local community profile, and
                      especially the future development goals of current residents, become important
                      components of the current site status. Also important are the potential local
                      users, or customers, for any proposed new facility and  the  availability of a
                      potential labor force in the nearby community - especially where a service or
                      retail facility is considered.

                  •   Transportation and  infrastructure considerations  also  represent important
                      factors in determining  current site status.  Obviously, the more prevalent and
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                      adaptive the infrastructure the greater the site's potential for both short-term
                      action and long-term success.

                  •   Significant features associated with a site are an important characteristic for its
                      potential sustainable redevelopment. A large portion of the existing Brownfields
                      Pilot Projects, for example, are located near some type of waterfront or shoreline
                      (e.g. harbor, lake, riverfront).  Other features of importance may include historic
                      districts, entertainment or recreational areas, greenways, significant architectural
                      features,  traditional ethnic neighborhoods,  or any  of  a  number  of other
                      characteristics  that  may be  defined by the  members  of a community as
                      important or critical to the maintenance of community character or lifestyle.

                  •   Current economic conditions, although often considered remote  from any one
                      particular site, can  have a  significant defining role in the  current status  and
                      ultimate desirability  of a site.  The economies of the immediate neighborhood,
                      local community, or nation as  a whole heavily impact the site and its potential for
                      future reuse.  Of critical importance to residential, commercial or retail sites are
                      the levels of employment and poverty in the immediately adjacent areas. But no
                      less important are the levels of income, and particularly the  disposable income,
                      of residents of the  community in general.  For  industrial  areas, the national
                      economy often becomes the defining feature.  In all cases, the local investment
                      climate and the attractiveness of the community as a  place for investment are
                      critically important.
4.1.4.4        SITE PRIORITIZATION
                  Of equal importance to the Brownfields process is the question of selecting which of
                  the inventory of potential sites will be redeveloped and which will be given priority in
                  the redevelopment process.  Community stakeholders should be involved in, or at
                  least well informed of, these efforts so that the results are mutually understood and
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                   the potential for unrealistic cleanup expectations is minimized.  This enhances the
                   lead organization's credibility and public trust.

                   A number of Pilot Projects have developed site ranking criteria  for the purpose of
                   prioritizing and selecting those sites that will become the subject of the Pilot effort.
                   Site ranking criteria are usually developed through some combination  of information
                   modeling, public input, and other trial or intuitive factors.   Examples of factors that
                   have been included in the ranking criteria include:

                   •  ownership status;
                   •  tax status;
                   •  land area and the history of land uses;
                   •  the  degree  of  reclamation  work  required  —  including  any  demolition
                      requirements;
                   •  the type and extent to which contamination is an impediment to development;
                   •  the availability or eligibility of the site for grant or program funds;
                   •  a determination of the probability  of project success  if the contamination is
                      removed; and
                   •  the early identification of end users of the property.

                   Strong community participation and inclusion in all phases  of the identification and
                   evaluation process is cited  as  the most  successful approach in establishing site
                   ranking criteria and  subsequent prioritization.  In addition  to  assuring that  local
                   community and neighborhood values and goals will be included as a part of the site
                   prioritization process, public involvement at this stage also contributes to an increase
                   in the  public's support and enthusiasm  for the project  as  the project proceeds
                   through its later stages.
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415
Risk Management


Characteristic
Barriers

Community
Concerns

Project Participant
Concerns

Characteristic
Tools & Approaches


                  Brownfields site restoration and reuse is one component of a broader economic
                  development process that must deal not only with the traditional risks involved
                  with real estate transaction  and development,  but  also with the concern for
                  protecting  the  public  health  and  environment from exposure  to oil and
                  hazardous chemical contaminants. The site cleanup and redevelopment process
                  adds an unfamiliar range of risks to the current property owner, prospective
                  buyer, potential developer, investor, and the community at large.  These risks
                  include, among others:
                  •  environmental liability;
                  •  time and cost overruns caused by project delays;
                  •  technology faults and obsolescence;
                  •  personal and third party liability for accidents;
                  •  diminished property value;
                  •  loss of investment;
                  •  changes in market conditions;
                  •  community fears regarding public health; and
                  •  the need for community support.

                  Because these risks are always present,  they cannot be ignored. The management
                  alternatives are to accept, reduce, avoid, spread, or transfer these risks (Grose,
                  1987).   Where the emphasis is placed and how the  various risks are balanced
                  with  their benefits and costs will vary by project and by the parties involved.
                  Regardless of the manner in which they are approached, the immediate goal is to
                  provide  maximum flexibility and balance between facilitating the project and
                  protecting the public health, the environment, and personal or corporate liability
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                 (EPA Interviews).  Risk management is the process of identifying, clarifying, and
                 dealing with this range of uncertainties in order to achieve the project goal.

                 Risk management and  site remediation  processes  can  promote  sustainable
                 Brownfields redevelopment by addressing a number of key project requirements
                 that relate to  the  immediate and long-term interests of different stakeholder
                 groups.  Some examples of these concerns, identified  through the  structured
                 interview process, include the need for:

                 •   greater  accuracy  and  reliability  in   site  characterization  data,  cleanup
                     techniques, and cleanup cost estimates;
                 •   remediation approaches based on relative risk and land reuse that are equally
                     protective  of public health for future generations;
                 •   overcoming  public fears and misconceptions about the extent and nature of
                     the pollution that may linger from one generation to  the next;
                 •   reducing liability and  financial uncertainty  for  developers,  owners, and
                     lenders;
                 •   restoring  ecological  integrity  or   preventing  further  damage  to  the
                     ecosystem's physical, biological and functional components; and,
                 •   permanent disclosure  of  site  conditions   and  contaminants  to  protect
                     prospective owners, lenders, and developers of the property in the future.

4.1.5.1    CHARACTERISTIC BARRIERS TO EFFECTIVE RISK MANAGEMENT AND SITE
          REMEDIATION
                   Risk Management & Site Remediation Obstacles
                      Stakeholder Communication & Coordination
                      Reluctant or Hesitant Stakeholders
                      Community Priorities & Objectives
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                       Incomplete or Inaccurate Site Characterizations
                       Threat of Contamination Spread
                       Long-term Remedial Approaches
                       Government Policy & Requirement Changes
                       Loss of Market Opportunity Window
                    J Contingent Risks of Owners/Developers
                  In order to address the specific requirements of a Brownfields redevelopment
                  project and assure its future sustainability, a number of risk management and site
                  remediation obstacles must be overcome. These include:

                  •  a greater  potential  for communication and coordination problems  than is
                     normally evident in a redevelopment project due to the increased number of
                     stakeholders involved;
                  •  delays caused by those  stakeholders who  are not familiar with  the risks
                     involved  and are therefore  reluctant or hesitant  to  provide the support
                     activities needed to  accomplish the effort;
                  •  extraordinary pressures placed on owners and developers by communities
                     with differing land use priorities and objectives;
                  •  limitations to  existing  pollution  detection, measurement,  and  cleanup
                     technologies  and methods  that result  in incomplete  or inaccurate  site
                     characterizations  (especially in  situations where pressures exist to accelerate
                     cleanup and  minimize  costs),  increased  potential  for  future discovery of
                     additional  contamination problems,  failure to achieve  the  cleanup levels
                     required, and an  inability to allay the concerns  of the public and regulatory
                     agencies;
                  •  the potential threat of spreading contamination, either  due  to  the  lack of
                     source controls, accidents during remediation, or complications in mitigating
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                     pollutant  migration, that can affect and  involve adjacent landowners  and
                     neighborhood residents;
                  •  long-term, complicated, and very costly  remedial  approaches that impair
                     project financing  and private  developer  incentives,  such as groundwater
                     contamination  which is viewed  by  a number  of  developers and Federal
                     officials interviewed as a "real show  stopper"  (Federal Officials and Boston
                     stakeholder interviews);
                  •  changes  in government  policies  and  requirements,  or variations across
                     multiple   agencies   and levels  of government, that  create confusion in
                     delineating liability and result in unexpected project costs;
                  •  additional time needed for owners/developers to reconcile risks and liability
                     with the community and  regulatory  stakeholders that can cause the project
                     to lose its window of market opportunity; and,
                  •  difficulty in providing liability reassurances, insurance, or indemnification to
                     those owners/developers  who might otherwise be willing to incur the costs
                     for cleanup as part of their overall cost, but who are unwilling or unable to
                     incorporate  the  contingent  risk  of  additional  contamination  and  its
                     subsequent cost to cleanup.
                  Overall, the  risk associated  with  a Brownfields  redevelopment process  has
                  essentially two components. The first is the potential risk of chemical exposure
                  to  the  community surrounding the site.  The second is the level of uncertain
                  liability that the  potential project  participants (e.g., owner, developer, lender)
                  face in the management of the project. The community as a whole is concerned
                  with the benefits associated with the reduction of risk to public health posed by
                  a contaminated  property  and  the  potential  adverse effect of any increased
                  exposure encountered  during the  restoration process.   This can include the
                  residual contamination remaining after the redevelopment process is completed.
                  The direct project participants (e.g. owner, developer, lender) are confronted by
                  the potential  risk associated with a continuing responsibility for any previously
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                  undetected contamination of the  property.   This essentially  translates  to  a
                  permanent liability.

                  Although the interests of these two groups often diverge, and are sometimes in
                  opposition, both groups share a common interest in developing a mechanism by
                  which risk related liabilities can be effectively managed and controlled.   This
                  process   depends on  obtaining the  most  accurate  and  reliable  information
                  available and on developing a sense of trust in the agencies that are responsible
                  for regulatory control and long-term risk management.
4.1.5.2       COMMUNITY CONCERNS
                  The key factors influencing community response to risk relate to the manner in
                  which the potential risk is presented and interpreted, and the level of trust or
                  confidence the public places  in the defining institution or agency.    Although
                  the types of risk inherent in a Brownfields redevelopment are not new, they are
                  unfamiliar to, and not fully understood by the broader range of stakeholders and
                  the community at large.  Especially  questionable  are  risks  associated  with
                  environmental  contamination,  cleanup, and  liability.   Failure  to adequately
                  inform and involve the public can cause significant delays as a result  of public
                  reluctance or outright opposition to the project.

                  As Freudenburg (1994) notes, there is no such thing as a self-interpreting fact.
                  In order for the public to effectively compare and evaluate the risks  and benefits
                  associated with all possible redevelopment alternatives, they must reach a certain
                  level of understanding. They must understand not only the factual basis of the
                  actual risk, but also the meaning of the risk in relation to such questions as,  'Is it
                  safe?' or  'Just how safe does it have to be?'   This understanding  is not easily
                  attainable in the absence of any prior experience with, or information about, the
                  risk.  In any event, quantitative estimates of actual risks do not necessarily relieve
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                   the  public's  concern.   (Sinden,  1992).   The  key to  the sustainability of a
                   Brownfields project is to ensure there will be someone to translate the scientific
                   and technical results to community groups.

                   The  important  connection of risk  communication to  the  sustainability of a
                   Brownfields project, rests with this need to provide not only for the transmission of
                   information, but also  to develop shared meanings among individual  stakeholders,
                   institutions, and communities,  and to  establish  relationships of trust. This  is a
                   specialized effort undertaken to reach-out to those stakeholders and public citizens
                   who are  interested  in  the  project, to  educate them, and to involve them.  The
                   objective is to achieve community and stakeholder acceptance and support for the
                   proposec
                   In order
                            site cleanup and reuse or restoration plans.
                                              Risk Communication -
                                           Three Essential Components
                                         CD Understandable Information
                                         I Public Concern & Reassurance
                                         CD Audience Empowerment
nclude three
                   essential  components.   It  should  inform by translating the  information  and
                   knowledge produced by the scientific and technical community into a context that
                   makes it both accessible and readily understandable to the general public.  It should
                   alert the  public to be concerned  for those issues that are  critical  to  both their
                   interests and the process itself, and also reassure them with respect to the  positive
                   and desirable aspects of the project.  Risk communication  should also empower its
                   audience  to act with  respect to the health related and environmental risks  that are
                   being communicated.  (Sinden, 1992)
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                  Outreach  efforts  should channel through existing community groups that have
                  established credibility within the community  (New Orleans, LA and Providence,
                  Rhode Island Site Interviews).  Complex technical  jargon should  be effectively
                  translated  to enable  the general public to understand the common  phases  and
                  mechanics  of the site  assessment and remediation process (Boston  Interviews).
                  These efforts should also address the risks posed by the nature of the contamination
                  relative to common risks incurred everyday by community citizens.  In conducting
                  risk communication activities, it's important not to create false hopes, unwarranted
                  fears, and  unrealistic  expectations  among  the  public/stakeholders.    This  is
                  accomplished  by  framing the information within, or keeping the focus on, the
                  desired outcome,  (e.g.  new business  opportunity,  jobs, housing, services, and tax
                  revenues) rather than parts-per-million problems.

                  The  importance of informing and involving the community as  early as possible in
                  the process is reflected both in the effectiveness of the  outcome and in the degree of
                  confidence that stakeholders have in the  process and the managing organizations.
                  Experience increasingly shows that when  stakeholders are not included early in the
                  decision-making process, they are more  likely to resist the decision, oppose its
                  implementation, and distrust the organizations that are charged with implementation.
                  (Jenkins-Smith, 1992). Conversely, decisions in which stakeholders are involved early
                  in the process are usually more effective and more durable. Engaging stakeholders
                  ensures that public values are considered, improves the knowledge base for decision-
                  making, and may  improve the credibility of agencies responsible for managing risks.
                  (CRARM, 1997)

4.1.5.3        PROJECT PARTICIPANT CONCERNS

                    Project Participant Concerns
                       Current Owner -
                          J  Reluctance of Participation
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                         J  Liability Indemnification
                       Developer -
                             Return on Investment
                             Risk Factors/Perception of Risk
                       Lender -
                          J  Borrower Circumstances
                             Maintain Property Value
                  In many ways, the most serious obstacle to the potential redevelopment of a
                  Brownfields property is  not the presence of contamination, but the perception
                  of contamination.  The  owner, developer and potential  investor associate
                  economic  concerns with  the  uncertainty  of  future  liability.   These  project
                  participants  are interested in the potential benefit that may be derived from
                  development of the property in question.  However, they  are  significantly
                  impeded  by the  adverse  impact  that   may  result  from  an  incomplete
                  characterization of existing site contamination.  Also, the potential for discovery
                  of new contamination at some future time, the failure of institutional controls
                  related to a limited reuse development, or changes to  government policies that
                  threaten the basis for earlier negotiations or agreements play a role.

                  Current Owner - One of the more frequently cited obstacles to the progress of
                  a Brownfields project is the reluctance of some current owners of idle properties
                  to become involved in either Phase I  or Phase II site investigations or to release
                  their property for sale.   Even where  efforts  have been  made to encourage
                  participation through new liability provisions or legislation,  some  owners  still
                  resist  the opportunity to  assess, remediate, or dispose of their contaminated
                  property.

                  Although a number of reasons were  given for  this reluctance,  (e.g. investment,
                  waiting for the property  value to appreciate, confusion over ownership, etc.) the
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                  apprehension over  liability for site  contamination and  the  fear of  discovery
                  factored heavily in  the owners decision to avoid sale  or site investigation. As
                  noted by one interview respondent, owners are aware that this liability exists in
                  perpetuity.  This fact makes them reluctant, either to investigate or disclose what
                  may  represent  a severe  financial  cost,  especially when these  costs may be
                  incurred years after disposition or sale of the property.

                  The   potential   environmental liability   associated  with  the   risk  of  site
                  contamination  for   the  current   property  owner,  then becomes  a  major
                  impediment to  the  sustainability of the Brownfields process. In one extreme
                  example, when  a tenant using a portion of a defunct  facility discovered
                  underground storage tanks, the owner took  steps to have the tenant  removed,
                  not the tanks.

                  In addition to a number of legislative initiatives at the state and Federal level, a
                  number of projects have developed  special  arrangements with local municipal
                  governments to take ownership of sites as one means of mitigating this liability.
                  Although  the  current  owner cannot  be  permanently indemnified,  these
                  arrangements  allow the  municipality  to relieve  the  current  owner  from
                  responsibility by assuming ownership and agreeing not  to pursue  the  current
                  owner in the future.  However, current landowners are aware that this is not an
                  absolute guarantee  and are concerned that laws,  regulation, or practice  may
                  change in the future, making them again responsible for the liability.

                  Developer  (or  equity investor)   -  The  key  issue for  the developer  of a
                  Brownfields site is the level of certainty or predictability that  can be established
                  with  respect to the  known contamination of a property.   Correspondingly, the
                  degree of uncertainty associated with the risk of  liability for future  problems
                  discovered at the site weighs significantly. Central to this issue is the effect on
                  the current value  of  the  property,  and the potential  of  the  property  for
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                  successful redevelopment.  The developer's primary concern is for the potential
                  return on investment,  and the relationship of that return to the potential risks
                  associated with the property.

                  There are specific risk factors affecting any developer. These include:

                  •   the nature and extent of the existing contamination;
                  •   the  existence of a proposed remediation plan with appropriate  regulatory
                      approvals;
                  •   the potential for indemnification;
                  •   the likelihood of third  party actions arising from adjacent property owners,
                      employees or tenants;
                  •   the cost and timing of the remediation effort;
                  •   any remaining land use restrictions on the property; and
                  •   any other variable that  might affect cash flow or the potential liability of the
                      owner.  (Jackson, 1998)

                  The perception of risk on  the part of the developer or equity investor is also a
                  function of the potential value of the property as a clean property and depends
                  on  the context of  the property  itself.    Factors  such as  demand  for  and
                  marketability of the site, the value of surrounding land uses, the general level of
                  economic activity in the area and other qualities of the site and its surroundings
                  will influence the  level of risk  that  a developer will be willing to  accept or
                  undertake.

                  Certain society-wide conditions, such as the increasing pressures resulting from a
                  shortage of developable  land (both  in terms  of acreage  and  cost)  and the
                  currently favorable investment climate may serve to make developers more risk
                  tolerant.  Other intangible qualities may also come into consideration such as the
                  potential prestige of participating in  the project, any altruistic interests on the
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                 part of the developer, or the desire of the potential developer to acquire a basis
                 of experience in Brownfields redevelopment.

                 Lenders  -  Similar to developers, the primary concern  for the lender  is  the
                 effective  management of site related risks.  From the lender's  standpoint,  this
                 concern  is based on the possibility of ultimately becoming the owner of the
                 property in question through  foreclosure.   A  second consideration  is that
                 lenders may incur liability for contamination  prior to  actually taking possession
                 of the property if the lender is perceived as participating in its management.

                 In  addition to concerns for the level  of risk associated with potential  site
                 contamination, the lender will also be concerned with risks directly related to the
                 borrower.  Central to this consideration is the borrower's ability to pay back the
                 loan.  In addition, the lender is also concerned with the circumstances  under
                 which the borrower owns or operates the facility and the risks that cleanup costs
                 will exceed the available budget.  The risk of any  re-openers at the site, and the
                 responsibility  for addressing any unexpected situations  once the project  has
                 begun, are also lender concerns. (Armstrong, 1998)

                 The orientation of the lender is to quantify to the greatest extent possible, the
                 risks inherent in the site development. The lender will be interested in achieving
                 the  highest clean up standards possible so  that  the collateral value  of the
                 property is maintained throughout the course of  the lender's involvement with
                 the property.  As noted during one of the site interviews, repayment of the loan
                 is  the  primary concern of the lending  institution. The last thing a bank or
                 lending institution wants is to become the owner of a contaminated property.

4.1.5.4       CHARACTERISTIC  TOOLS  AND APPROACHES  FOR RISK MANAGEMENT
              AND SITE REMEDIATION
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                    Characteristic Tools & Approaches
                       Project Organizing
                       Federal & State Agency Roles
                       Risk-Based Corrective Action (RBCA)
                       Property Ownership Alternatives
                       Institutional Controls & Insurance
                  A number of characteristic tools and approaches were identified that respond to
                  the barriers and needs of the risk management and site remediation processes.
                  The objective is to reduce the chance of incurring unknown  or unanticipated
                  project delays, costs, and liabilities by identifying and quantifying them as early in
                  the process as possible.  The underlying principle  is that predicting risk going
                  forward is easier than attempting to reconstruct and quantify risks from past
                  practices (Chattanooga Interviews).

                  Project Organizing - The  potential risks  associated with a project can be
                  significantly  reduced,  and readily resolved, by  including  within  the project
                  organization experienced  stakeholders or consultants who  are already familiar
                  with identifying, quantifying and resolving those Brownfield project factors that
                  contribute to  risk.   This would include attorneys successful  in  real  estate
                  transaction and environmental  liability risk, consultants and  site  contractors
                  successful in characterizing and remediating the  type of site and contamination
                  problems  expected, and investment organizations  already accustomed to and
                  familiar with   creative financing  options.    The  West  Central  Municipal
                  Conference, a  non-profit organization supporting local  governments around
                  Chicago, IL, has created a Rapid Response  Team incorporating such  expertise
                  that can quickly respond to the risk issues raised by municipalities, owners, and
                  others.
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                  Federal and State Agency Roles - The role of these government organizations
                  is crucial to the timeliness and effectiveness of risk management and remediation
                  processes. Increasingly, the traditional roles these agencies serve in Brownfields
                  redevelopment is changing from  after-the-fact  regulatory enforcement to up-
                  front  collaborative  relations.   These  agencies become  stakeholders  in  the
                  processes,  sharing  technical  resources  and  information,  clarifying  liability
                  alternatives early on, and generating mutually agreeable strategies and plans for
                  site restoration.   Hence, they share  in  some degree  of  the  project risks.
                  Examples  of collaborative tools are State Voluntary  Cleanup Programs  (VCP),
                  Rhode Island's  Remedial Evaluation Reports (Rhode  Island interview), EPA
                  Comfort Letters and Prospective Purchaser  Agreements, and  EPA/DOJ
                  Supplemental Enforcement Projects (EPA Interviews).

                  Risk-Based Decision-Making  Approach  -  EPA's  guidance  on risk  base
                  decision-making  for corrective actions at underground storage tank sites where
                  petroleum releases have  occurred represents a promising new  approach that
                  specifically addresses human and ecological risks (USEPA, 1996(b)).  Basically, it
                  is a process that employs risk and exposure methodology to help agency officials
                  determine the  extent and urgency of corrective actions, and the scope and
                  degree of regulatory oversight needed.  It provides consistent site assessment or
                  investigation requirements; flexibility  in developing cleanup levels  or goals
                  appropriate for the proposed  or  future use of the site; a basic approach for
                  evaluating remedial options; and a sound scientific basis for regulatory and
                  community acceptance of cleanup decisions.  This aids  in developing reliable
                  project schedules and cost estimates. The importance of EPA's guidance to the
                  management of risks associated with a Brownfields project is that, by working
                  through the process, specific target levels  are identified.   This reduces project
                  uncertainties and enables the risks  to be resolved and/or cost quantified.  Where
                  risk-based decision-making is incorporated into the corrective action process for
                  underground  storage  tanks  through  formal  standards developed  by  the
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                  American Society for Testing and Materials  (ASTM), it is known as "risk-based
                  corrective  action"  or by the acronym  RBCA.   Hence, the ASTM's RBCA
                  standard  may  be  a  good  framework for approaching  site restoration  and
                  redevelopment.

                  Property Ownership Alternatives - Risks from certain environmental liabilities
                  can be reduced  or transferred  depending on  property  ownership.  Federal
                  agencies and local  municipalities are  assuming ownership of many abandoned
                  sites.   They  are  implementing the site  characterization and  remediation
                  processes, then transferring or selling the site to other public or private parties.
                  Under recent state legislation, a state agency or municipality can provide degrees
                  of indemnification to the new owners for risks posed by previous contamination
                  problems (EPA and  Federal Agency  interviews).  Leasing of Brownfields sites
                  reserves the  environmental  liability  for the owner while enabling the site to be
                  cleaned  up  or  restored to safe  use  (Chattanooga  interviews).    Multiple
                  contaminated  parcels can  be  clustered  and addressed collectively,  enabling
                  multiple owners to  share the environmental  liability and costs of remediation or
                  insurance.   This allows the site  to progress  toward redevelopment and reduces
                  the respective risks and costs incurred by individual owners (Cape Charles and
                  Chattanooga interviews).  Because public/private  partnerships and  non-profit
                  development groups do  not need to  obtain  the  same rate-of-return  from
                  developing a site as private owners and developers, they can  temporarily assume
                  ownership while restoring the  site  or alleviating  the causes of environmental
                  liability.   They can then sell the parcel at its new market  value  to private
                  developers for  subsequent redevelopment.

                  Another alternative is structured "3-way simultaneous transactions", where the
                  middle  owner  assumes  regulatory  responsibility  as  temporary owner.   This
                  owner  funds  and  remediates  the  contaminated  property,  obtains  agency
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                  approvals needed to restore the property to the market, and sells the property to
                  the perspective buyer (Hollingshead, 1998).

                  Institutional Controls and Insurance -  Institutional controls by state and local
                  governments, such as special zoning codes, ordinances, and covenants provide
                  instruments that enable the property to be used within prescribed limits.  It also
                  ensures permanent disclosure and a long-term record of liability associated with
                  Brownfields.    For  example,  Northampton  County,  VA  has  developed a
                  comprehensive set of covenants and restrictions  intended  to  manage  current
                  risks and to minimize future risks for the industrial park in Cape  Charles.

                  A growing  variety of self-insurance programs and private insurance policies are
                  viable options for addressing potential costs associated with environmental and
                  other liabilities over long time periods and  among  other parties. The insurance
                  industry is  providing greater flexibility in the types, terms and costs of policies,
                  which can  limit  or completely eliminate  some of the risks involved  in  site
                  assessment and remediation.   The  three  common types  of environmental
                  insurance include: property transfer insurance, cleanup cost  cap/loss insurance,
                  and owner-controlled insurance (USEPA,  1997(a)).  In addition, Contractor's
                  Pollution   Liability  and  Consultant's  Environmental  Impairment  Liability
                  insurance policies are available.

                  Characteristics of new environmental liability insurance include:

                  •  long-term periods of coverage, often more than 20 years;
                  •  policy limits tailored to the predictive cost of remediation;
                  •  options for reinsurance;
                  •  affordable premiums; and
                  •  policies adaptable to sellers, buyers, and lenders.
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                  Use of insurance as a risk management tool can reduce the fears or reluctance of
                  buyers and allow them to allocate risks among the seller and  other involved
                  parties (Taylor, 1998).  Thereby reducing the risk of absorbing one-time, major
                  costs, or to cover contingency costs.

                  Due to the complexity and pivotal role that legal/regulatory processes play in
                  risk management, a  separate element has been identified to discuss  them in
                  further detail.
4.1.6  Legpl / Regulatcay Issues
                  The  effects of  legal/regulatory issues are woven  throughout the  fabric of
                  Brownfields projects.  They may take such forms as barriers to property transfer
                  (e.g.  investigation and commitment to cleanup triggered  at time of change in
                  ownership) and utilization (e.g. zoning, wetlands) or limitations  on owner (e.g.
                  restrictive covenants)  or governmental authority (e.g. municipality's inability to
                  spend its money on privately owned sites).  Most of these impacts, however, are
                  known and their associated cost or risk can be defined and  quantified.
                  Economic  viability is a  key factor  in sustainability and for investors  and
                  developers  in deciding whether or not to engage in a Brownfields project. This
                  factor  is  usually  defined by  a balancing  of  economic benefit  and cost.
                  Quantification of cost typically addresses the value of money and  risk.  The
                  legal/regulatory issues of most concern to the Brownfields' investor are not the
                  ones that  impact  cost  directly or indirectly,  but those  that introduce  risk,
                  particularly undefined or ill-defined risks.

                  The investor is comfortable  with legal/regulatory obstacles when the cost to
                  overcome these obstacles  can be factored into the economic viability equation.
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                  These costs may be excessive but that is an alert that the economic benefit or
                  return must be  greater.   However,  the greatest disincentive to the investor is
                  excessive  or unknown risk.  For this  reason, it is those legal/regulatory issues
                  that better define or even reduce risk that can have the most impact on the
                  success or failure of a Brownfields project, and will be addressed here.
4.1.6.1
CERCLA LIABILITY
                  The legal/regulatory  issue  most  associated  with  a  Brownfields  Project is
                  primarily one of environmental liability and its concomitant costs and delays.
                               Figure 4.3: Evolution of Brownfields Environmental Liability






CERCLA




"Join! & Several
Liability"







Clean AirAct
Clean Water Act
Toxic Substances Control Act
RCRA


1986
CERCLA Amendment
SARA



1992
EPA Guidance

                            "Covenant Not to Sir
                                PPA
                                                                          1996
                                                                      CERCLA Amendment
"Comfort Letter Policy"

Innocent La
ndowner
                                                                Liability Protections for
                                                              ''Secured Lenders & Fiduciaries1'
                  The principal source of Brownfields  environmental liability is the liability for
                  cleanup  under  the  Federal   Superfund   Statute  —   the  Comprehensive
                  Environmental Response, Compensation, and  Liability Act (CERCLA).  The
                  intent of CERCLA is to impose strict, joint and several liability for the cost of
                  cleanup of a contaminated site on the  parties responsible for the contamination.
                  These parties are the current and former owners  or operators of contaminated
                  properties  and  those  that arranged  for  the disposal  of wastes at  the  site.
                  However,  parties that have not necessarily  caused or  contributed to  the
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                  contamination  have  been  interpreted  to  be  "owners  or  operators"  or
                  "arrangers".

                  Under the strict, joint and several liability scheme,  a single responsible party at a
                  site can be held liable for all of the costs of cleanup, even if that party only
                  contributed a small portion of the waste. The party bringing suit does not need
                  to prove intent or negligence.  Therefore, a present owner who only recently
                  purchased the property could be held liable for all of the costs of cleaning up
                  the site.  Further, if that party sells the property to a new owner, the previous
                  owner can still be held liable for all  of the cleanup costs.  As a result  of this
                  potential legal liability, and the lack of control over  future activities at the site,
                  prudence  may impede the decision to transfer contaminated properties even
                  when they have outlived their usefulness.

                  Buyers,  including local governments, can be held liable for cleanup  costs at a
                  contaminated property, even  if they did not know  the land was contaminated at
                  the time of purchase.  Sellers can be held liable for  cleanup costs, even  if they
                  sell their property to a purchaser who agrees to assume all of the risks  associated
                  with the property.  A party can be held liable  if that person  generated  or
                  transported materials  to  the property, even if  that  person acted properly.
                  Additionally, owners or operators of the property can be held  liable for cleanup
                  costs even if the person disposed of waste many years earlier and acted properly
                  under then existing laws.
                  As a result, concerns for environmental liability can act as a disincentive  for the
                  following parties associated with a Brownfields project:

                  •   potential purchasers, developers, and occupants of such properties;
                  •   current owners that wish to avoid investigation  of or loss of control over
                      such properties in connection with redevelopment;
                  •   lenders for Brownfields projects; and
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                  •  corporate  entities  and  individuals  associated  with  such  parties  whose
                     activities or responsibilities might cause them to be considered to fall within
                     the "owner or operator" or "arranger"  category.

                  To address these concerns regarding environmental liability, certain amendments
                  to CERCLA, State and EPA regulatory policy changes, and legal decisions have
                  been issued to better  define the responsibilities of the various parties.   For
                  instance, the 1986  CERCLA amendments, the Superfund Amendments  and
                  Reauthorization Act  of  1986  (SARA),   provide  a  defense  for  "innocent
                  landowners", who  unknowingly acquire contaminated property as long as they
                  undertake the requisite inquiry (CERCLA Sections 107(b) and 101(35)).

                  Earlier court decisions  and an EPA rule were superceded by a 1996 CERCLA
                  amendment that added new protections from liability for  "secured lenders and
                  fiduciaries." These provisions modify the security interest exemption to lenders,
                  to establish a liability exemption for fiduciaries.  It also specifies actions that can
                  be taken by lenders and fiduciaries without incurring liability.   This protection
                  essentially provides that an owner of a facility who holds ownership primarily to
                  protect its  security interest, but  does not manage the facility,  is exempt  from
                  liability (CERCLA Sections 101(20)(E)(G) and 107(n)).

                  In addition, EPA, in its  attempt to further  clarify  or reduce risk regarding
                  owner/operator/arranger liability and thus encourage Brownfields development
                  projects, has adopted enforcement policies toward that end. For instance, under
                  the "Comfort Letter" policy, EPA will provide letters to assist parties who seek
                  to  purchase, develop, or  operate a Brownfield.  Typically, this letter clarifies
                  common  misunderstandings about  NPL  listing and CERCLA liability  and
                  includes provisions indicating EPA will not pursue those parties for the cleanup
                  costs of past contamination (USEPA, 1996(c)).
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                  Furthermore, 1992  EPA  guidance revised  earlier  1989  guidance  expanding
                  liability protection for small volume waste contributors under the "de minimus"
                  settlement provisions of CERCLA. These provisions allow settlement with a
                  party whose responsibility for hazardous substances at a site are minimal in both
                  amount and effects.

                  EPA guidance has also expanded the criteria it uses to decide whether or not to
                  enter into "covenant not to sue" or "Prospective Purchase Agreements" (PPA).
                  EPA can  now consider  benefits  to  the community in the  form  of  jobs,
                  productivity and revitalization as well as direct benefit to EPA in the form of a
                  voluntary cleanup or reimbursement.  Also, PPAs can now protect the parties
                  from potential contribution  lawsuits by  third parties,  as  well as from Federal
                  enforcement actions (USEPA, 1995 (b)).

                  The risk related to environmental liability not only stems  from the broad range
                  of potentially affected parties, but also from the uncertainties associated with the
                  adequacy and finality of the cleanup remedy, and the possibility of regulatory
                  delay. EPA addresses these issues in the abovementioned  policies and guidance,
                  but additionally has  been ready to  help the parties in a Brownfields project to
                  better  clarify  or define  risk  through  its  interpretation of  the  CERCLA
                  definitions.   An example  of this is EPA's current  approach  to interpret  the
                  definition of "facility" as not necessarily including an entire functional site (e.g.
                  factory or plant), but to focus on those places where the  hazardous substances
                  are located (EPA Interviews).

                  States such as Massachusetts,  Michigan,  and Pennsylvania, and municipalities
                  such  as Chattanooga, have added a  step to environmental liability risk reduction.
                  Through various means they have not only created "covenants not to  sue"  but
                  have  also put in place "agreements  to indemnify" (Northeast/Midwest Institute,
                  1998).  This may seem to be an extreme form of encouragement, but some type
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                 of indemnification commitment appears to be the wave of the  future to get
                 Brownfields development off the ground.
4.1.6.2       OTHER ENVIRONMENTAL LAWS
                 Other environmental laws may also impact the environmental liabilities of the
                 parties involved in a Brownfields project during the cleanup and redevelopment
                 phases.  Air emissions during this stage may be regulated by the Clean Air Act.
                 Process stormwater discharges may be regulated by the Clean Water Act.  Even
                 PCBs or other substances subject to the Toxic Substances Control Act may be
                 involved.   However, the law most likely to impact a Brownfields site is the
                 Resource Conservation and Recovery Act (RCRA).  It was enacted to  regulate
                 hazardous  waste  treatment,  storage,  and  disposal   (TSD)  facilities  and
                 underground storage tanks (UST). Most Brownfields sites,  if not classified as
                 hazardous  waste  TSD  facilities,  will have  a UST somewhere  on  the  site.
                 Fortunately, RCRA's UST provisions, like CERCLA, specifically exempt persons
                 holding a security interest in a site from cleanup requirements.

                 However, even if a Brownfields site is not regulated because of USTs, or because
                 it was a former hazardous waste TSD  facility,  the developer may become a
                 "generator" under RCRA simply by excavating any substances on the site which
                 come within the definition of a "hazardous waste" (RCRA Section 3002). Either
                 way, the RCRA "corrective action", "manifesting", "permitting", and "land-ban"
                 restrictions may come into play and have a severe impact on the environmental
                 liabilities and costs associated with development of the site.

                 Corrective  action, for example, may direct cleanup of an entire "facility" before
                 development may proceed on the part targeted  for Brownfields development.
                 The definition of "facility"  under RCRA (RCRA Section  1004(29)) is  more
                 specific and rigid than under CERCLA. Where feasible, EPA  is considering
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                  amending  the  RCRA  regulations  to  eliminate  obstacles  to  Brownfields
                  redevelopment.  However, for provisions such as the facility definition, as with a
                  number of others included within RCRA, relief cannot come from the USEPA
                  or the courts.  It must come from a congressional amendment of the law itself.

                  In summary, the cost associated with the  risk due to environmental liability,
                  which  is either unknown  or ill defined,  may be the measure of difference
                  between a successful and unsuccessful Brownfields project.  To the extent that
                  this risk is  defined, investors  and other  parties can build in contingencies and
                  make decisions to improve  the probabilities  of the success of the venture.  EPA,
                  state and municipal regulators and other  interested persons have established
                  policies, agreements, decisions, and guidance in a continuing effort to clarify,
                  define  and  even reduce risk in the  circumstances  outlined above.  Therefore, a
                  significant indication of the probability of success of a Brownfields project is the
                  extent  to which the project  decision-makers  have availed themselves of this
                  knowledge  and introduced it into their decision making.  Financially interested
                  parties who have not calculated the risk from or, at worst, are not aware of the
                  environmental costs and liabilities listed above are indicative of a Brownfields
                  project with a dubious chance  for success.
4.1.7
Site Redevelopment
Approach

-

Program Factors

Ecological Factors

Socioeconomic
Factors

Site Marketing


                  A Brownfields site becomes abandoned or is underutilized for a number of reasons.
                  Often the reasons have little or nothing to do with the perceived or actual threat of
                  contamination at the site.   The old base of large industrial institutions that was
                  primarily responsible for the urbanization of America from  the late nineteenth
                  century  to  the present, has slowly eroded over the past twenty years.   These
                  industries provided economic support in the form of jobs, tax revenues, material
                  goods and services, but also in many cases, served as a singular defining element for
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                  the character of the city itself.   Such associations as the automobile industry with
                  Detroit  or steel  with Pittsburgh  are  just  two examples.  However,  smaller
                  communities such as Gary, IN or Chattanooga, TN have also been defined by their
                  industrial past.

                  The  decline of the industrial  base has left  a  large  inventory  of economically
                  unproductive Brownfields sites, not only in the industrial sectors  but also  in allied
                  commercial, retail, and housing areas.  Correspondingly,  the  economic  base  of
                  employment and tax revenue for the urban community has been diminished. The
                  new imperative for communities at the end of the twentieth century is to redevelop
                  the Brownfields legacy of the American industrial boom and stimulate an economic
                  revival of the  inner core of cities, as well as older industrial areas in smaller, more
                  rural communities.

                  However, unlike previous approaches to site development that concentrated heavily
                  on economic  factors,  the  major feature of the Brownfields  site redevelopment
                  process  is  a  holistic  orientation  that  recognizes the importance  of balancing
                  economic  factors  with social and  ecological  factors.  The  concern here is with
                  achieving site redevelopment that  also contributes in some  way to  the overall
                  sustainability of subsequent Brownfields processes, and ultimately to  community
                  development goals.

                  In this discussion, the term "site  redevelopment  process" refers to the specific
                  restoration  and reuse  process  of a site  and  not  to the overall  Brownfields
                  redevelopment program or project.

4.1.7.1       PROGRAM   FACTORS   INFLUENCING   THE  SITE   REDEVELOPMENT
              PROCESS

                    Site Redevelopment Program Factors
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                        Community Expectations
                        Rationality
                        Ownership
                        Program Life Cycle
                        Control of Development
                  A Brownfields site is the result of multiple and complex processes that affect the
                  socioeconomic life of a  community and  the  natural ecology that supports the
                  community.   These include economic decline, changes in residential and living
                  patterns, increasing levels of social pathology (e.g. crime, drugs, etc.), a low market
                  potential for the reuse of many sites, and the increasing degradation or loss of natural
                  resources.

                  During the course of this  study, a  number of factors specifically affecting the
                  sustainability of the site redevelopment process have been identified.

                  Community Expectations - A Brownfields  site  takes time to redevelop  and this
                  contradicts the desire of a community to see a quick result that  addresses a large
                  number of needs simultaneously.  The general public often  does not appreciate the
                  number of steps involved, the fiscal and structural limitations on what the process
                  can accomplish, and the time needed to carry out the process.  The result is often a
                  growing  dissatisfaction with the project and a resulting loss of long-term  support.
                  The development of realistic expectations on the part of the affected community is
                  frequently cited as a key-contributing element to  project sustainability.

                  Rationality - One of the more important influences on the attempt to attract new
                  development for Brownfields sites is that despite a growing  shortage of developable
                  land, the market has not shifted sufficiently for the redevelopment  of Brownfields
                  sites to be competitive with greenfield  sites.  In part, this is due to a failure to capture
                  the entire cost of development,  including infrastructure and  environmental  costs
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                   (cyclical rather than linear), from the potential developer.  Subsidized development
                   occurs in the suburban fringe areas, but is absent from the inner city.  The older city
                   structure is often assumed to have an  edge in infrastructure development, but this
                   infrastructure is often insufficient to support modern development.

                   The key issue, from a business standpoint, is that a rational decision to expand or
                   acquire new space would favor a greenfield site. The site is  clear, the associated risk
                   and costs are low - especially if infrastructure costs are subsidized with public funds —
                   and the time required for development is significantly reduced.  In order to attract
                   development to Brownfields sites, a corresponding value  must be  offered as an
                   incentive to counter-balance the advantage of greenfield development.

                   Ownership - There are a number of reasons why Brownfields sites have not been
                   redeveloped.  Chief among them is site ownership. In some cases owners simply do
                   not have the money to redevelop the site.  In others, owners do not want to lose the
                   land  because they have  some  sense of its potential  value, but  do not  really
                   understand the real estate marketplace  or the reality of the  costs of contamination.
                   Estate issues  related to the death of one owner or one member of a partnership can
                   also present problems.  The potential value of the property as a leverage to secure
                   credit for other transactions may be an impediment to sale of the property.  In many
                   cases  it is also difficult to track down absentee owners.

                   The  resistance of current property owners and the  cumbersome  requirements
                   necessary  to transfer  or acquire  a property pose  a  significant obstacle to the
                   Brownfields  redevelopment process.   This is  because the unused  or underused
                   property continues to deteriorate while past or current owners  are being recalcitrant
                   or  cannot be located. One criteria that has been used  in the selection of potential
                   candidate sites for many Brownfields projects is a determination of the relative effort
                   required to obtain transfer of the property (or ownership) for redevelopment.
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                  Program Life Cycle - It would be reasonable to expect that as the Brownfields
                  program develops and expands over a number of years, the increasing experience
                  with the process would lead to greater efficiency and reduced costs.   This would
                  result in  a corresponding decline  in  the amount of public revenue needed to
                  continue the development process.  However, this may not necessarily  be the case.
                  The potential for ever-increasing cost and complexity in the redevelopment process
                  may also increase as the program matures. Candidate sites in the earlier stages of the
                  program  will most  likely  be  those  that  present relatively  straightforward
                  contamination problems and have good market potential. But, in the later stages of
                  the community redevelopment program, the number  of available sites with good
                  potential will dwindle.  As a result, the program will need to address sites with more
                  problems that are less  attractive for redevelopment.  The costs of success at these
                  sites will be increased as a result. In  order to  maintain a sustainable program, the
                  community may have to allocate more rather than less public funding to accomplish
                  the same result in the future.

                  Control  of Development  -  Where a Brownfields redevelopment has  been
                  successful, the success may have a tendency to attract additional development to the
                  affected neighborhood or  community. This development may not necessarily be
                  controlled by the same criteria  as  are  established for the  sustainability  of the
                  Brownfields  project, since  this  development is  not  directly associated with  a
                  Brownfields site.  As a result, the success of the Brownfields project may cause a
                  development  boom  in the surrounding area that is essentially not sustainable or
                  ecologically sensitive.   The incorporation  of the  Brownfields  project  into  a
                  comprehensive  economic  development  plan  for the community  is  critical to
                  avoiding this type of impact.

4.1.7.2       ECOLOGICAL   FACTORS  INFLUENCING  THE  SITE  REDEVELOPMENT
              PROCESS
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                    Site Redevelopment Process - Ecological Factors
                        Eco-Industrial Parks
                        Reclaimed Brownfields for Parks & Open Space
                        Greenspace as Interim Use
                        Reclaimed Brownfields in Ecologically Sensitive Areas
                    J  Landscape Design Factors
                  Since  Brownfields  sites were once  active industrial or  commercial  businesses,
                  redevelopment strategies for these sites typically focus on rehabilitating them into
                  vibrant new commercial or industrial uses. But new strategies are needed for many
                  sites to prevent them from reverting back to Brownfields  and to contribute  to
                  sustainable growth in the community. One strategy is to link the intended land use
                  and architectural  design with ecological  and aesthetic  qualities  valued  by the
                  community. This strategy applies to urban as well as rural Brownfields sites.

                  Several approaches were identified through the research that apply this strategy and
                  thereby promote the sustainability of Brownfields site redevelopment.

                  Eco-Industrial Parks  - Basically,  an eco-industrial park  is a combination  of
                  manufacturing and service businesses designed  to coordinate their collective resource
                  needs  and processes  in  order to increase efficient use of raw materials, minimize
                  waste  outputs,  conserve  energy and natural resources, reduce  transportation
                  requirements,  and provide an aesthetically attractive  place to work.  This resource
                  efficiency means  economic benefits  for the businesses.  The community benefits
                  from improvements in ecological quality and  creation of jobs.  Two types of eco-
                  industrial parks are emerging as viable options for Brownfields sites: virtual and zero-
                  emissions or closed loop manufacturing (Spohn, no date).

                  Virtual eco-industrial parks  represent networks of related regional  companies not
                  physically located in the same complex.  By coordinating services and processes, and
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                   in some cases combining them, the companies can create an economy-of-scale that
                   results  in cost savings and  decreases ecological impacts.  Networked  businesses
                   located within a  common region reduce  transportation costs  and create waste
                   exchanges that can realize savings in solid waste and hazardous waste disposal costs.

                   Zero-emissions or closed loop manufacturing parks focus on the total elimination of
                   wastes.  Companies are co-located to share energy, water, and other resources, and
                   to  recycle low-value byproducts.  By  careful design and  cooperation, firms can
                   coordinate  their  production  processes  and  infrastructure  needs  to  maximize
                   efficiency.  Examples of this type of  eco-industrial park include Cape  Charles'
                   Sustainable  Technologies Industrial  Park, and the  Volunteer  Site's National
                   Sustainable  Development Laboratory outside  Chattanooga, which test  innovative
                   remediation technologies and foster  linkages  and research in recycling  or  reusing
                   sustainable buildings.

                   Reclaimed Brownfields for Parks  and Open Space -  Creating parks, gardens,
                   greenways, trails, and open space can be very effective and an inexpensive way to
                   catalyze sustainable redevelopment of  infill  properties.  Because  people  do not
                   frequent greenways as often as business or residential areas, they are more amenable
                   to  alternative  remediation strategies.   These strategies  include  bioremediation,
                   phytoremediation, and natural  attenuation that are well suited to sites of low level
                   contamination with little  risk of chronic health exposure. These low cost remedial
                   alternatives  can create an attractive site  that stimulates increased  property values
                   surrounding it.  This can result  in increased tax revenues (which could offset the
                   remediation costs) and greater market demand to redevelop nearby properties. In
                   addition,  parks  can generate revenue  from  user  fees, concessions, boat/bicycle
                   rentals, etc.  This approach is especially effective for blighted properties that are not
                   otherwise economically beneficial for redevelopment.
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                  Greenspace as Interim Use - In certain situations like small or isolated parcels, an
                  effective approach to redeveloping a Brownfields site is to convert it into an urban
                  forest, park or garden on an interim basis until the parcel can  be integrated into  a
                  larger redevelopment plan for the  area. Urban  trees provide $4 billion in energy
                  savings  each  year  (i.e. through  shading  and cooling)  and  this  saving could be
                  increased if trees were strategically planted (Moll, 1995). Urban forestry programs
                  include  actively promoting the  planting of new trees as  well as  the reforestation of
                  urban areas where die-out of trees has  occurred.  Urban parks and gardens  serve as
                  places for community reflection and recreation, thereby enhancing the quality of life
                  of its residents.  Additionally,  urban parks and  gardens contribute to cleaner air
                  quality  and can become valuable tools for achieving a community's  air emission
                  compliance requirements.

                  Reclaiming Brownfields in Ecologically Sensitive Areas - Restoring Brownfields
                  to blend into the surrounding ecological  systems offers many  indirect benefits to
                  sustainable communities.  For instance, a key component of the Cape Charles, VA
                  Brownfields project is to restore  portions of  the  Brownfields site  into coastal
                  wetlands  and  beach  dune areas;  a major  natural  feature on  the  surrounding
                  landscape.  These areas will be incorporated into wildlife preserves and protected
                  habitat  areas that will attract a  variety of native and  migratory bird  species, among
                  other types  of wildlife, which will  become a focal point for environmentally-sensitive
                  ecotourism  businesses within the  community.  The objective is  more wildlife, more
                  people, more jobs, more growth.
                  Landscape Design Factors  - Integrating Brownfields design and land use with
                  natural  landscape features builds  sustainable links between the  redevelopment and
                  the ecology. In Providence, RI and Chattanooga, TN, the  communities are using
                  the  riverfront as the  central  attraction to  anchor redevelopment  of adjacent
                  Brownfield  sites.  In Cape Charles, the Sustainable Technologies Industrial Park has
                  been architecturally designed to balance with the surrounding natural landscape.  The
                  industrial building complex incorporates solar  energy technology, native vegetation,
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                  fresh water streams,  marshes, and earth-tone building designs  to blend into the
                  landscape for greater aesthetic appearance and value.

4.1.7.3       SOCIOECONOMIC FACTORS INFLUENCING SITE REDEVELOPMENT
                    Socioeconomic Factors Influencing Site Redevelopment
                       The Right Property
                       The Right Use
                       The Right Incentives
                  The  Brownfields redevelopment process  should  contribute in  some way to the
                  overall sustainability of the community, as a community.  To a great extent, the
                  design parameters for an individual project will be affected by the site characteristics,
                  the influence  of surrounding land uses, and the goals of the comprehensive plan.
                  But the proposed reuse of the subject site should also conform to the overall vision
                  of the community's economic and social future.

                  Several socioeconomic characteristics of a Brownfields project have been linked to
                  the potential for sustainability.  From the standpoint of the project itself, the most
                  important factors contributing to overall success can be summarized as: 'the right
                  property, the right use, the right incentives.'

                  The  Right Property  —  There is  one important characteristic associated with
                  successful  redevelopment  properties  that  also   applies  to  a  Brownfields
                  redevelopment; the property must have some value.  In the case of the Brownfields
                  site, this value is calculated in terms of the desirability of a clean site at the current
                  location.

                  Several factors can influence this determination.  Especially important is the value
                  and use of surrounding real estate. It may be more difficult to attract certain types of
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                  investors to properties in areas  of the city that are severely depressed or exhibit a
                  high crime rate. The surrounding land uses should be compatible with the proposed
                  project.  Also important is  the  level  of stability in the surrounding neighborhood.
                  Potential investors will be concerned with establishing some certainty that they know
                  what the neighborhood will look like  in the future and that the neighborhood is not
                  in a constant state of change.

                  The cost of the initial acquisition of the property, and the level of environmental
                  uncertainty associated with  the  project, are expected to have an influence on the
                  project.    These costs should be in line with the intended use and the uses of the
                  surrounding properties. For example, if the anticipated revenue (profit in the case of
                  a private development) generated from any proposed redevelopment will not be
                  sufficient to ultimately cover the cost of the site  purchase plus remediation, some
                  source of external funding will be necessary in order to sustain the development.

                  Other factors to be considered, especially for private development  (Skowron, 1998)
                  include:

                  •   site  visibility, ease of access, traffic count and population density   — for a
                      potential retail site;
                  •   the quality and character of adjacent structures  - for a potential residential site;
                  •   labor force availability, access to customers and suppliers, and an airport hub  —
                      for an industrial site; and,
                  •   transportation access, modern utilities and other infrastructure, topography and
                      soil conditions (flat sites are preferred), and proper zoning - for any site.

                  As previously noted, the importance  of ownership to the ongoing success  of a site
                  redevelopment  relates to  the  maintenance   of project continuity and flow.
                  Difficulties  in  identifying absentee landlords, acquiring ownership through public
                  taking, or other estate considerations (in the death of an owner) can severely hamper
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                  progress  and may  ultimately  cause a  project to  fail.   Important  to the site
                  consideration is the presence of a known owner who is willing to participate with the
                  program, either by sale, or some other ownership transfer arrangement.

                  There are also many good reasons to select a property  that may not be  easily
                  remediated or may have less  than desirable redevelopment qualities.  The property
                  may be important, not because of the quality of the property itself, but because it is
                  centrally located or is part of another parcel, or when combined with another parcel
                  may collectively become important. It may also be important to the development of
                  other adjacent parcels, or other projects in the nearby area.

                  In many cases an urban infill development may be a highly sustainable Brownfields
                  candidate site.   Urban infill  development  on individual  building lots  enables a
                  Brownfields program to grow and evolve through a series of small and incremental
                  additions and changes.  It is especially  useful in  areas where existing businesses
                  require space for expansion, or where restoration and reuse of historic districts, and
                  the linking  of sustainability to  historic preservation, are important.  (Beatley and
                  Manning, 1997).

                  The Right Use - Determination of the right land use for a candidate site is critical to
                  the overall sustainability of the process itself and its final outcome.  Important to
                  this process, in addition to site history and surrounding land uses, is the role of the
                  community in specifying its needs, values and most especially, its understanding of
                  the project and its  role in the community.  Significant delays in implementing the
                  final  plan can  result from the resistance  or lack  of cooperation of community
                  residents.

                  However, a  number of project participants also  cautioned that the community
                  should not necessarily be the sole determinant of the future use of the property. A
                  high community priority may not necessarily be a highly marketable redevelopment
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                  priority.   The community's preferences may also be too narrowly focused.   The
                  process of determining future site use must be a balance between the community's
                  values, the values of the market, and the values that will attract a specific developer.

                  The Right Incentives  - As noted  earlier,  one important consideration  for the
                  success of a site redevelopment is the continuing attractiveness  of greenfields.  The
                  sustainability  of a Brownfields project depends on the successful development of
                  incentives and trade-offs to increase the potential value or return on a Brownfields
                  redevelopment.

                  Incentives are also important to several groups of stakeholders  involved in the
                  redevelopment process.  These stakeholders include:

                  •   owners as an inducement to sell or cleanup existing contaminated property;
                  •   developers  in  order to  increase the potential return on  investment  from  a
                      Brownfields redevelopment by increasing financial opportunities and decreasing
                      uncertainty;
                  •   lenders or investors who  will need to balance the value  of  investment  in  a
                      Brownfields redevelopment against other real estate or market investments; and
                  •   the community in the form of what encourages people to patronize or  support
                      the intended use of the property over the long term.

                  In general, there are several forms of incentives.  These incentives  will often be
                  specific to the individual project or its participants.  Direct subsidies in the  form of
                  public or private grants to cover specific activities associated with the Brownfields
                  redevelopment are the most visible form. Also, frequently used are tax credits, either
                  to encourage development or as an inducement to increase employment in the  local
                  community.  Overlay districts such  as  Enterprise  Community or Empowerment
                  Zone designations  are also a strong inducement to development. One of the most
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                  important incentives from the standpoint of the lender, investor, or developer is the
                  presence of mechanisms for insurance or indemnification against uncertainty.

                  A powerful incentive to ensure continued community support of the project is the
                  strength of the public involvement program. The more the community feels a sense
                  of participation  in the  planning and decision  making process, the more it will
                  develop a sense  of ownership and identification with the proposed project, and a
                  corresponding sense of community pride associated with it.

                  In all  cases,  the sustainability of the  proposed project depends greatly  on the
                  marketing skills  and strategies employed to develop a rationale for a business or
                  industry to move into the central city or to reuse an existing rural development site.
                  For  the  public in general,  the  greater accessibility of daily  life services  and the
                  potentially increased opportunities for recreation and cultural  activity in the central
                  city represent a potential incentive to consider Brownfields properties.
4.1.7.4        SITE MARKETING
                  In the process of gathering information from project participants, one of the most
                  frequently cited problems  associated with a  Brownfields  redevelopment  is  the
                  process  of marketing the development site to potential developers.  Site marketing
                  includes  not only the  process  of selling the redevelopment project to potential
                  developers, investors, or lenders, but also to the community as a whole.
                  The community will be the ultimate beneficiaries of the proposed activity, as well as
                  the ultimate consumers of whatever product, service, or facility is  proposed for the
                  site. The important consideration is the analysis of the current market structure of
                  the community (e.g. labor, housing, consumer) to determine what the current trends
                  are and what is supportable.
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                  The role of prevailing market forces in the long-term sustainability of a Brownfields
                  redevelopment  is  often  overlooked.   It  is  essential  to  examine  both the
                  macroeconomy and the microeconomy of the local community. The question for a
                  Brownfields redevelopment is that of balancing community values and goals against
                  the requirements of the marketplace and what the market will bear and support. In
                  addition to the carrying capacity of the natural environment, the carrying capacity of
                  the economy becomes  an important consideration,  not only for what  can be
                  accomplished, but also  for when.  The timing of the development project, as with
                  any economic investment, is often critical to its long-term success.

                  Market conditions,  especially real estate conditions may also influence the final value
                  of a clean site, thus dictating the range  of development options available.  An
                  understanding of the real estate market is important to match  the right property to
                  the right development use, and to know what catalysts are needed to stimulate the
                  development of the property.

                  The  specific  market analysis  for a given site  includes three key components:
                  market supply, market demand and  revenue projections (Skowron, 1998).  The
                  analysis of supply  examines the existing quantity of similar type development in
                  the target market, by type (e.g.  office, retail, residential, etc.).  Current vacancy
                  rates are also  determined.  The result is then tested in comparison with the
                  current absorption rate, or the amount of the total that was used over the past
                  few years.

                  Analysis of the result indicates both the demand for the type of facility proposed
                  and the currently available quantity of that type of development.  On this basis,
                  a more accurate  picture  of the  actual need for the  proposed facility  can be
                  determined. For example, if current demand is low and vacancy rates are high,
                  the proposed development will be extremely difficult to market, no matter how
                  much effort is placed on site cleanup and restoration.
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                  Once the need for a proposed facility has been established, current sales, rental
                  and employment figures for similar projects can be obtained.    Examination of
                  these figures will form the basis of potential revenue projections associated with
                  the proposed  development.  If the potential  rate of return  calculated for  the
                  developer is not competitive, a determination can be made for what level and
                  types of subsidy may be required can be made.
4.1.8  TedmdcgyApplications
                  Since the beginnings of the human species, science has provided the knowledge,
                  technology, and practical means for obtaining our shelter, subsistence, security,
                  and  social amenities.  The raw materials  of technology,  energy and natural
                  resources  have  either  been  considered as  infinite  in  their  supply,  or  as
                  replaceable with the help of new, alternative technology. As the size and density
                  of our communities grew, technology  has evolved to provide greater  speed,
                  variety, cost savings, and effectiveness in the consumption of energy and natural
                  resources.
                  More   efficient   and   effective   extraction,   processing,   transportation,
                  manufacturing, distribution, and communication technologies enable us to keep
                  pace with population growth  and demands.  However, we have come to  realize
                  there are limits.  "From  the extraction  of raw  materials,  through  wasteful
                  production processes that produce  toxic by-products, to products with very
                  limited utility, and ultimately, to waste which accumulates in landfills, our current
                  system of manufacturing and using products is a one-way street.. .unless  you're
                  talking about  a  system in which there  is  unlimited  resource availability and
                  unlimited waste disposal capacity, producing, consuming, and discarding goods
                  in this straight-line way is obviously not sustainable" (Nelder, 1997).
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                 Technology and its application are clearly major elements of sustainability. The
                 process of identifying, developing,  evaluating, and integrating new technology
                 applications into community redevelopment provides opportunities to achieve
                 significant cost benefits for projects and quality of life improvements for the
                 residents.  This  process can also help change traditional social,  economic and
                 ecological perspectives and values that contribute to unsustainable development.

                 As technology is adapted and applied  to address our immediate needs  for
                 material resources, energy, a healthy environment, security, and convenience, it
                 can also be evaluated in terms  of providing the quality of life we want for future
                 generations.  The key  is to  make the  technologies  cost  effective to  the
                 communities  and developers, and  to  foster  community confidence in  the
                 technologies through education and experience with their benefits (Chattanooga
                 Site Interviews).

                 The Public Technology, Inc. (PTI,  1998), a non-profit organization supporting
                 city  and county governments  nationwide, has identified five primary areas of
                 technology  that  provide  an  effective  framework  for  categorizing  the
                 characteristics  of  technology  applications   that  promote  immediate  and
                 sustainable Brownfields redevelopment in urban and rural communities.  These
                 areas are  energy,  environment, transportation, telecomm/information, and
                 public safety.
4.1.8.1        ENERGY TECHNOLOGY
                   Energy Technology
                       Reducing Energy Demands
                       Renewable Energy
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                 Sustainable  Brownfields  redevelopment  seeks  to  improve  energy  efficiency,
                 conserve  energy  resources,  reduce energy demands, cut costs, and  develop
                 revenue from local energy assets.  Energy consumption is  therefore an effective
                 indicator for measuring sustainability.

                 Reducing Energy Demands - In Chattanooga, the city has integrated energy
                 efficient  and non-polluting  electric buses into its plan  for redeveloping the
                 downtown core.  The system provides three  public  parking lots on  the city
                 fringe to  reduce traffic and  maximize land use for greater revenue  producing
                 commercial  businesses downtown. The electric bus system shuttles people into
                 and  around the downtown core  through a fast and convenient routing  plan.
                 Revenue from the parking lots is used to subsidize free and unlimited shuttle bus
                 ridership. The system has become a source of community pride and a social
                 gathering place of business people, merchants, visitors, and consumers.

                 Renewable  Energy - In Cape  Charles, the community  has  linked solar cell
                 technology into its sustainable technologies industrial park, by including a solar
                 cell manufacturing company as one of the anchor tenants and by incorporating
                 solar cell technology into  the design and construction of the office park complex
                 to achieve energy savings.
4.1.8.2
ENVIRONMENTAL TECHNOLOGY
                   Environmental Technology
                      Industrial Ecology
                      Eco-Industrial Parks
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                       Pollution Prevention and Waste Minimization
                       Site Assessment and Remediation
                       Ecological Monitoring and Assessmer
                  Many new and innovative environmental technologies are emerging to promote
                  community sustainability and sustainable Brownfields redevelopment.

                  Industrial Ecology - The fundamental  concept of industrial ecology is  that
                  society must balance its accounts of materials and energy.  The ultimate goal of
                  industrial ecology "is to minimize  harmful wastes  and to  reuse to  the greatest
                  extent both industrial products themselves and wastes" (Kneese, 1998). Jesse
                  Ausubel (1998)  identifies  five key means  by which industrial ecology can lessen
                  the   impacts  —  zero  emissions,  materials   substitution,  dematerialization,
                  decarbonization,  and  function  economy.   His  technological  methods  for
                  achieving progress include materials flow and balance analyses, life cycle analyses
                  of products,  and analytical indicators such as  intensity-of-use and waste-to-
                  product ratios.

                  Eco-Industrial Parks — The practical application of industrial ecology is the eco-
                  industrial park, see Section 4.1.7.2. The design of these parks is based on how
                  natural ecosystems function.  The principle being that "a closed-loop of energy
                  and waste  is more efficient and  sustainable  than a system  viewing each in
                  isolation"  (Burlington, VT, 1997). Just as in natural  ecosystems, where all
                  organisms are inextricably linked to each other and to the surrounding physical
                  processes,  the  objective   of  the  eco-industrial  park  is  to link  technologies,
                  processes, products, and  industries.   This  will achieve environmentally sound
                  development, stable economic markets, job creation, and  new values and uses
                  for  traditional waste products.   Several communities are incorporating eco-
                  industrial parks  into their  sustainable Brownfields efforts including, Burlington,
                  VT, Buffalo, NY, and Cape Charles, VA.
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                  Pollution  Prevention  and  Waste  Minimization  - Process  engineering is
                  refocusing  on  waste  minimization with  the goal  of creating  closed-loop
                  manufacturing processes and recyclable or reusable materials and products.  For
                  example, the Burlington,  VT Pilot Project is  investigating alternative,  high
                  strength waste to product technologies such as bioshelter  materials, fish  food
                  and fertilizer production products.  The Green Project, a local community-based
                  program in New Orleans,  is promoting the recovery,  reuse and  recycling of
                  paint and other home building products. The Navajo Nations Pilot Project is
                  planning to reuse the building and machinery from a former lumber mill as the
                  basis for a more efficient mill operation.

                  Site  Assessment  and  Remediation   -   New  applications  of  analytical
                  instrumentation  in the  field  are  enabling  owners and communities  to  more
                  quickly, accurately, and less expensively characterize the nature and extent of site
                  contamination.  Examples include  x-ray fluorescence for lead and other metals
                  in soil, immunoassay test kits especially  for PCBs, field GC/MS methods for
                  organics, and mobile analytical laboratories used in the New Orleans and Illinois
                  Pilot Projects. Innovative materials and technological methods are also enabling
                  site remediation techniques to be integrated into reuse designs. Examples are:

                  •  the semi-porous membrane parking lot at the Foundry Site sports stadium in
                     Chattanooga;
                  •  the use  of onsite petroleum waste from leaking underground storage tanks
                     for the asphalt used to  repave  the Buffalo, NY Pilot Project site along the
                     waterfront;
                  •  air sparging of contaminated groundwater in Cleveland, OH; and
                  •  the use of phytoremediation in Trenton, NJ.
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                 These technologies  are not only as  effective  (or more so) than  traditional
                 excavation/landfilling  and pump-and-treat  in  achieving the  targeted cleanup
                 levels, but because they can be designed into the ultimate reuse of the property,
                 they directly promote long-term sustainability of the project.

                 Ecological Monitoring and Assessment - New remote sensing, Doppler radar,
                 and global positioning satellite (GPS)  technologies are enabling environmental
                 scientists to  identify, monitor  and  evaluate  changing  conditions  in  the
                 ecosystems' health.   These conditions include  trends in global temperature
                 changes,  ocean  currents,  and  surface  water  flows,  forest  cover,  animal
                 migrations,  desertification, etc. These  technologies can enable a community to
                 develop   its  comprehensive  baseline  profile  of  ecological conditions  and
                 urbanization, and to monitor changes to the environment based on its land uses
                 and trends, in order to evaluate and make changes to assure its sustainability.

                 Other examples of environmental technologies that create job opportunities and
                 other community benefits include:

                 •   the hydroponics facility being developed on the Buffalo, NY Pilot Project
                     site to create an environmental-friendly means of producing tomatoes all
                     year long in northern climates; and
                 •   biotechnology to create resistant strains of food sources, alternative food
                     sources, enriched food sources, and human health dietary supplements and
                     medications.
4.1.8.3       TRANSPORTATION TECHNOLOGY
                   Transportation Technology
                       Intelligent Transportation Systems (ITS)
                       Alternative Fuels & Vehicles
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                 Transportation technology entails transportation systems and the various modes
                 or  "hardware" to move  people  and goods.   Two specific  characteristics  of
                 transportation technology that can be associated with sustainable Brownfields
                 redevelopment were identified in this study's research, although many more may
                 exist.

                 Intelligent Transportation Systems (ITS) -  ITS involves the use of advanced
                 computer, electronics, and  communications  technologies  to  increase  the
                 effectiveness, efficiency, cleanliness, and safety of surface transportation systems.
                 An ITS would be supported and  integrated  into an Intelligent Transportation
                 Infrastructure (ITI) that includes:

                 •   traffic signal control systems;
                 •   freeway management systems;
                 •   transit management systems;
                 •   incident management systems;
                 •   electronic fare payment systems;
                 •   regional multi-modal traveler information  centers;
                 •   railroad signal control systems; and
                 •   emergency management systems.

                 Though still  theoretical, the benefits  of  an  ITI/ITS would be reducing travel
                 time,  accidents  and  congestion; providing  better  information,  increased
                 customer  satisfaction, and enhanced quality of life; and additional  opportunities
                 for new "environmentally-clean" businesses and intergovernmental cooperation
                 (PTI, 1996).

                 The  Intermodal  Surface Transportation Efficiency Act of  1991  (ISTEA)
                 encourages  the  use  of  ITS  and   provides  funds  to  communities  for
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                 implementation.   As a  result,  ISTEA  funding  is  a viable  alternative for
                 communities  that integrate these component  technologies and systems into
                 Brownfields redevelopment plans and urban strategies.

                 Alternative Fuels and Vehicles - Innovative applications  of natural gas,
                 electricity, and other alternative fuels to power privately owned and commercial
                 fleet  vehicles  is  growing in  public  acceptance  and  economic  feasibility.
                 Brownfields redevelopment can incorporate these vehicles and their businesses
                 into community-wide and regional multi-modal  strategies,  land reuse, and
                 marketing efforts  to further sustain  the project and  community.  An excellent
                 example is Chattanooga's electric shuttle buses.  These vehicles also contribute
                 to  the  ecological sustainability of the  community  by reducing CO2 and
                 particulate emissions, thereby promoting cleaner air.
4.1.8.4
TELECOMM/INFORMATION TECHNOLOGY
                   Telecomm/Information Technology
                      Geographical Information Systems (GIS)
                 New telecommunication and information management technologies contribute
                 to sustainable Brownfields redevelopment by improving services, cutting costs,
                 and developing new businesses that are environmentally "clean"  and readily
                 adaptable   to   existing  Brownfields  buildings.    Telecommunication   and
                 information distribution technologies  facilitate  public meetings,  notices,  and
                 education  of the community regarding Brownfields activities.   This  promotes
                 community  confidence  and acceptance of proposed remediation and reuse
                 plans.

                 GIS - Information processing  and management systems such as  geographical
                 information systems, commonly referred to as  GIS, have become  extremely
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                  versatile and valuable tools.  These tools enable communities to visually identify
                  and map Brownfields sites or potential sites and to overlay them with municipal
                  planning information,  baseline  ecosystem  characterizations,  and  community
                  demographics  to create comprehensive  databases. GIS  applications have been
                  incorporated into many of the Brownfields projects analyzed. The ease by which
                  these  databases  can  be   maintained  and  updated  to  provide  graphical
                  representations of ecological, economic and social changes in the community are
                  the key to their role in promoting sustainability.
4.1.8.5
PUBLIC SAFETY TECHNOLOGY
                  Public safety and health is a primary community concern. There is a wide range
                  of evolving trends  and  capabilities in  safety technologies.    From  simple
                  community alarms, air quality monitoring systems, fire suppression systems, and
                  security monitoring systems  to complex  infrastructure  and building  code
                  developments (e.g. earthquake resistant buildings and water treatment methods).
                  These  trends   can  promote Brownfields  sustainability  by  enhancing  the
                  marketability of a site and reassuring the  community's confidence that safety and
                  health risks are effectively addressed.
4.1.9  PtojectFunding/FwajxE
                  The association between long-term financing and the sustainability of a Brownfields
                  redevelopment project is fundamental. Access  to  equity financing and early-stage
                  capital is often considered not only to be the most important factor in a project, but
                  also  the  most difficult  to  secure  (Brookings, 1997).     A number  of project
                  participants interviewed have indicated that analyzing the funding needs of a project,
                  and  identifying and  confirming the  long-term  funding sources early in the
                  redevelopment cycle,  is a key component of the  continued success of a project.
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                   Conversely,  the  under  commitment  of resources  and  a lack of funding were
                   considered a major impediment to the redevelopment of a Brownfields site.

                   Although the ultimate goal  of public support to the  Brownfields redevelopment
                   process is to minimize and eventually eliminate the use of public funds, most of the
                   projects examined as a part of this study utilized a combination of public and private
                   funds to provide the financial basis for the project's continued operation.   In the
                   more  successful projects, public funds were utilized as an impetus or  catalyst to
                   initiate the project  effort and provide the seed capital with which to leverage other
                   non-public foundation grants, and private investment. The goal is to define a pivotal
                   point at which the  project is  shifted from a reliance on public investment to a point
                   where private investment and market forces can take  over.

                   Brownfields  project funding requirements can be seen as a continuum ranging from
                   a  project  that is  expected to  be ultimately  self-sustaining within the  private
                   marketplace  to one that is completely supported by  public funds throughout its
                   anticipated  life-cycle.    The mix  of  private  and  public  funds embodied in  a
                   Brownfields  redevelopment project will differ from project to project, based  on the
                   characteristics of the specific site  in question, capabilities of the current owners, and
                   the planned future use of the site.	
                   In the case
                                    Three Primary Funding Considerations
                                  D Developer Capabilities • Future Site Uses
                                  D Site Characteristics
for example, the
                   anticipated income and subsequent rate of return on the developer s investment may
                   be sufficient to cover the initial cleanup and redevelopment along with the ongoing
                   operations costs.   Public or non-profit grant funds may be  required  for  these
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                   projects only for the initiation of the process, and for the development of marketing
                   approaches and incentives to attract potential investors or  developers.  Once the
                   private  developer becomes  involved,  there  is little  further requirement for the
                   infusion of public funds, except for those required to maintain any initial incentives
                   provided as an inducement for private involvement.

                   At the other end of the  continuum are those projects that are developed by the
                   community itself, such as  parks, greenspace development or the redevelopment of a
                   site to provide a needed public facility (e.g. community center, recreational facility,
                   museum, theatre, etc.). In these cases, the public investment will require that sources
                   of income be provided to  support the project during the redevelopment process and
                   throughout the project life cycle.

                   Such projects normally can be expected to benefit the community and to generate
                   revenue in the form of  additional taxes  from increases  in surrounding property
                   values, or from small private businesses that are created around the public facility, as
                   well as user/admission fees paid by the facility itself.  However, these increases in
                   revenue are usually not sufficient to offset all  of the costs  of redevelopment and
                   operation. As a result, publicly supported projects are usually only sustainable to the
                   extent that the local municipal budget will continue to support them.

                   The location and specific nature of a Brownfields project site can significantly affect
                   the financing considerations associated with site characterization.  As noted earlier in
                   this study, a number of sites will have sufficient positive features and the level of risk
                   will be  sufficiently calculable that they will  very  likely be  candidates  for private
                   investment and cleanup.   Here the anticipated rate of return will  be  sufficient to
                   cover the necessary cleanup costs.  These sites will be relatively easy to finance and
                   will probably not require much, if any, additional influx of capital during the life of
                   the project to maintain sustainability.
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                  However, other sites will not be so attractive and will not have the benefit of being
                  economically viable in the absence of outside funding. Limiting features may include
                  such factors as concern for the safety of potential employees, customers or residents
                  of the proposed new  project, depressed  economic  conditions in the surrounding
                  communities, the potential for long-term devaluation rather than appreciation of the
                  property, or limited access to markets, transportation or other features.  In addition
                  to public funding as an inducement to development, additional  subsidies  (e.g. tax
                  abatements, infrastructure improvements, or outright grants) may be necessary for
                  several years following the initial start-up of the development.

                  A third factor affecting the mix of public and private funds required for the project is
                  the  capabilities of the potential  owner or development entity itself.  For private
                  developments, the larger and  more solvent the potential  site developer or investor,
                  the  more likely they will be able  to  absorb the level  of risk  associated with a
                  development.  The importance  of public funding  as an  incentive  to  encourage
                  involvement or as  a hedge against potential risk will be correspondingly diminished.

                  These three primary considerations, site characteristics, future uses,  and developer
                  capabilities describe a range of sites that for a variety of reasons  will require some
                  combination  of public and  private  funds  in order  to  achieve   a  sustainable
                  development. The important  aspect from the perspective of project sustainability is
                  the maintenance of a continuous source of income, whether from public or private
                  sources, or some combination  of both,  throughout the life of the project.   In
                  addition to a focus on  the long-term funding of the project, there is a consideration
                  for  the immediate start-up  as well.  Most projects will not  be  immediately self-
                  financing and will require, at least in the initial stages, some form of public finance.
4.1.9.1        FUNDING CONSIDERATIONS

                  The financial stability  of a  Brownfields redevelopment project is important to  its
                  long-term future sustainability.  As noted, one key element of  this  process is  to
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                  identify funding requirements as early in the redevelopment process as possible and
                  to elicit a commitment of funds from identified sources.  Project funding takes time
                  to  develop and requires  as  much lead-time as possible.  Critical  funding gaps
                  represent a primary deterrent to the redevelopment process, while carefully targeted
                  financial  assistance can  help advance  cleanup  and  reuse activities  and "achieve
                  significant economic, social, and aesthetic benefits" (Bartsch, 1996).

                  A structured financial package in the initial stages  of project development provides a
                  long-term basis for planning the project and assures that each phase of the project
                  will not be delayed by shortfalls  in resources.   It also makes it easier to  attract
                  additional funding or investment (especially from  private  firms) by demonstrating to
                  potential investors that a firm financial basis already exists. A well-organized project
                  funding structure  also provides the  basis for project evaluation as redevelopment
                  progresses. In this sense, it becomes  a convenient checklist against which to evaluate
                  project schedule and completion  goals. Early detection of possible  overruns  and
                  delays is also facilitated.

                  Brownfields redevelopment is more than a single process; it is composed of multiple
                  elements, each of which must be funded, either separately or collectively in order for
                  the program to succeed.  Some of the more important project funding requirements
                  include: site based remediation, site preparation,  construction of new facilities, and
                  other soft costs such as permitting, publications, etc. (Skowron, 1998).

                  Costs  for infrastructure development and improvements are  another consideration
                  for Brownfields redevelopment. As noted during the project interviews, it is often
                  difficult to find subsidies to address the potentially  inadequate  or  antiquated
                  infrastructure of urban areas.  But,  local governments in  the  suburban fringe are
                  more willing to accept extensive subsidies for infrastructure improvements as part of
                  the incentives built into the total development package.
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                  Often overlooked, however, are such other important areas as the operational needs
                  of the Brownfields management organization  itself.   As one  project participant
                  noted, once a Brownfields coordinator is hired, the salary and administrative costs
                  for two years  can  take about one-half of the total EPA Brownfields grant.  Other
                  considerations include the resources required for the planning, public outreach, job
                  training,  community partnerships and site marketing processes.  One  of the most
                  frequently overlooked expenses is the cost of acquiring financing itself. Grant and
                  other proposals,  although often prepared with volunteer labor can represent a
                  significant expense, especially to a small project.

                  Essentially, the Brownfields redevelopment process can be characterized  as  five
                  separate processes, each of which requiring some form of funding:

                  •   the Brownfields program and program related expenses;
                  •   site characterization and remediation;
                  •   planning, public outreach and design approval;
                  •   development and reconstruction; and
                  •   long term operational support.

                  The long-term survival of the redevelopment  effort and therefore its  long-term
                  sustainability are contingent on the ability of the  project to adequately fund the
                  resource requirements operative at each of these stages of development.
4.1.9.2        SOURCES OF FUNDS
                  For most of the projects considered in this study, and indeed for the greater majority
                  of Brownfields redevelopment projects, the initial project funding will come from
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                  public sources.   These  sources  provide the necessary  resources to  initiate and
                  accelerate the  redevelopment  process.   However,  a sustainable project cannot
                  depend solely on external resources.

                  Important to the long-term success of the project is  the process of defining where
                  the project is going, in terms of its long-range goals and then identifying funding that
                  supports what the community has decided to do.  One cautionary note provided by
                  a respondent during the site interviews was that it is too easy to let the availability of
                  grants set the priorities and direction of the project, causing the project to lose site of
                  its original goals.

                  Another important consideration is that project planners, the  community at large,
                  and especially, the affected neighborhoods should understand the project in terms of
                  its financial  requirements, and should also understand the business perspectives of
                  the key participants, lender, developer, current and previous owner, etc.  In addition
                  to community awareness and  participation, other preliminary  activities associated
                  with the process of securing financing for a project include:

                  •   a comprehensive needs  assessment or marketing study for the community and
                      especially the neighborhoods immediately surrounding the site;
                  •   prioritization and ranking of relevant community issues;
                  •   identification of relevant environmental regulations and compliance issues;
                  •   development of a design and plan for the construction of any capital facilities;
                  •   the identification of revenue sources.

                  Identification of the sources of public funds will  include a mixture of Federal, state,
                  and municipal mechanisms including grants, tax  incentives, or  loan funds.  Federal
                  programs that are amenable to Brownfields funding requirements  are sponsored by
                  agencies such as EPA, HUD, DOT, DOC, and SBA among others. State funding
                  may be available through environmental or economic development agencies, as well
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                  as certain tax programs and revolving loan funds, depending on the individual state.
                  Local initiatives may also include grant or other incentive programs, in addition to
                  tax increment financing programs which are attracting increasing attention (Bartsch,
                  1998).

                  Of particular interest for Brownfields type redevelopment projects are the use of tax
                  increment financing (based on the assumption that redevelopment of a property will
                  increase its future value and that this new value can  be  used to raise public sector
                  revenue to finance the project) and revolving loan funds  (the initial capitalization of
                  the fund is cyclically reimbursed through the payback of  principal and interest from
                  loans made by the  fund).   These initiatives  offer  the possibility  for long term
                  continuity  of funding for multiple  individual projects while at  the  same time
                  potentially increasing the total level of funding available.

                  In both cases, there is an emphasis on continued sustainability through reinvestment
                  of the  proceeds of redevelopment back into the community.  With tax increment
                  financing, the reinvestment is made by earmarking future tax revenue increases for
                  the repayment of bonds floated  by the municipal or  state government to fund the
                  immediate  needs  of the project. Essentially,  sustainability here is  maintained by
                  borrowing from future revenues.  For revolving loan funds, the proceeds of the loan,
                  or literally the return  on the community's investment,  are returned to the fund to be
                  recycled as a new loan for continued redevelopment; effectively using the revenue
                  generated by one project as the seed capital for another.

                  One of the more important strategies  for identifying public sources  of funding
                  articulated during the project interviews was that of fractionating or separating the
                  project into key or component  parts.   As noted  earlier a Brownfields project is
                  complex and composed of multiple elements (i.e. land use planning, environmental
                  remediation,  real  estate development,  community  economic  development,  job
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                  training and creation, etc.).  Each of these elements represents both a community of
                  interest within the larger community; and a source of targeted public funds.

                  By fractionating the  project, individual sources of public funds can be identified to
                  finance the cost of a small portion of a much larger project.  This strategy has been
                  used successfully by a number of communities to assemble a package of multiple
                  Federal,  state, and non-profit grant  and funding sources  directed toward specific
                  aspects of the  overall  program, but which together form a piecemeal funding
                  structure that finances the total project.  One good example of this approach is
                  evident in the Cape Charles  project where a combination of Business Enterprise,
                  DOT,  NOAA, and  other grants have been used to augment  parts of the total
                  community redevelopment plan.

                  The mix of funding  sources for the Brownfields redevelopment effort also includes
                  identification of private sources of investment.  A generic listing of some of these
                  sources includes:

                  •   property owners or other responsible parties who  may  provide  funds  for
                      cleanup  as part of a settlement either before, in lieu of, or after the transfer of
                      the property for redevelopment;
                  •   prospective purchasers or developers who may include the costs of cleanup and
                      site restoration as a part of the proposed cost of any new development;
                  •   equity investors, whether individuals,  partners,  mutual  funds, or real  estate
                      investment trusts, who may find themselves in a cash rich position and  are
                      looking for new sources of investment;
                  •   commercial  banks who may provide sources of funding as a part of a business
                      development loan or mortgage; and
                  •   private foundations and universities, especially those interested in some aspect of
                      the project such as environmental restoration, low-income housing or those with
                      a larger community orientation.
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                  A representative of the real estate banking industry in New Orleans provided some
                  insights into  the  perspective  of commercial  banks with  respect  to financing
                  Brownfields  site redevelopment.   There is a need for project  participants  to
                  understand the process that the bank has to go through to get a loan paid (e.g. how
                  to identify risks, review loan underwriting criteria,  loan processing, and repayment).
                  Repayment of the loan is the major issue for the bank.  There must be a sound basis
                  for repayment - sufficient cash flow and some long-term equity component. The
                  main focus is on collateral value or the ability of the bank to foreclose. The bank will
                  also look at the included grants and loan guarantees.

                  Because each site  has many different potential uses and associated strategies for
                  redevelopment, it is also important to address the viability of investment in all of the
                  possible redevelopment strategies before the investment is made. Banks have learned
                  that it is not just the  property, it is also the surrounding land area that makes the
                  difference in a loan. In this sense, the project becomes a community investment.

                  The level  of contamination  is  also of  concern and  has   scared off investors
                  haphazardly in the past.  In order to meet the requirements  for a loan, the project
                  will normally be expected to provide for:

                  •   full cleanup  to expected land use requirements;
                  •   Phase I and Phase II assessments on a limited use project; and
                  •   assurance of the adequacy and competency of the cleanup.

                  Limited cleanup to risk-based re-use development levels is possible, but poses an
                  additional capital expense and line items — risk varies on case-by-case basis.

                  Of particular concern to the  private  investment community  are the economic
                  viability of the asset and the degree of liability associated with the investment (See
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                  Section  4.1.6).   But,  the  single  most important  characteristic of a  Brownfields
                  redevelopment that will stimulate private investment is demand for the site (Henry
                  and Muller, 1996).  Banks and other investment institutions will be reluctant to place
                  money in a property that is not in demand. In order to secure private financing for
                  the ongoing redevelopment of a property, it is essential that the property be carefully
                  evaluated for its potential marketability, or in essence, the extent to which someone
                  wants it.

                  Project funding is a critical component associated with the potential sustainability of
                  a Brownfields redevelopment project.  Based on the prevailing site characteristics
                  and the anticipated future uses of a proposed site, a mixture  of private and public
                  funds will be required for development.  On the basis of the  funding sources
                  identified,  Brownfields projects can be categorized into three types, those funded
                  primarily by private organizations, those funded by public entities, and those that are
                  a mixture  of public and private  funds.  Important characteristics associated with
                  sustainability are  the early  and accurate identification of financing requirements, a
                  high level of community awareness and knowledge of the financing process and the
                  careful preparation and analysis of the project characteristics as a part of the overall
                  strategy to attract outside investment.
4.1.10 EnvifoomeatalJustifE
                  In recent years, concern has been  raised that persons from low-income and
                  minority communities are suffering a disproportionate burden of adverse health
                  consequences from the  siting of industrial plants  and waste dumps at nearby
                  locations, and from exposures to pesticides and other toxic chemicals within
                  their home and occupational environments.  There  is also concern  that the
                  environmental  programs  and  policies  being  established  by  governmental
                  agencies were not adequately addressing these  disproportionate exposures. The
                  President's Executive Order 12898 (EO)  entitled " Federal Actions to Address
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                 Environmental Justice in Minority Populations and Low-Income Populations"
                 issued February, 11 1994 directs Federal agency officials to examine how agency
                 activities and policies affect the nation's minority and low-income populations.
                 As a result of this EO, the term "environmental justice" was formalized.

                 EPA defines environmental justice as the "fair treatment for people of all  races,
                 cultures, and  incomes,  regarding  the  development of  environmental  laws,
                 regulations, and  policies"  (Environmental  Justice  Homepage,  1997).    A
                 subcommittee  of  the  National  Environmental  Justice Advisory  Council
                 (NEJAC),  a  Federal  advisory committee  to EPA,  states   "The  vision  of
                 environmental justice is the development of a holistic, bottom-up, community-
                 based multi-issue, cross-cutting, integrative, and unifying paradigm for achieving
                 healthy and sustainable  communities — both urban and rural" (NEJAC, 1996).
                 Thus environmental justice can be seen as a far ranging attempt to ensure the
                 equal distribution  of costs and benefits  of  Federal government policies and
                 actions that have environmental ramifications.

                 EPA's Action Agenda (USEPA 1995 (a)),  incorporates environmental justice as
                 an integral component of the  Brownfields  initiative.    As it relates  to  a
                 community redevelopment activity, the application of "environmental justice" is
                 called for where there is concern of an environmental inequity.  The tendency
                 for Brownfields properties to be concentrated in communities inhabited by
                 minority   and  low-income  populations  indicates  that  a   concern   for
                 environmental inequity is a major consideration for the Brownfields process. By
                 removing  the  contamination  and  conducting redevelopment  efforts at  the
                 project site, the result is an overall environmental and social improvement.  In
                 this way, the implementation  of a Brownfields redevelopment project can be
                 seen  as a  remedy  to address  issues  of environmental inequity, and  thereby
                 promote environmental justice.
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                  It is difficult to discuss Brownfields redevelopment efforts without incorporating
                  environmental justice considerations.  As stated by the National Environmental
                  Justice Advisory Council:

                     "Environmental justice and Brownfields are inextricably linked: the
                     inescapable  context for  discussion of  the   Brownfields  issue  is
                     environmental  justice and urban revitalization.   At the core of a
                     justice perspective is recognition of the  interconnectedness of the
                     physical environment to the overall economic, social, human, and
                     cultural/spiritual  health  of   a  community.    The  vision  of
                     environmental justice is the development  of a paradigm to achieve
                     socially equitable,  environmental health,  and  economically secure,
                     psychologically vital, spiritually whole, and ecologically sustainable
                     communities.   To  this end, Brownfields  redevelopment  must be
                     linked to helping address  this  broader set of community needs and
                     goals" (NEJAC, 1996).

                  The major characteristic of environmental justice as it relates to sustainable
                  Brownfields redevelopment is:  the requirement for community participation/
                  involvement in the decision-making process.  To  the extent that  there  is
                  community involvement, a corresponding measure of environmental justice can
                  be anticipated. The key factors associated with community participation related
                  to  Brownfields redevelopment programs/projects  (NEJAC,  1996;  USEPA
                  OSWER Action Agenda) can be summarized as:

                  •   early, adequate and  meaningful community involvement  in the  decision-
                     making process;
                  •   a group of stakeholders committed to effecting a change for the better;
                  •   all parties having equal access  to all information relating  to the  proposed
                     redevelopment;
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                  •  honesty and integrity for all participants for dealings between stakeholders;
                  •  willingness to negotiate in order  to achieve the necessary balance for the
                     final  decisions so that ideally  all  participants see the results as a win-win
                     situation.

                  The end result would be a situation where there is an equitable distribution of
                  the costs and benefits of the chosen redevelopment plan, and no group would
                  suffer   from   disproportionate   adverse   health   effects   associated   with
                  environmental agency policies  or activities within the environment.

                  A related issue, that of gentrification, can also be important to the sustainability
                  of the  Brownfields  redevelopment program/project.   Gentrification is the in-
                  migration of middle-or-higher-income residents  into a deteriorating or recently
                  renewed neighborhood in association with  local redevelopment.   Often the
                  incoming residents will also have ethnic or racial differences. This can present a
                  number of advantages  to  community growth. However, if the  situation is not
                  handled effectively,  it could create tension between the groups and destabilize
                  the balance within  the community.   The  sustainable  approach  requires  a
                  combination of total community participation and consensus building. The total
                  community includes both the new incoming members,  and  the  population
                  originally present.   Collaboration  should be  done in accordance with the key
                  community participation factors described previously.

                  Environmental  justice   contributes  to the  sustainability  of  a  Brownfields
                  redevelopment project in a way that is somewhat unique when compared to that of
                  the other elements.   Brownfields tend to  be located  in close proximity to the
                  neighborhoods of low-income  and  minority populations.  When  a redevelopment
                  project is implemented in such a community, there will naturally be degrees of
                  community and quality of life  improvement experienced by the  nearby  residents.
                  For this reason, project officials may conclude  that environmental justice concerns
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                  are automatically addressed as a part of project implementation. In some cases this
                  may be true. However, it is important that empowered community participation (a
                  key factor in assuring that environmental justice is achieved) be included as a part of
                  the  redevelopment  implementation  process. In  the  absence  of  this type  of
                  involvement, environmental justice issues  may not be  addressed in a meaningful
                  manner, and ultimate sustainability of the project may be threatened.
                  Because the Brownfields redevelopment process is a relatively new approach and
                  the Brownfields  Pilot Projects have for the most  part  not fully  matured,
                  information on project organization, activity, and  accomplishments is somewhat
                  inconsistent and  limited to assessments  of near-term success as  opposed  to
                  sustainability over time.  In fact, no Brownfields redevelopment project available
                  for this study was  ongoing for more than 5-10 years.   As a result,  it is not
                  possible to develop the quantity and level of data necessary to fully verify the
                  elements and characteristics  of sustainability,  or to  establish definitively  a
                  statistical correlation between these factors and the long-term sustainability of a
                  Brownfields project.

                  The absence  of consistent and systematically derived quantitative  information
                  does not, however, completely preclude all forms of verification that might be
                  available to a study such as this. Although determination of a direct correlation
                  between the  PECs identified  and  the long-term sustainability of Brownfields
                  projects is  not possible, verification of the potential for association  between
                  these two factors  is  conceivable.

                  The potential for association can be established by a qualitative analysis of the
                  characteristics of these elements and the link between these characteristics and
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                  the component factors associated with the  concept of  sustainability.  This
                  potential is  then confirmed  by comparing these  elements and  characteristics
                  against  the  experience of  real  projects;  in  this  case, through  information
                  developed from interviews with municipal government sources. This technique
                  does  not provide  a  definitive  basis  for the assertion  that  elements  and
                  characteristics  are correlated with project sustainability, but it does provide  the
                  structural framework necessary to develop  a model of  those  elements  and
                  characteristics  that can be  associated with the sustainability of  a  Brownfields
                  project.

                  On the basis of the  literature review, analysis  of the fifteen Pilot Projects, and
                  preliminary  interviews  conducted  with  EPA, other  Federal  agencies,  and
                  Brownfields project  site personnel, ten  major elements  have been defined in
                  Section 4.1  and associated with the potential for sustainability.  The relevant
                  social, ecological and economic characteristics associated with sustainability have
                  also been described for each of these elements  in the previous section.

                  In order to establish a basis against which to verify the  association between
                  these elements and the potential  sustainability of a Brownfields redevelopment
                  project, these  analytical results  were compared against the  actual  experience of
                  individual municipal  governments.  Within the limitations  of the scope of this
                  study, this verification phase was initially confined to eight municipalities.

                  Interviews were conducted  with  officials of  the municipal governments who
                  were either  directly connected  with the coordination  and  management of  the
                  city's Brownfields  program, or who exercised executive responsibility for  the
                  parent agency  of a Brownfields  program. The telephone interview sessions were
                  structured according to the ten  elements defined in Section  4.1. For each of the
                  elements, the primary focus was to determine the extent to which  the element
                  was incorporated  as a  part of the  respondent's  approach  to  Brownfields
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                  redevelopment. Also, the respondent's view of the relative importance of each
                  element to the success or failure of the project was  determined,  as was the
                  influence each element had on overall project sustainability.

                  Although historical data to support this study  is severely limited in terms of the
                  availability of completed sustainable projects,  a few Brownfields Pilot Projects
                  are currently  reaching the point at which meaningful data can be derived.  As a
                  follow-on to  this  study,  the  next logical  step would  be to conduct  a more
                  detailed, systematic analysis of the Brownfields Pilots.  This would be based  on
                  additional primary  data  sources  acquired  for a randomly selected  sample  of
                  completed projects or projects that have reached the  stage where a successful
                  transition  has been made  from  site  assessment  and  clean-up  to  actual
                  redevelopment of the facility or property.  This analysis would serve to further
                  support the  model that is being developed  during the  second phase of this
                  study.

                  For purposes of this study, the  interviews with municipal officials  have  been
                  conducted to accomplish two objectives.  The first objective is to verify the
                  existence of  each  of the  elements and to determine their relative  importance
                  when associated with sustainability and successful Brownfields  redevelopment.
                  The second objective is to update and confirm data obtained from the detailed
                  analysis of the fifteen Pilot Projects.  This has been accomplished by inquiring of
                  the respective respondent's information about the status or results of specific
                  characteristics, processes, or examples identified  in the Pilot Project database
                  records.

                  Since four  of the  fifteen Pilot Projects are  the subjects  of on-site visits and
                  personal  interviews,  the  municipalities  selected  for  the verification  process
                  consist of eight of the remaining fifteen, which are:
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                  Bridgeport, CT; Buffalo, NY; Burlington, VT; Charlotte, NC; Cleveland, OH;
                  Greenfield, MA; Oregon Mills Conversion, OR; and the West Central Municipal
                  Conference in Cook County, IL.
       THE RESULTS OF THE MUNICIPAL VERIFICATION ARE SUMMARIZED BELOW:
Element
Community Profile
Percent Agreement Among the 8 Municipalities
50%   confirmed  this   element's   importance  to
sustainability  and  critical  role  in achieving project
success; the remaining 50%  felt it was important for
sustainability but not critical for success.
Comprehensive Planning
63%  confirmed  the  element  is  important  to
sustainability and critical  to  success; the remaining
37% ranked it important but not critical to success.
Organizational Focus
88%  confirmed  the  element  is  important  to
sustainability and critical  to  success; the remaining
12% ranked it important but not critical to success.
Site ID & Characterization
75%  confirmed  the  element  is  important  to
sustainability and critical to success; 12.5% ranked it
important but  not critical to  success; and,  12.5%
ranked  it not  important or not relevant  to their
project.
Risk Management & Cleanup
63%  confirmed  the  element  is  important  to
sustainability and critical  to  success; the remaining
37% ranked it important but not critical to success.
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Legal/Regulatory Issues
63%   confirmed  the   element  is   important  to
sustainability and  critical to success; 25%  ranked it
important  but  not  critical  to  success;  and  the
remaining 12% did not rank it.
Site Marketing and Reuse
50%   confirmed  the   element  is   important  to
sustainability and  critical to success; 37%  ranked it
important but not critical; the remaining 13% ranked
it appropriate for sustainability but  not relevant to
their project(s).
Project Financing
100%  confirmed  the  element   is  important  to
sustainability and critical to success.
Technology Applications
37%   confirmed  the   element  is   important  to
sustainability and  critical to success; 37%  ranked it
important to sustainability but not critical to success;
and 26% ranked it appropriate to sustainability but
not relevant to their project.
Environmental Justice
37%   confirmed  the   element  is   important  to
sustainability and  critical to success; the remaining
63%  ranked it  important to  sustainability  but not
critical to success.
                  Overall, with one exception, the eight respondents confirmed that all ten of the
                  elements are important  to  the sustainability of a  Brownfields redevelopment
                  program or project.  However, their presence and role in promoting the success of a
                  program or project varies on a  case-by-case basis. The single exception indicated
                  that the Site Identification, Characterization and Prioritization element was neither
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                 appropriate nor relevant to the Brownfields redevelopment process.  This ranking
                 was predicated on the respondents opinion that any such process would result in the
                 creation of a formal list of sites that, because of their association with Brownfields,
                 would automatically carry the stigma of contamination and therefore, would be
                 avoided by developers and prospective buyers.

                 The respondents also provided descriptions and explanations of many of their
                 processes, which verified many of the characteristics identified and defined in
                 Section 4.1.  The following table summarizes a number of key characteristics,
                 according to  their respective elements,  that municipalities  noted  during  the
                 survey.  In some  cases,  these  characteristics  directly  verify  those discussed
                 previously in Section 4.1.  Others are indirect verification or present additional
                 variations on previously described themes.
         I1 able 4.4:  SUMMARY OF CHARACTERISTICS VERIFIED BY
                                  MUNICIPALITIES
    Community Profiling
    •   Primary focus is on community/neighborhood needs
    •   Community vision is more critical than historical information
    •   Economic indicators applicable to the community need to be addressed
    •   Market analysis is  a key component
    •   Ecological baseline data not as relevant to urban/suburban communities as it is to rural
    Comprehensive Community Planning
    •   Brownfields need to be integral components of comprehensive plans
    b*   The variety of plans need to be integrated so their components support each other and
       make sense for the community
    L*   Existing community/neighborhood groups and networks should be used to feed into the
       planning processes
    •   A mechanism or strategy for continual or periodic updating should be included
                                            202

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    Organizational Focus and Structure

    •   Central organization should be at the local municipal government level

    •   Brownfields are addressed by the local economic development and planning departments
       with environmental functions
    •   Single   point-of-contact  is  needed  to  generate  working  relationship  and  mutual
       understanding and trust with development/financing communities
    •   All business  loans,  grants,  municipal  funding,  and  financial  partnerships  should  be
       coordinated through the same point-of-contact
    •   Technical, legal and financial  expertise should be integrated into local organization to retain
       responsibility, credibility and ownership of decisions and outcomes
    •   Technical support teams, task forces and committees are viable and important resources

    •   Close collaboration with State and Federal regulatory officials is critical to timely and flexible
       interpretation of project requirements
    •   Academic institution resources  are cost effective, able to provide  unique technical support,
       and provide on-the-job  training opportunities to students

    Site Identification, Characterization & Prioritization

    •   Identification and listing of sites as "Brownfields" could be detrimental

    •   Sites that have existing end-users or potential developers should be prime focus

    •   Reuse potential should be a prime focus as opposed to contamination problems

    r*   Regional prioritization  of sites not  feasible  where  crossing  of political jurisdictions  is
       involved — unless respective jurisdictions participate and support the process
    L*   Legislative incentives  to entice private property owners to participate — especially non-local
       owners are needed
    •   All project information should be centrally available for quick and reliable access



    Risk Management and Remediation

    •   State legislation that deals with clean-up levels and release from liability is critical

    •   Deed restrictions and environmental covenants are effective institutional controls  at local
       level
    •   Community involvement should be managed so the community does not use the vector of
       potential health risk  to force  greater demands  on  owner/potential  developer than are
       economically feasible
    •   Extended timeframes for Brownfields redevelopment pose greater financial risk to rural
       communities dependant on short-term grants or limited funding capabilities
                                             203

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 CHAPTER  4
 ANALYTICAL  RESULTS
        Caution is used to avoid increasing community optimism that the project will create jobs —
        especially when fewer jobs, different skill level jobs, or long delays in the project may occur
        Environmental liability insurance is an increasingly feasible tool to manage risk
•I

Legal/Regulatory Issues

   Mechanisms for municipal liability release are needed especially for municipalities forced to
   assume ownership due to foreclosure, abandonment, or eminent domain
   Less stringent liability and more flexibility is needed for Brownfields which are generally a
   less serious health threat than Superfund sites

Site Redevelopment and Marketing

•  Development or redevelopment follows certainty in the economic marketplace

•  Market demands can pose greater barriers than availability of project funding

•  Organized marketing programs in rural communities are not sustainable without long-term
   grants
•  Brownfields properties should not be marketed or advertised as "Brownfields"

•  The quality  of the community profile is important in giving prospective developers a sense
   of certainty
•  Market studies or focused feasibility analyses are valuable steps in the process

•  Building  on historical  and  natural  resources  develops  permanence  and continuity  of
   development among generations
•  Greenspace or open space is an effective reuse alternative along riparian corridors

•  Multi-use commercial and  industrial  developments are preferred over large, single  use
   facilities due to their adaptability


•  Community needs to identify and trust proprietary remediation technologies

•  GIS technology extremely valuable as  central repository for all relevant project information

E*  Transportation infrastructure needs  to be  tailored to meet  changing land uses and  to
   provide better public amenities

Funding/Financing

•  Best to integrate assessment and clean-up costs into overall redevelopment financing plan

•  Lack of certainty in cost of remediation important barrier or risk

•  Lending community's knowledge and  participation is needed to help make deals happen
                                             204

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CHAPTER  4
ANALYTICAL  RESULTS
    •  Cost/benefit models are very complicated and only useful if they are designed for site-
       specific conditions or situations
    •  Ultimately, private financing based on market driven economy will sustain process
    •  Resale value of the property after clean-up is generally less in rural areas  than the cost of
       clean-up and regional market values
    •  Rural communities  need financial assistance with infrastructure installation  in  order to
       promote redevelopment of sites
    Environmental Justice
    •  The biggest problem is lack of understanding about what environmental justice means
    L*  Best way to address  environmental justice is to include local  residents in the  community
       planning process
    •  The emphasis should be on addressing the community's overall needs

                  In addition to the  above characteristics related to specific elements of sustainable
                  Brownfields  redevelopment, the following general  considerations were recorded
                  during the verification interviews:

                  •   The specific manner in which activities are performed in each elemental
                      process should pave the way for the next element.

                  •   Community knowledge of the overall development process is needed to
                      ensure sustainable development.

                  •   One key is to build on those resources that have lasting value.

                  •   At times, the  use of professional  mediators and formal charrettes can be
                      very effective  in establishing clear communications and building credibility
                      and trust among stakeholders.

                  The  data  collected  through  the  survey  of  the  eight  municipalities  and
                  summarized above provides verification that the elements and  characteristics of
                  sustainable Brownfields  redevelopment presented in Section 4.1  are  indeed
                                             205

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CHAPTER  4
ANALYTICAL  RESULTS
                  reliable and replicable. Also, because each characteristic can be associated with
                  one, or  a  combination of the  three parameters of sustainable  development —
                  economic, ecological, and social sustainability, it can be concluded that they are
                  accurate and replicable as well.
                                              206

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ANALYTICAL
                RESULTS
                                         207

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CHAPTER  5
CONCLUSION
                                        One significant aspect of a Brownfields project is its apparent
                                        (but   illusory)   simplicity.      Initially,   a   Brownfields
                                        redevelopment project appears as a straightforward process
                  of reclaiming an abandoned  or underutilized property, through the elimination or
                  control of potential contaminants, and putting  the land to some  new use for the
                  benefit of the  community.   But,  the moment that this process  is begun, the
                  Brownfields redevelopment effort becomes connected to an extensive and complex
                  web of ecological, economic and social  systems, all of which influence not only what
                  can be done with a specific property, but also how sustainable the outcome will be.

                  The complexity of a Brownfields redevelopment project is evident in the number of
                  different ways in which the Brownfields process itself has been characterized, both in
                  the literature  and by the project participants and government officials who were
                  interviewed for this study. Apart from  the problems associated with contamination,
                  the Brownfields  redevelopment process  has  been  described  as a  real estate
                  transaction, a land use issue, a planning issue, a  community development issue, and
                  an economic development issue, among others.  From the information collected
                  during this first phase of the study, it is evident that a Brownfields redevelopment
                  effort is probably all of these at once, and no one of these in particular.

                  In addition   to  addressing  concerns   for  environmental remediation  and the
                  restoration  of  a  contaminated  property to  productive use,  a  Brownfields
                  redevelopment  project  is also an  integral part of the economic  and social
                  revitalization of the larger community.  Recognition of the historic antecedents that
                  have lead to the present underutilization and abandonment of potentially valuable
                  properties has  led  communities  to  look  beyond conventional  development
                                             208

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CHAPTER  5
CONCLUSION
                  approaches  in  favor  of a broader perspective that recognizes  the  integration of
                  economic, social and ecological factors - or a sustainable approach.

                  Sustainability, both  of  the  redevelopment  project itself and  in  terms  of its
                  contribution to the larger community, then becomes an important component of
                  the  complex Brownfields  process.  The  integration of  sustainability  with the
                  Brownfields  redevelopment process  represents a true paradigm  shift to the extent
                  that it  reflects changes in the manner  in  which  development is planned, the
                  organization of the social mechanisms that control and implement planning, and the
                  role of the community in that planning process.

                  Correspondingly, the process of redevelopment itself requires new mechanisms and
                  structures for linking issues, goals,  interests, and organizations  into a combined
                  redevelopment effort.  The challenge is to connect the concept  of sustainability to
                  activities at  the project level in a  manner that does  not impede the process, but
                  facilitates  the integration  of social, economic,  and  ecological  parameters in a
                  structured approach that balances the requirements of each.

                  In addition to a successful outcome, a sustainable Brownfields project also includes
                  two primary dimensions.   The  first is  a concern for  potential  environmental
                  degradation and the maintenance of a harmonious relationship between the project
                  and the rest of the natural environment.  The second is related to  the social and
                  economic well being of the community as it relates to the perceived benefits of the
                  project.

                  In both cases, the domain objective is to maintain the project over the long-term so
                  that it meets the needs of the community without jeopardizing the future goals and
                  vision of the community.    Through the course of this analysis  some general
                  premises related to the sustainability of a Brownfields project have been developed.
                                              209

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CHAPTER  5
CONCLUSION
                      Sustainability is a normative concept - it is not based on a set of fixed objective
                      criteria that are inherent to the development process, but will reflect the attitudes
                      and perceptions of the community as a whole.

                      Sustainability refers not so  much to the project outcome, but to the manner in
                      which the community responds to its economic and social needs, as well as its
                      ecological issues.

                      Sustainability is  often not clearly  understood, either as a guiding principle for
                      development or as a final goal; it depends on community outreach, education,
                      and collaboration for its success.

                      Achieving Sustainability will require emphasis on new structures and approaches,
                      including changes in the way communities are planned, in order to  balance the
                      requirements of the three core parameters.

                      Sustainability is context dependent and very much a grass roots process - what is
                      sustainable in one community may not be so in another.

                      Brownfields  sites were not abandoned  or underutilized because  they  are
                      Brownfields sites; they will not be redeveloped solely because the environmental
                      contamination has been addressed.

                      Sustainable Brownfields  redevelopment  is  not  solely  an  environmental
                      consideration, but is also a function of risk and cost.

                      Uncertainty is a key impediment to the development of a Brownfields property -
                      - the risk can be accommodated if the uncertainty can be defined or mitigated.
                                             210

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CHAPTER  5
CONCLUSION
                   *»*  The important ecological factor impeding the redevelopment of a Brownfields
                      property is not the presence or absence of contamination, but the perception of
                      contamination.

                   *»*  The Brownfields process is  as much a response to the community's economic
                      and social needs as it is an environmental program.

                   Within the parameters defined by the ecological, economic, and social systems, a
                   number of specific key elements that can be associated with the sustainability of the
                   Brownfields  redevelopment process have been identified.    These elements  are
                   generic in the sense that they have demonstrated applicability in multiple contexts.
                   Table  5.1 summarizes the elements that have been identified through the course of
                   study.

                   For each of the identified elements that have been associated with sustainability, a set
                   of basic characteristics have also been developed.   These characteristics represent
                   specific criteria or processes that are accessible to the participants in a Brownfields
                   redevelopment and can be manipulated at the project level to influence the degree to
                   which  the project is  itself sustainable  or  contributes  to the overall  sustainable
                   development of the community.  A summary of the elements and their associated
                   characteristics is presented in Table 5.2.
                                              211

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 CHAPTER  5
 CONCLUSION
 Table 5.1: Key Elements Associated with Sustainable Brownfields Redevelopment
^^^^^^^^^^^^^^^^^^^^^^^^^^H ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^H
 Elements                 Effect on Sustainable Brownfields Redevelopnient
 Community Profiling
                           Sets the foundation for all community decisions and
                           future growth
 Comprehensive
 Community Planning
                           Involves, integrates, and commits community
                           participants and stakeholders to common vision and
                           goals
 Organizational Focus and   Integrates the program into the political and
 Structure                  administrative government

 Site Identification and
 Characterization
^
 Risk Management and
 Restoration

 Legal/Regulatory Issues
                                                 I
Reduces the risks that influence remediation, financing,
marketing, redevelopment, and regulatory strategies
                                                                            *
 Site Marketing and
 Redevelopment

 Technology Applications
Addresses the fears and misconceptions associated with
redevelopment by clarifying uncertainties  and balancing
benefits with costs
Prescribes requirements for property transfer and
utilization, as well as liability of owners, operators,
lenders, buyers, and the municipal government
Highlights the importance of balancing economic, social
and ecological factors of land use with  focus on
community needs and future generations
Increases cost benefits and quality of life as new
technologies are identified, developed and integrated
                                                                             I

 Project Funding and
 Finance

 Environmental Justice
                           Provides the fiscal basis to initiate programs/projects and
                           ensure their continued operation until market forces take
                           over
                           Ensures environmental equity, equitable costs and
                           equitable benefits for the community and stakeholders
                                             *
                                             )lders
                                       212

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CHAPTER
C O N C L U S
5
O N
Table 5.2: Characteristics Associated with Elements of Sustainable Brownfields Redevelopment
Elements
Community Profiling
Comprehensive Community
 Planning
Organizational Focus
and Structure
Site Identification
and Characterization
                   Characteristics
                        Develop environmental baseline inventory for future ecosystem management
                        Estimate natural resource consumption limits
                        Incorporate important landscape and attractive community features
                        Associate ecological assets with community values
                        Define the composition and character of the community
                        Understand the socio-cultural influences and needs that promote stability
                        Preserve natural, cultural, and historic resources for inter-generational
                        continuity
                        Develop a sense of community self-reliance
                        Determine the economic basis of the community and climate for investment
                        Recognize the skills and knowledge of the community labor force
                        Develop private-public partnership
                        Incorporate community concerns into the decision-making processes
                        Integrate the regional ecosystem(s) perspective
                        Include "Best Practices" for sustainability
                            Develop a comprehensive approach to all concerns
                            Identify the carrying capacity of the ecosystem
                            Establish urban growth boundaries
                            Determine current and planned surrounding land use
                            Promote the potential benefits for minimizing automobile use
                            Determine economic self-sufficiency
                            Depend on community-stakeholders' consensus
                            Identify uncertainties and build-in  flexibility in planning options
                            Equalize benefits and burdens for  the community and stakeholders
                        Emphasize need for strong community and public leadership
                        Include all project stakeholders and concerned or interested citizens
                        Centralize local government coordination, point-of-contact, and authority
                        Integrate all public and private resources
                        Determine which party is best to initiate and perform the site characterization
                        Obtain accurate ecological information
                        'S   Delineation of site characteristics
                        'S   Representation of nature of contamination
                        'S   Site assessments
                        'S   Integration of assessments, audits and inspections
                        'S   Identification of groundwater contamination
                        'S   Create continuous updating procedure
                        'S   Use of technical resources available
                        Assess the redevelopment potential of the site
                        'S   Adjacent land owners and uses
                        'S   Cooperation of the owner
                        'S   Cost of remediation
                        'S   Socioeconomic conditions of the community
                        'S   Transportation and infrastructure
                        'S   Attractive natural or historic features
                        'S   Current economic conditions
                        Illustrate the basis of prioritizing the site over other candidate :
                        'S   Site prioritization schemes
                        'S   Multi-level screening process/prioritization model
                                                        213

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CHAPTER  5
CONCLUSION
Characteristics Associated with Elements of Sustainable Brownfields Redevelopment (Continued)
                                                 214

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CHAPTER
C O N C L U S
5
O N
Elements
Risk Management and
Restoration
               Characteristics
               •    Identify and clarify the barriers to effective risk management
                    'S   Lack of communication and coordination with stake holders
                    'S   Reluctant or hesitant stakeholders
                    'S   Community priorities and objectives
                    'S   Incomplete or inaccurate site characterization
                    'S   Threat of contamination spread
                    'S   Long-term remedial approaches
                    'S   Government policy and requirement changes
                    'S   Loss of market opportunity window
                    'S   Contingent risks of owners /developers
               •    Address the community concerns
                    'S   Relate scientific results and risks to community understanding
                    'S   Inform the public of issues critical to their interests
                    'S   Empower the public to act with respect to the risk communicated
               •    Address the project participant concerns
                    'S   Reluctance to participate and liability indemnification for current owner
                    'S   Return on investment and risk factors/perception for buyer & developer
                    'S   Borrower circumstances and property value maintenance for lender
               •    Identify the tools for Risk Management
                    'S   Project organizing
                    'S   Federal and State agency roles
                    'S   Use risk based corrective actions based on future uses
                    'S   Identify property ownership alternatives
                              institutional controls and insurance
Legal/Regulatory Issues
Site Marketing and
Redevelopment
                    CERCLA
                        "Joint and Several Liability"
                        SARA, 1986
                        EPA Guidance, 1992
                        "Covenant not to Sue"
                        "Prospective Purchase Agreements"
                        CERCLA Amendment,  1996
                        "Comfort Letter Policy"
                        "Secured Lenders and Fiduciaries" protections
                    RCRA, Clean Air Act, Clean  Water Act, Toxic Substances Control Act, etc.
                    Promote program factors
                    'S   Community expectations
                    'S   Rationality and incentives
                    'S   Ownership
                    'S   Program life cycle
                    'S   Control of development
                    Promote ecological factors
                    'S   Eco-Industrial parks
                    'S   Reclaimed Brownfields for parks and open spaces
                    'S   Green space and open space as interim use
                    'S   Reclaimed Brownfields in  ecologically sensitive areas
                    'S   Landscape design considerations
                    Promote socioeconomic factors
                    'S   The right property
                    'S   The right use
                    'S   The right incentives
                    Site Marketing
                    'S   Sites as community assets
                    'S   Role of prevailing market forces
                    'S   Market or feasibility analyses
                                                        215

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CHAPTER  5
CONCLUSION
Characteristics Associated with Elements of Sustainable Brownfields Redevelopment (Continued)
                               Characteristics
Elements
Technology Applications
Project Funding/Finance

Environmental Justice
                                   Energy Technology
                                   */  Reducing energy demands
                                   */  Renewable energy
                                   Environmental Technology
                                   */  Industrial Ecology
                                   */  Eco-Industrial parks
                                   */  Pollution prevention and waste minimization
                                   */  Site assessments and remediation
                                   */  Ecological monitoring and assessment
                                   Transportation Technology
                                   */  Intelligent Transportation Systems (ITS)
                                   */  Alternative fuels and vehicles
                                   Telecom/Information Technology
                                   */  Geographic Information System (GIS)
                                   Public Safety Technology
                                   Redevelopment processes requiring funding
                                   'S  Site characterization and remediation
                                   'S  Planning, public outreach and design approval
                                   'S  Development and reconstruction
                                   'S  Long term operational support
                                   Public Sources of funds, primarily for the initial stages of the project
                                   S  Federal - EPA, HUD, DOT, DOC, SBA
                                   'S  State — environmental or economic agencies, tax programs, loans
                                   'S  Local — incentive programs, tax increment financing programs, grants
                                   Private Sources of funds
                                   'S  Property owners or other responsible parties
                                   'S  Prospective purchasers or developers
                                   'S  Equity investors
                                   'S  Commercial banks
                                   'S  Private foundations and universities
                                   Early, adequate and meaningful community involvement in decision making
                                   Stakeholders who are committed to effecting a change for the better
                                   Equal access to all information relating to the redevelopment
                                   Willingness to negotiate to achieve a win-win situation
                                   Environmental equity, equitable costs and equitable benefits for all
                     Despite the inherent complexity of the Brownfields redevelopment process and the
                     multiple systems and processes that come together to influence the sustainability of
                     the  process, there is  one overarching concept that is most frequently  cited with
                     respect to ensuring the sustainability of a Brownfields redevelopment project.  What
                     is ultimately sustainable is what makes sense for the community.
                                                     216

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                     New York, Inc.
                                                    IX

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APPENDIX   A
ACRONYMS
           A List of Standard Acronyms Used in This Document


           ASTM               American Society for Testing and Materials
           BERI                Brownfields Economic Development Initiative
           BRAG               Base Realignment and Closure
           CAP                 Corrective Action Plan
           CDBG               Community Development Block Grant
           CDC                 Community Development Corporation
           CERCLA             Comprehensive Environmental Response, Compensation & Liability Act (Superfund)
           CERCLIS            Comprehensive Environmental Response, Compensation & Liability Information System
           CESD               Center of Excellence for Sustainable Development
           CPC                 Cuyahoga County Planning Commission
           CRA                 Community Reinvestment Act
           DOD                U.S. Department of Defense
           DOE                U.S. Department of Energy
           DOI                 U.S. Department of the Interior
           DOJ                 U.S. Department of Justice
           EC                   Enterprise Community
           EDZ                 Economic Development Zone
           EJ                   Environmental Justice
           EPA                 U.S. Environmental Protection Agency
           ESA                 Ecological Society of America
           EO                  Executive Order
           EZ                   Enterprise Zone
           EZ/EC              Empowerment Zone/Enterprise Community
           FUSRAP             Formerly Utilized Sites Remedial Action Program
           GAO                U.S. General Accounting Office
           GC/MS              Gas Chromatography/Mass Spectrometry
           GIS                  Geographic Information System
           GPS                 Global Positioning Satellite
           HUD                U.S. Department of Housing and Urban Development
           ICMA               International City/County Management Association
           IDA                 Industrial Development Authority
           IDE                  Industrial Development Bond
           IEMTF              Interagency Ecosystem Management Task Force
           IRM                 Institute for Responsible Management
           ISTEA               Intermodal Surface Transportation Efficiency Act
           ITI                   Intelligent Transportation Infrastructure
           ITS                  Intelligent Transportation System
           LAC                 Local Action Committee
                                                                  A-1

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APPENDIX  A
ACRONYMS
          LCLT               Lopez Community Land Trust
          LNYW              "Live Near Your Work" Program
          LUSTs              Leaking Underground Storage Tanks
          MOU               Memorandum of Understanding
          NEJAC              National Environmental Justice Advisory Council
          NIMBY             "Not in My Backyard"
          NFS                National Park Service
          NYSEDZ            New York State's Economic Development Zone
          OEA                Office of Environmental Affairs (U.S.E.P.A.)
          OSWER             Office of Solid Waste and Emergency Response (U.S.E.P.A.)
          PCB                Polychlonnated Biphenyl's
          PECs                Parameters, Elements, and Characteristics
          PPA                Prospective Purchase Agreement
          RBCA               Risk-Based Corrective Action
          RBDM              Risk-Based Decision Making
          RCED               Rural Economic and Community Development
          RCRA               Resource Conservation and Recovery Act
          RFP                Request for Proposal
          RIDEM             Rhode Island Department of Environmental Management
          SARA               Superfund Amendments and Re authorization Act of 1986
          SEP                Supplemental Environmental Project
          STIP                Sustainable Technologies Industrial Park
          SUNY               State University of New York
          TDR                Transfer of Development Rights
          TQM                Total Quality Management
          TSCA               Toxic Substances Control Act
          TSD                Treatment, Storage and Disposal
          U.S.C.               United States Code
          USEPA              United States Environmental Protection Agency
          UST                Underground Storage Tank
          UVA                University of Virginia
          VCP                Voluntary Cleanup Program
          WCMC              West Central Municipal Conference
                                                                  A-2

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APPENDIX  B
GLOSSARY
ASTM
                                   The American Society for Testing and Materials. An organization that establishes standards for industrial and
                                   other services, including methods of testing and sampling of hazardous waste and contaminated media.
Brownfields
Brownfields Program
Brownfields Pilot
Brownfields sites are abandoned, idled, or underutilized industrial and commercial facilities where expansion or
redevelopment is complicated by real or perceived environmental contamination.


The U.S. Environmental Protection Agency's Brownfields Economic Redevelopment Initiative is organized to
help communities revitalize Brownfields properties (both environmentally and economically), mitigate potential
health risks, and restore economic vitality to areas where Brownfields exist.  It is designed to  empower States,
communities, and other stakeholders in economic redevelopment to work together in a timely manner to prevent,
assess, safely clean up, and sustamably reuse Brownfields.  Efforts under the Brownfields Initiative are grouped
into four broad and overlapping  categories: 1) Providing grants for Brownfields pilot projects;  2) Clarifying
liability and  cleanup issues; 3)  Building partnerships  and  outreach  among  federal agencies, states, tribes,
municipalities, and communities; and 4) Fostering local job development and training initiatives.


The Brownfields pilots are designed to support creative  explorations  and demonstrations of  Brownfields
solutions.  The Pilots, each funded at up to $200,000 over two years, test redevelopment models; direct special
efforts toward removing regulatory barriers without sacrificing protectiveness; and  facilitate  coordinated site
assessment, environmental cleanup and redevelopment efforts at the  federal, state, and local levels. These grants
are used to generate interest by bringing together community groups, investors, lenders, developers, and other
affected parties to address the issues of cleaning up sites contaminated with hazardous substances and returning
them to appropriate, productive use.  The pilots are intended  to provide EPA, States, Tribes, municipalities, and
communities with useful information and strategies as they continue  to seek new methods to promote a unified
approach to site assessment, environmental cleanup, and redevelopment.
Brownfields Site
                                   A Brownfields site is a property, or portion thereof, that has actual or perceived contamination and an active
                                   potential for redevelopment or reuse.
CERCLA
                                   The  Comprehensive Environmental Response, Compensation, and Liability Act authorizes  the  federal
                                   government to create a special trust fund  (the Superfund) to be used for the assessment and cleanup of spills and
                                   other releases of hazardous substances, as well as abandoned or uncontrolled hazardous waste sites. It establishes
                                   the requirements and procedures for the  cleanup of sites that have been contaminated by releases of hazardous
                                   substances, and requires that a deed for federally owned property being transferred outside the government
                                   contain a covenant that all remedial action necessary to protect human health and the environment has been
                                   taken, and that the U.S. shall conduct any  additional remedial action necessary after transfer.
                                                                     B-1

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APPENDIX  B
GLOSSARY
CERCLIS
                                   The Comprehensive Environmental Response,  Compensation, and Liability Information  System is  a
                                   database that serves as the official federal inventory of CERCLA hazardous waste sites, and includes information
                                   about the sites, planned and actual site activity, and financial information.
Ecosystem
EZ/EC
Enterprise Zone
Described in its simplest terms, an ecosystem is an interconnected community of living things (including humans), and the
physical environment (non-living substances) within which they interact.


Empowerment Zone/Enterprise Community.  A geographic area that has been  targeted to  receive special
federal treatment and incentives in an effort to spur private investment and job creation.   The program is  a
Presidential initiative  designed to  afford communities real opportunities for growth and revitalization through
economic opportunity, sustainable  community development, community-based partnerships, and  a strategic
vision for change.  Designated communities  receive technical assistance, grants, employer tax credits, tax-free
facility bonds, tax deductions, and  increased coordination with federal programs.   The urban  portion of the
program is administered through HUD; the rural portion through USDA Rural Development.

A targeted area that has been designated as blighted or economically depressed by a governmental  entity in an
effort to stimulate economic activity through tax reduction, changes in zoning restrictions, and other
governmental regulations on private enterprise. Implemented through state legislation, these economic incentives
for investment and/or job creation are expected to stimulate market forces to respond in the designated areas.
Environmental Justice
Established by Executive Order No.  12898,  environmental justice asserts the fair treatment of people in  the
development of environmental laws,  regulations, and policies; irrespective of race, culture  or  socioeconomic
status.
Fringe
The contiguous area on the periphery of existing development and infrastructure that is connected to the urban
core.
Hazardous Substance
                                   As defined under CERCLA, any chemical or radiological material that poses a threat to public health or the
                                   environment; also any such wastes as defined under RCRA. Examples include materials that are toxic, corrosive,
                                   ignitable, explosive, or chemically reactive.
Human-made Capital
All of the tools, machines, equipment, technologies, structures, factories, and infrastructure that are the output
product of economic production, or are consumed in the process of economic production.
Industrial Ecology
The study of engineering principles and processes based on the concept that society must balance its accounts of
materials and energy with the  ultimate goal of minimizing harmful wastes and reusing, to the greatest extent
possible, both the wastes and the industrial products themselves.
Institutional Controls
                                   A legal or institutional measure that subjects a property owner (or tenant) to limitations on access or activity at a
                                   particular site in order to protect  human health or the environment.  Institutional controls  normally allow a
                                   contaminated property to be returned to use more quickly.
Infill Redevelopment
Construction of new projects on undeveloped parcels of land that are interspersed among existing, developed
parcels with supporting infrastructure in place; or reintroducing development and adaptive reuse to a previously
developed, abandoned, demolished, or vacated site with supporting infrastructure in place.
                                                                    B-2

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APPENDIX   B
GLOSSARY
Leakage
That portion of income to a community that is not spent or reinvested locally, but leaves the area as payment for imported
goods and services, outside investment, or as tax payments to government.
Natural Capital
The natural environment and its living systems, defined in terms of a stock of environmentally provided assets  (soil,
atmosphere, forests, minerals, water, fauna, wetlands), that provide the useful materials that represent the raw input or
consumable products of human production.
PECs
                                   The parameters,  elements  and characteristics  of sustainable  development,  defined   so  that  parameters
                                   represent the  three major systems  of social structure; economic, social, and  ecological.  Within these three
                                   parameters, specific elements are defined in terms  of their association with sustainable development and the
                                   associated characteristics of those elements are documented.
Phase I Audit
                                   A Phase  I Environmental Audit is an initial environmental investigation that is limited to  a historical records
                                   search to determine ownership of a site and to identify the kinds of chemical processes that were carried out at
                                   the site.  A Phase I audit may include a site visit, but does not involve any environmental sampling.
Phase II Audit
                                   A Phase II Environmental Audit is an investigation that includes tests performed at the site in order to confirm
                                   the location and identity of environmental hazards and recommend cleanup alternatives.
Phase III Audit
PRP
A Phase  III Environmental Audit includes  the comprehensive characterization, evaluation, and  removal of
contaminated materials from a site, and their legal disposal.


A potentially responsible party is any individual, or  organizational entity (e.g. owners, operators, transporters,
managers,  or generators of hazardous  wastes) that  is potentially  responsible  for,  or  contributing  to, the
contamination problems at a CERCLA (Superfund) site.
Public Capital
Funds that are spent by government entities for products, facilities, or services that are designated for the benefit
of the public.
RBCA
                                    Risk-Based Corrective Action is a streamlined approach, defined by the ASTM, in which exposure and risk
                                    assessment practices are integrated with traditional components of the corrective action process to ensure that
                                    appropriate and cost-effective remedies are selected, and that limited resources are properly allocated.
RCRA
                                    The Resource Conservation and Recovery Act (1976) establishes the federal regulatory program to track solid
                                    and hazardous waste management from generation to disposal. The Act defines solid and hazardous waste,
                                    authorizes EPA to set standards for facilities that generate or manage hazardous waste, and establishes a permit
                                    program for hazardous waste treatment, storage, and disposal facilities.
Removal Action
                                    A removal action is usually a short-term effort designed to stabilize or cleanup a hazardous waste site that poses
                                    an immediate threat to human health, or the environment.
Revolving Loan Fund
A loan program, usually sponsored by a government entity, in which a specific amount of public funds is set aside
to make loans for delineated purposes.  As the loans are repaid, the funding pool is reallocated and loaned out
again.
                                                                     B-3

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APPENDIX  B
GLOSSARY
Risk Assessment
                                   The process of identifying and documenting actual and perceived risks to human health or the environment, to
                                   allow further evaluation and appropriate responses.
Risk Communication
                                   The exchange of information about human health or environmental risks among public and private individuals to
                                   accurately inform and promote mutual understanding.
Rural
                                   Areas of land constituting various land uses at a low density which are suitable for sparse settlement, farms; or
                                   areas with little or no public services not suitable,  necessary, or intended for urban  use; separated from other
                                   jurisdictions  by farms, forest, or open space; and usually dependent on agriculture  or some other singular
                                   industry.   Defined by population, the US Census  Bureau  considers rural to  be all territory, population, and
                                   housing units in places of less than 2,500 including outside incorporated areas and census designated places, and
                                   the rural portions of extended cities.
Site Assessment
                                   The process of determining whether there is contamination present at a  site, the source and extent of that
                                   contamination, and the potential pathways of exposure to the public and the environment.
Social Capital
People, their capacity levels, institutions, cultural cohesion, education, information, skills, and knowledge.
Suburban
                                   Areas adjacent to the urban core with various land uses at various densities having     disclusionary zoning that
                                   implements a separation of uses, and with a focus on residential spacing.
Sustainability
The ongoing process of achieving development or redevelopment that does not undermine its physical or social systems of
support.
Sustainable Development
A process of change in which the resources consumed (both social and ecological) are not depleted to the extent that they
cannot be replicated. The concept also emphasizes that the creation of wealth within the community considers the well-
being of both the human and natural environments, and is focused on the more complex processes of development rather
than on simple growth or accumulation.
Sustainable Brownfields
                                   A project defined as one in which redevelopment and growth are maintained over the long-term and occur within
                                   the limits of the environment so that the current needs of the citizens are met without compromising the ability
                                   of future generations to meet their needs.
Tax Increment Financing
A method of financing infrastructure and other public costs of preparing and providing useable lands for
development or redevelopment by enabling a city to specifically allocate the property tax revenue generated from
a new development to the debt incurred as a part of the initial improvements required for that development. The
taxable  value on the developable  land is  frozen before  development occurs.   Upon  the  completion  of
development, the ensuing increased tax revenues realized as a result of an increase in taxable valuation above the
frozen value is reallocated to pay for the improvements to the property. The developer still pays  all taxes due on
the increased value.  The amount up to the frozen valuation is distributed to all governmental taxing jurisdictions
(city, county, school district, public utility, etc.). However,  the increased increment above the  frozen value  is
reallocated away  from the  various taxing jurisdictions  and governmental purposes and applied to the  initial
project improvement costs.  Once these debts are recovered,  the full taxable valuation is  again distributed among
the various taxing jurisdictions.
                                                                     B-4

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APPENDIX  B
GLOSSARY
Urban
                                   Areas of large land mass and population nucleus constituting various land uses at high density with supporting
                                   infrastructure and public services, and a high degree of economic and social integration. Defined by population,
                                   the US Census Bureau considers urban to be all territory, population, and housing units in urbanized areas and in
                                   places of 2,500 or more persons outside urbanized areas.
Urban Sprawl
Voluntary Cleanup
Zoning
The  decentralization of the urban core through the unlimited outward extension of dispersed  development
beyond the urban fringe where low density residential and commercial development exacerbates fragmentation of
powers over land use; also, the consumption  of  resources and land in excess of what  is necessary where
development is costly and underutilizes existing infrastructure.


A formal means established by many States to facilitate assessment, cleanup, and Program (VCP) redevelopment
of Brownfields Sites. Under VCP, owners or developers of a site are encouraged to approach the State
voluntarily to work out a process by which the site can be readied for redevelopment.


The  local governmental control over  land use by stipulating what can be constructed in certain areas and how
structures may be used. A community is classified by various zones, with differing land use controls imposed on
each zone, specifying the allowable uses of land and buildings, the intensity or density of such uses, and the size
and placement restrictions of buildings.
                                           Disclusionary Zoning  -  The separation of uses by strict delineation of what can be included in certain
                                           zoning classifications and buffering the different uses and their intensities.


                                           Inclusionary Zoning   -    The prerequisite of including low- to moderate-income  households in a
                                           development that exceeds a certain specified number of housing units.
                                                                    B-5

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APPENDIX
GLOSSARY
                                                    B-6

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APPENDIX  C
SUMMARY  OF  PILOT  PROJECTS  ANALYZED
Appendix C  -  Brownfields  Pilot  Project Case Analysis
Pilot Project: Boston, MA
Key Elements
                             Characteristics Identified and How They Contribute to Sustainabilitv
Project Scope, Scale &
Goals
The Dudley street neighborhood (DSN) is the focus of the redevelopment effort for the Boston Pilot.  The DSN is
located in the heart of Roxbury and North Dorchester, and is known to contain some 1300 vacant (and potentially
contaminated) lots. For this Pilot, six properties have been targeted, one of which is listed as an alternate.
Community Profile
Boston is one of the major industrial centers in New England, and is a major Atlantic seaport.  Population in the
metropolitan area is 575.000. The DSN is a tn-lmgual community (e.g. English, Spanish and Cape Verdean). This DSN
is the principal business center for Boston's African-Am eric an community. Not only does this area suffer from greater
unemployment than other areas in Boston, but it also contains a disproportionately higher percentage of the state's
contaminated sites.
Pro gram/ Pro j e ct
Organization
EPA Region I  selected the  city of Boston for a Regional Brownfields Pilot.  The city's Brownfields Partnership
Taskforce is providing funding to the Brownfields Economic Redevelopment Initiative (BERI). BERI is focused on
the DSN (a member of the BERI group) as the target of Brownfields Pilot Project redevelopment activities.  Another
member of the  BERI group is the University of Massachusetts; this institution is also involved with Pilot activities.
Tufts University has also been involved in the some of the outreach efforts associated with the Pilot.
Site ID and
Characteriz ation
The Modern Electroplating site is a 2-story building with 55,000 square-feet of floor area The Freedom Electronics site
contains an 87,000 square-foot building. The site has a leaking underground storage tank and illegal landfill materials
have been disposed onsite. The Hampden Street site has a total of 148,000 square-feet. The owner has not responded
to letters about access to the site. The Simon's Lot site has a total area of 293,000 square-feet.  Three  of the four
owners of the property are  tax-delinquent.  The Clifton Street  Bakery property has a total of 26,707  square-feet.
Attempts to obtain cooperation of the owner have not been completely successful; however, the owner has some
interest in selling.  A developer has shown strong interest in redeveloping the property. The site is large and has strong
community support for its redevelopment.
Risk Management &
Cleanup
The EPA has already spent over $1 million at one of the sites (Modern Electroplating) to conduct a removal action. A
site assessment is necessary to estimate remaining costs of cleanup. Phase I and Phase II assessments have been either
completed or are in progress at two of the sites.  Less than cooperative site owners are complicating the process of
obtaining additional information about the actual hazards posed by the sites.
Community Planning
The Pilot, in conjunction with some of the other members of BERI, has conducted community outreach meetings to
educate the community about Brownfields, and to obtain feedback regarding acceptable development strategies at the
target sites.
                                                                  C-1

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APPENDIX  C
SUMMARY  OF   PILOT   PROJECTS   ANALYZED
Site Marketing
Interested developers have been identified for some of the sites.  Qualitative assessments have been made about the
marketability of some of the sites based on location, presence of loading docks, availability of transportation, condition
of existing structures on the properties, amount of available land associated with the site, and proximity to waterfront
areas and wetlands.
Redevelopment
Approaches
The Modern Electroplating site was selected as the "anchor" site to serve as s model for other targeted sites. It is in a
prime business location.   The city has moved to foreclose on the site due to back taxes. Potential redevelopers have
expressed interest in the property. It is located in an Enhanced Enterprise Zone, which makes it eligible for additional
funding sources and tax incentives.   The  Freedom Electronics site is owned by the city of Boston.  It is also well
located in terms of business and transportation,  and it is also  eligible  for an  assortment of incentives  including
redevelopment/remediation  financing,  tax credits for hiring community residents, and  investment tax credits for
choosing manufacturing as the end activity at the site.
Technology Applications
Project Financing
Legal/ Re gulatory
Initiatives
The Pilot has collected and stored information in a GIS for five sites.  Stored information includes economic assets,
transportation, contamination levels, and zoning.


A proposal has  been submitted to the EPA for  the Brownfields  Revolving Loan Fund.  The fact that five of the
properties  are located in  areas designated as either a Federal Empowerment Zone (EZ)  and/or a State Enhanced
Enterprise Community (EEC) carries a variety of financial advantages.  EZ sites are eligible for additional sources of
funding that can be used for revitalization efforts.  The EZ provides a $2,500 tax credit for each resident of the zone
hired (a Workers Tax Credit).  Reduced loan financing rates are  also offered to eligible  large-scale redevelopment
projects. Similar funding options and tax incentives are available for sites located in EEC areas.  If the end use chosen
for the property is manufacturing, the State offers  a 5% investment tax credit. The Freedom Electronics site has been
designated as an Overall Economic Development Project (OEDP) by the  Metropolitan Area Planning Council.  This
designation makes it eligible for a $750,000 Public Works  Grant that can  be used for site development,  remediation,
demolition, construction, land filling or other activities necessary for redevelopment.


The Pilot program provided information to the  State Brownfields committee,  which in turn drafted  Brownfields
legislation for the city of Boston.
Community Involvement
The DSN has an existing community group that is  active in providing input to the redevelopment of this inner city
Boston neighborhood.  Other organizations within the greater community are also involved with the operation of the
BERI. The DSN and other community groups such as the Nuestra Commumdad, the Environmental Diversity Forum,
and the Alternatives for Community and the Environment are all collaborating with city personnel officials to identify
known sources of pollution.
Environmental Justice
One of the reasons for the targeting the DSN for this Pilot is to address some of the disproportionately higher
exposures that minority and/or disadvantaged communities have to contaminated sites.   The existing  community
groups that are working with BERI provide a forum for the inclusion of minority participation with the redevelopment
process.
                                                                          C-2

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APPENDIX   C
SUMMARY   OF   PILOT   PROJECTS   ANALYZED
Pilot Project: Bridgeport, CT
Key Elements
                               Characteristics Identified and How They Contribute to Sustainabilitv
Project Scope, Scale &
Goals
The Pilot objective is to return contaminated inner city, derelict land to productive use and create a prototype for other

cities.  The expectation is that the project will lead to new jobs, local economic growth, and increased tax base and

property values. The project is in two phases; the first is to hire a consultant to collect background data on potential

sites, the second is to select six sites to serve as model redevelopment sites. All tasks under the original Pilot Work Plan

have been completed — this is a successful Pilot on this basis.
Community Profile
Bridgeport,  with a population of 132,919,  is the  largest  and most distressed city in  the State.  The citywide

unemployment rate is 8.6%.  Manufacturing jobs have decreased 50% in the last decade. The area poverty rate is 17%.

Significant suburban greenfields development has occurred leaving several hundred acres of prime inner-city industrial

real estate abandoned.
Pro gram/ Pro j e ct
Organization
The Office of Planning and Economic Development provides the overall management and has convened a task force

(the Community Linkage for Environmental Action Now) to act as an oversight and advisory committee.   Project

oversight and assistance comes from EPA Region 1.
Site ID and
Characteriz ation
A site inventory of 205 sites has been ranked according to a database pnontization model.  Six sites have been targeted

for concentrated attention, with one site, the 9.8 acre former Jenkins Valve property, as the first site to be addressed.

This property is to be used for an indoor ice-rink, ballpark, and a new museum.
Risk Management &
Cleanup
Using an outside consultant, the project will collect information on the tax status, land use, land area, demolition

requirements, existing infrastructure, crime, redevelopment potential, and need for  remediation for the inventory of

potential sites. These sites have been ranked for development potential and six candidate sites have been identified for

highest and best use studies.
Community Planning
Planning includes "Team  Bridgeport," a group appointed by the Governor to develop a State Action Plan  for the

redevelopment of the City.
Site Marketing
Approximately 12 companies have expressed interest in sites the city has identified as having economic development

potential.   The city is maintaining ongoing communication with these companies.  The American Institute of

Architects used one site (a former power plant) as the  focus for an environmental design charrette to emphasize the

need for a comprehensive view of the interconnection between economic need, community development, and long-

term environmental stability.
Redevelopment
Approaches
Estimates are that approximately 200 jobs have been created, but no facility is as yet operational so there is no increase

in property tax base.  The Pilot has addressed approximately 60,000  square feet of facilities for redevelopment.  But

early project reports of accomplishment may have been overstated.  One 10-acre site has been cleaned and is ready for

redevelopment.
Technology Applications
                               Data not available.
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APPENDIX   C
SUMMARY   OF   PILOT   PROJECTS   ANALYZED
Project Financing              The State has pledged $2 mm to support site purchases and land assembly. The Grow Bridgeport Program combines
                               multiple sources of public funds into  a $7mm grant for small business  financing.  An additional $3 mm in Federal
                               Enterprise Community Funds supports a ten -year development plan. A Cooperative Agreement with EPA exists for a
                               revolving loan fund. The project has also received $15mm in private funding.


Legal/Regulatory             The city expresses concern that statutory constraints on the use of loan  fund money (cannot be used for petroleum-
                               related releases, lead/asbestos abatement, and most demolition activities) would discourage businesses  from seeking
                               loans.  The solution is to try to minimize the effect by consolidating the Brownfields funds with the existing Grow
                               Bridgeport Fund.


Community Involvement      The city is involving the local community in the Brownfields decision making process. The CLEAN group  has been
                               organized  to include individuals representing the local community, business, and government.  This group  has been
                               directly involved in the evolution of the program and has grown in size.


Environmental Justice         Data not available
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APPENDIX   C
SUMMARY   OF   PILOT   PROJECTS   ANALYZED
Pilot Project: Buffalo, NY
Key Elements
Characteristics Identified and How They Contribute to Sustainabilitv
Project Scope, Scale &
Goals
The project focuses on developing a city-wide master list of potential Brownfields properties, prioritizing and assessing
10-20 sites from a preliminary inventory of 100, creating a GIS database of site information, preparing a Brownfields
Redevelopment  Manual,  Community  Outreach  Plan,  Developer Workshop/Showcase,  and  a  South  Buffalo
Redevelopment Plan.
Community Profile
Buffalo is a typical northeastern urban area with population of 328,000; HUD ranked as the 4th most distressed in U.S.,
with a poverty of about 25%. The city contains about 98% of the surrounding county's minority population; is a HUD
EC and  includes several NYS EDZs.  Historical development was primarily for industrial manufacturing and as a
rail/waterway transportation hub for US/Canada/Great Lakes  commerce. Long history dealing with hazardous waste
issues (30 sites on NYS List, 60 sites on CERCLIS), several Brownfields sites are located along water bodies.
Pro gram/ Pro j e ct
Organization


Site ID and
Characteriz ation
The  Pilot is led by a Buffalo Brownfields Task Force including city, county,  state, private industry, universities, and
general public citizens. The task force is chartered by the Mayor.


As of January 1998, the  100 sites identified for inventory, representing about 4,000 acres, were screened to 25, with 22
listed as potential Pilot demonstration projects.  Eleven sites have Phase I assessments underway or completed by the
Task Force.
Risk Management &
Cleanup
                               No data available.
Community Planning
The City Planning Dept. is creating comprehensive development plans focusing on various sectors/wards of the City
(ex. South Buffalo Redevelopment Plan) to integrate new business development with recreational/green space areas.
Site Marketing
A partnership exists between the city and the local electric power utility to conduct a Brownfields Redevelopment
Workshop & Developer Showcase to highlight progress made, discuss and promote  sites identified with developers,
present factual evidence on specific sites to lessen false perceptions, address developers concerns and barriers, consider
regional development needs, strengths  and  strategies.  Results will be compiled into a  Redevelopment Manual to
sustain future developer outreach efforts.
Redevelopment
Approaches
Redevelopment strategies and approaches tailored to specific qualities and location of individual sites are consistent
with comprehensive area plans. Unique "First Source Agreement" requires businesses receiving city assistance to give
first hiring consideration  to local residents. On  larger  properties the plan is to seek mixed use with focus on
recreation/greenspace/light industrial/commercial. Emphasis is on creating jobs  for local residents.
Technology Applications
The Pilot is developing a GIS database of Citywide Brownfields sites and their qualities; creating a high-tech business
incubator in a former auto parts plant; and transforming a former steel mill along Lake Erie into a 22-acre hydroponic
tomato greenhouse; and using petroleum waste from a site for repaving asphalt.
                                                                        C-5

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APPENDIX   C
SUMMARY   OF   PILOT   PROJECTS   ANALYZED
Project Financing              The project leveraged  a variety of Federal HUD  EC  &  NYS EDZ grants,  donations  from  local Development
                               Corporations, and private company investments. Tomato  Greenhouse project is  underway  to obtain  utility rate
                               discounts and wage tax  credits ($750-$1500 credit per year for each new full-time employment position created). Phase
                               I/II assessments through NYS Environmental Assessment Bond Fund, site evaluation and highway improvements
                               through NYS Transportation Bond Act.


Legal/Regulatory             No data available.
Initiatives


Community Involvement       Project prepared a Community Outreach Plan to  inform  the public of the city's Brownfields community participation
                               process.


Environmental Justice         Buffalo Environmental  Management Commission used to educate, sensitize, involve, and empower minority & low-
                               income community regarding Brownfields.  City has agreements with new manufacturing plant, greenhouse, and other
                               private re developments  to maximize hiring of women and minority subcontractors.  Majority of the largest Brownfields
                               redevelopments occurring in area's minonty/disadvantaged neighborhoods.
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APPENDIX   C
SUMMARY   OF   PILOT   PROJECTS   ANALYZED
Pilot Project: Burlington, VT
Key Elements
                                Characteristics Identified and How They Contribute to Sustainabilitv
Project Scope, Scale &
Goals
The Pilot targets 17 properties consisting of 40 acres of land within a 3-mile radius of Burlington's central business
district. The Pilot's goal is an integrated approach that incorporates ecological zoning strategies, pollution prevention,
and sustainable  development. Objectives include  developing a comprehensive Brownfields Plan,  achieving a high
degree of citizen participation & support, and creating a redevelopment model for other small cities.  One Brownfields
site is within a 430-acre agri/industrial park situated on a 830-acre land tract that includes the world's largest wood chip
electrical generating plant, leaf compost facility, wood/metal recycling depot, and community-supported agriculture.
Community Profile             With a population of 39,127 Burlington is among the poorest cities in Vermont (about 19% below poverty) and has
                                received a Federal Urban Enterprise Community (EC) designation. Over 50%  or the population are between 20-49
                                years old. Its Brownfields pose an obstacle to growth and land use within the city, causing unwanted urban sprawl and
                                relocation. The largest Brownfield site is preventing highway construction  to connect the city-center with the Lake
                                Champlain  waterfront. Nine  of the Pilot sites  are  located within the EC, and most  of the sites are in or near
                                disadvantaged neighborhoods.
Pro gram/ Pro j e ct
Organization
The Project Coordinator works for the city's Community and Economic Development Office; in coordination with an
advisory committee  task  force, and  with contracted firms to help identify marketable properties, strategies and
potential purchasers.
Site ID and
Characteriz ation
                                No data available.
Risk Management &
Cleanup
The city is seeking ways to address community concern over particulates created by the scrap wood-fired power plant
through air monitoring and the charrette process. The city is addressing private developer fears over liability by using
various municipal instruments to acquire Brownfields sites, clean them up, sell or lease them back to private developers,
thereby retaining the environmental liability.
Community Planning
The city has established a "Coordinating Committee" for a pre-Pilot Brownfield project in 1992 that continues  to
advise the City.  The  committee  consists of  community members,  local businesses, environmental groups, and
government regulators. A similar approach to developing community  advisory groups is to be used for other sites. A
comprehensive Brownfields Plan is being developed to integrate Pilot Project goals/objectives.
Site Marketing
                                No data available.
Redevelopment
Approaches
The city is taking an integrated approach that incorporates ecological zoning strategies, pollution prevention, and
sustainable development to encourage  environmentally  friendly economic  growth. The  emphasis is  on creating a
transportation corridor between  the city core and waterfront, cleamng-up and  redeveloping  the waterfront, and
creating an eco-industrial park at the largest urban site.  An "Urban Reserve" is being created along the waterfront
through zoning restrictions on oil/gas tanks.
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APPENDIX  C
SUMMARY  OF   PILOT   PROJECTS   ANALYZED
Technology Applications       A DOE grant is being pursued to implement a prototype of high-strength waste-to-product technology such as fish
                                food and fertilizer production; also researching bioshelter design and construction and value-added food production.


Project Financing              In addressing its project coordination, community involvement, site assessment, and remediation issues the city has
                                used general city  revenues while  leveraging EPA Pilot Project grant, State Housing & Conservation Trust, EC, and
                                Lake Champlam Basin funds, CDBG, tax credits, and private developer money. Obtaining legal assistance from the City
                                Attorney and community banks'  in-house  counsel,  and technical assistance  from local university and  non-profit
                                economic planning and development groups.


Legal/Regulatory              No data available.
Initiatives


Community Involvement       The city relies  heavily on community  advisory groups  (ex. Barge Canal Coordinating Committee), local business
                                associations, and local neighborhood  planning assemblies  to  maintain public awareness of issues  and to identify
                                alternatives.


Environmental Justice          The city plans to involve disadvantaged neighborhood citizens  in all stages of the planning process; allow community
                                to assess the level of risk they are willing to live with at sites; and have community determine future land use options.
                                                                         C-8

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APPENDIX   C
SUMMARY   OF   PILOT   PROJECTS   ANALYZED
Pilot Project:  Cape  Charles,  VA

Key Elements                      Characteristics Identified and How They Contribute to Sustainability


Project Scope, Scale & Goals       The land set aside for the STIP covers 570 acres, and includes wetlands, a coastal dune habitat, and industrially zoned
                                   areas.  The Pilot targets  155 acres of this property that contains a former dump, a railyard site and the remains of
                                   abandoned industrial operations. The target area is situated on a narrow strip of land between the Chesapeake Bay and
                                   the Atlantic Ocean.  The goal of the Pilot is to assess the extent of contamination  at the  site, and to design a
                                   remediation strategy that will allow for redevelopment of the park.  After redevelopment the property will contain the
                                   eco-industrial park, restored wetlands, a nature trail, an environmental education facility, and a tertiary sewage treatment
                                   system.


Community Profile                The Town of Cape Charles is located on the southern tip of Virginia's Eastern Shore on a narrow strip of land between
                                   the Chesapeake Bay and the Atlantic Ocean.  The area boasts rich farmland, productive waters, vast wetlands, and miles
                                   of unspoiled coastline. The  population of the area is 13,000; 27% of which live below the poverty level. Forty-seven
                                   percent of the population is African-Am eric an.


Pro gram/Project                  The focus of the Pilot is the development of the Cape Charles Sustainable Technologies Industrial Park (STIP). Solar
Organization                      Building Systems is designed as the first tenant at this site. The STIP is designed to demonstrate advanced facilities in
                                   resource efficiency and pollution prevention.  Because of the possibility that there may be hazardous substances at the
                                   site, an assessment must be conducted prior to redevelopment.  After the Pilot is completed, the site area will include
                                   an eco-industrial park, restored wetlands, a nature trail and  environmental education center, and  a tertiary sewage
                                   treatment facility.


Site ID and Characterization       The targeted Brownfields area at this  site consists of 155 acres. Phase I and II investigations are designed to determine
                                   the extent of contamination  at the site. The first parcel is 25 acres in size and is designated as  the Town Dump. This
                                   site consists of harbor frontage, the former town dump and the main entrance of the park. The second parcel is the
                                   Natural Habitat Preserve site and is 28.8  acres in size.  Plans for this area include construction of a 1,500 foot
                                   boardwalk leading to a beach  observation platform,  restoration  of vegetative  cover for  migrating neo-tropical
                                   songbirds, and construction  of a stormwater runoff marsh.  The third parcel is designated Parcel A and was formerly
                                   used as a bulk  storage facility and  a municipal dump.  Based on the Phase  I investigations already performed,
                                   subsequent investigations will be at an undeveloped lot adjacent to the town wastewater treatment plant  (said to be the
                                   site of a bulk oil storage facility), and a closed municipal dump  on the southeastern portion of this parcel.


Risk Management & Cleanup      The site may contain hazardous substance materials that may threaten public health and the marine environment. This
                                   potential risk must be  assessed before the eco-industrial park can be developed.


Community Planning              The approach taken to develop community consensus  was by holding a community-wide "charrette"  or interactive
                                   workshop on redevelopment issues. Through the consensus process, a design was created for the selected site.


Site Marketing                    Solar  Building Systems is the  first tenant of the proposed redevelopment project.  This  company  has  taken  up
                                   temporary operations  in a converted vacant school building located off site from the  targeted project site area.  There
                                   are plans to use non-Brownfields land areas (including 111 acres of coastal maritime forest) outside of the targeted 155
                                   acres to add to the attractiveness, usefulness and overall sustainability of the proposed Pilot Project.
                                                                         C-9

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APPENDIX   C
SUMMARY   OF   PILOT   PROJECTS   ANALYZED
Redevelopment Approaches
Solar Building Systems (SBS) is the first tenant of the STIP. The company wants to hire out-of-work crab pickers,
(whose former employment involving pulling bits of meat from the shells of Chesapeake Bay crabs required fine-motor
coordination), to solder computer chips. Other efforts by the Pilot at the site include; managing some of the adjacent
coastal maritime forest as a habitat preserve for a selected endangered species and the restoration of wetlands. The
planned redevelopment efforts at this site will enable persons who had been formerly making less than minimum wage
working at seafood processing plants to double those wages by working for Solar Building Systems. Terms of the IDA
lease require that IDA be responsible  for the environmental remediation of these areas.
Technology Applications
Project Financing
Wetlands within the limits of the project area have been delineated and are envisioned as playing a role in tertiary
sewage treatment.   Solar Building Systems produces  siding and roofing material containing energy-producing solar
panels.


The Pilot's efforts  have resulted in the leveraging of additional resources for the project. These include an $800.000
Rural Business  Enterprise  grant  from  the U.S.  Department of  Agriculture and the  Economic  Development
Administration.  These funds will be used to establish infrastructure in the Industrial Park.  The Pilot also received a
$798,000 grant from the Department of the Interior to purchase land adjacent to the Park to extend a nature preserve.
The National Oceanic and Atmospheric Administration awarded the Pilot $190.000 to develop a coastal water quality
program.
Legal/Regulatory Initiatives
The Pilot has developed a Master Plan and Comprehensive Design and Operations Standards for the STIP.  Based on
these documents, the Cape Charles Planning Commission adopted a new STIP zone.  The Cape Charles Town Council
then rezoned the property into a new STIP zone, dedicated the land for road access and approved subdivision of the
industrial park land.
Community Involvement
The charrette and consensus-building process used to select redevelopment plans were community-wide and included
participation from minority and low-income populations.  The approach used in selecting the redevelopment involved
a philosophy that "is good for business, good for the environment and good  for the people ...all the people".  By
involving all members of a community in the process of selecting design plans that benefit everyone, a powerful
creative force is generated that enhances the chances for success of the effort.
Environmental Justice
A total of 47% of the 13,  000 persons living in the area  are below the poverty level.   One  of the goals of the
redevelopment effort is to produce situations that would allow residents of this community to improve their overall
economic conditions. The jobs being offered by the SBS will increase earnings over those previously obtained in the
seafood processing plants. The charrette and  consensus building process used to  select redevelopment plans were
community-wide and participation from minority and low-income populations within the community was emphasized.
                                                                        C-10

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APPENDIX  C
SUMMARY  OF   PILOT   PROJECTS   ANALYZED
Pilot Project:  Charlotte, NC
Key Elements
                                Characteristics Identified and How They Contribute to Sustainabilitv
Project Scope, Scale &
Goals
The Pilot Project is focused on the South End-Willmore redevelopment area.  The goal of the project is to  return
properties to productive use. The city is establishing clear guidelines for appropriate cleanup levels on selected sites.  A
model framework for environmental risk decision making to be used by lenders managing Brownfields risk  for private
investment is also being developed.
Community Profile             The City of Charlotte is an urban center with a population of approximately 395,934, 34.4% of which are minority, with
                                10.8% of the population living at or below the poverty level. The proposed project target area includes the city's oldest
                                industrial area, the South End/Wilmore district, parts of which date to the latter portion of the 19th century. The Pilot
                                Project area includes an industrial site with a  number of abandoned warehouses and manufacturing plants as well as a
                                resident population of 3,469.  Although physical improvements have been made to the area  in  the form  of private
                                redevelopment of several mills to retail, entertainment or residential uses, a number of sites remain where activity has
                                yet to occur.
Pro gram/ Pro j e ct
Organization
The criteria for selecting sites and determining the amount of funding for site activity were developed by the Pilot
Project's Environmental Committee. Assessment funds are divided equally between sites where transactions are already
in process for redevelopment and sites identified by the community as priority sites for future redevelopment.   Project
volunteer groups include law firms, lending institutions, colleges and universities that provide assistance with potential
regulatory barriers.
Site ID and
Characteriz ation
A core  site team consisting of representatives from  four  neighborhood associations, as well  as other stakeholders,
participates in the site selection process.    Site selection is based on input from community  meetings and a set of
selection criteria developed for this purpose by the project's Environmental Committee.
Risk Management &
Cleanup
Grant funds have been used to negotiate a final agreement for one site, the first such agreement under the State's new
Brownfields Act. The agreement will limit future use of site groundwater in exchange for a State promise not to hold
the developer responsible for any historic contamination found. The developer will spend  14.5 million on the site,
creating approximately 400 jobs.
Community Planning
                                No data available.
Site Marketing
Plans exist to transform one site into a regional community design center, a place where design related businesses can
acquire space  for product assembly, hold shows or meetings, and  to serve as a resource center  for design related
businesses. Other sites will be purchased for use as  flex space or to  expand existing manufacturing facilities for
currently operating businesses at nearby sites. Already redeveloped textile mills and factory sites have been used for
restaurant, retail, upscale housing and  a  working trolley line.  The stadium and  practice facilities  for the local
professional football team are also located on a former Brownfields site in this region.
Redevelopment
Approaches
The Pilot provides information to current property owners to assist in site marketing, clarification of environmental
issues and regulations, site assessment funding for qualified sites, and assistance in estimating cleanup costs.
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APPENDIX   C
SUMMARY   OF   PILOT   PROJECTS  ANALYZED
Technology Applications       No data available.


Project Financing               A sponsored workshop for lenders  that was attended by 29 lenders representing 10 banks was conducted under the
                                auspices of the Pilot Project.  The conference focus was education related to issues, key players, and perspectives
                                common to  transactions involving environmental problems.  Approximately $1.5 million in public funding has been
                                invested in the target area.  This investment was leveraged  to provide additional private funds to redevelop several
                                other properties in the area.


Legal/Regulatory              Statewide Brownfields legislation to simplify the regulatory review process and offer covenants not-to-sue was  signed
Initiatives                      in  1997.  The  result of efforts by  the  N.C. Citizens for Business and  Industry, with participation from the N.C.
                                Department of Environmental Affairs, and the staff of the Charlotte municipal government, this legislation has been
                                cited by the  President of the U.S. Conference of Mayors as  a model for similar legislation in other states.  The State
                                also has a Voluntary Cleanup Program.


Community Involvement       The Pilot produced  a public  television segment addressing the impact of Brownfields redevelopment and to announce
                                the first public meeting to be held.  Subsequently, 3 additional  community meetings have been held, supported by
                                several outreach attempts including a mass mailing and door to door distribution of literature. The Pilot Project's
                                public  outreach materials have been recognized  by an award  from the  National City County Marketing and
                                Communications Association.


Environmental Justice          The population of the Pilot target area is over 93% minority  as opposed to approximately 34% for the city as a whole.
                                Neighborhood concerns presented at public meetings are addressed by the Brownfields coordinators who respond by
                                letter to each of the meetings' attendees.
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APPENDIX   C
SUMMARY   OF   PILOT   PROJECTS   ANALYZED
Pilot Project: Cleveland,  OH
Key Elements
                               Characteristics Identified and How They Contribute to Sustainabilitv
Project Scope, Scale &
Goals
This was the first Pilot grant awarded by EPA.  A total of 4 sites have been identified. They are the Sunar Hauserman
site, the Mid-Town Corridor site, the Collingwood Railyard Site and the Burke Lake front Airport Site.  The objective
is prepare for the  future reuse of the  chosen sites, to ensure that decisions about cleanup and redevelopment are
consistent with the needs/expectations of the community, and to ensure that minorities and the disadvantaged are able
to participate in BF redevelopment efforts. The initial scope  of the project included only the first three of the sites
listed above, but a fourth site has now been identified.
Community Profile            Cleveland is located in north central Ohio on the shores of Lake Erie. It is Ohio's second largest city with a population
                               of over 490,000 in the  city and the surrounding area.   It is the largest municipality in  Cuyahoga County.  There is
                               extensive industrial and  commercial development throughout the city.
Pro gram/ Pro j e ct
Organization
The Cuyahoga County Planning Commission (CPC) was selected by EPA as the recipient of the first Brownfields Pilot
grant.  CPC is working with the Cuyahoga Community College (Tri-C) described as a community/business task force.
Other  organizational units  involved with the Pilot include the Cleveland State University (a recipient of a two-year
grant to  support the  creation of the Brownfields Redevelopment  Finance Center to develop models/strategies  for
resolving Brownfields issues), the Cuyahoga  County  Council (that developed a revolving  loan  fund for  site
assessments), and the assorted municipal entities from the City of Cleveland.
Site ID and
Characteriz ation
The  Sunar Hauserman site is a 7  acre  site  with a PCB  contamination problem.   It  has  become a successful
demonstration  site.  After the bankruptcy of the original  owner,  a total of $4.2 million has  been leveraged for
environmental cleanup and property improvements.  There are  several new businesses employing approximately 170
persons and generating over $1 million per year in income and tax revenue. The Mid-Town corridor (in the vicinity of
East 61st and Euclid) has a number of buildings with asbestos contamination.  The Collingwood Railyard is  a  joint
Count/City effort designed to transform idle Conrad property into a commercial/re tail center on Cleveland's northeast
side.
Risk Management &
Cleanup
The Sunar Hauserman site is generally considered a successful demonstration site. After the bankruptcy of the original
owner, a total of $4.2 million has been leveraged for environmental cleanup and property improvements. There are
several new businesses employing approximately 170 persons and generating over $1 million per year in income and tax
revenue.
Community Planning
Community Planning activities have been typically initiated by the CPC in conjunction with the other organizations
working in connection with BF projects. The College has established a community/business task force that ensures
broad-based participation and input for the BF effort.
Site Marketing
                               No data available.
Redevelopment
Approaches
                               No data available.
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APPENDIX  C
SUMMARY  OF   PILOT   PROJECTS  ANALYZED
Technology Applications       Different remedial technologies were used at each site including aquifer sparging with air. Groundwater pumping and
                                soil vapor extraction were used at the Sunar Hauserman Site:


Project Financing              In addition to the $200,000 obtained from EPA, Cleveland personnel have been able to secure another $3.2 million for
                                the purpose of extending the redevelopment effort.


Legal/Regulatory              The  State of Ohio has a  Voluntary Cleanup Program  that will  likely provide  assistance  in providing the proper
Initiatives                      remediation in a reasonable amount of time.


Community Involvement       The Tn-C is the organization that is most involved with the various forms of community interruption and outreach.
                                They have: held a forum to discuss risks posed by Brownfields, assisted with the development of high school curricula
                                on environmental  issues, initiated the development of programs to provide trained and capable workers  to support
                                Brownfields redevelopment efforts, and conducted outreach activities to recruit and train assorted inner-city residents
                                to perform work needed to remediate Brownfields sites.  (Note that a decision was made not to proceed with this last
                                program because there was  a limited market for these skills.)


Environmental Justice          The  extensive  involvement of the members  of the community  (with  particular emphasis on  the minorities and
                                disadvantaged)  with all elements the planning process ensures that knowledge about potential environmental justice
                                issues will be handled.
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APPENDIX   C
SUMMARY   OF  PILOT  PROJECTS  ANALYZED
Pilot Project:   East Palo Alto, CA


Key Elements                  Characteristics Identified and How They Contribute to Sustainability


Project Scope, Scale &         There are a total of 166 acres of Brownfields areas in East Palo Alto. The goals of this Pilot are to redevelop a large
Goals                          portion of the 130-acre Ravenswood Industrial Area (RIA) complex, create  new job opportunities for residents, and
                               increase the city's tax base, and thereby improve community services.


Community Profile             East Palo Alto is ethnically diverse with a population of 25,000 within a 2.5  square mile area. According to the 1990
                               census,  community residents  are 86% minority, including: African Americans, Latinos, Pacific Islanders and Asians.
                               The city was incorporated in 1983, but it inherited an inadequate infrastructure, low sales and property tax revenues, no
                               central business district and the 130-acre Ravenswood Industrial Area.


Program/Project               This is a Regional Brownfields grant made to the city of East Palo Alto.  As a part of the Pilot cooperative agreement,
Organization                  Region IX EPA will provide a staff person to the City of East Palo alto through February 6, 1998. The Region IX EPA
                               office and the U.S. Department of Housing and Urban Development  (HUD) will also provide assistance to the  city in
                               connection with redevelopment efforts pursued under this Pilot.  Specifically, Region IX EPA and HUD have  joined
                               together to provide  Federal  staff liaison to  work with Brownfields  and economic  development issues, coordinate
                               Federal and State programs to meet city needs, and identify assistance  programs for which the city qualifies. East Palo
                               Alto is also working with the  California Regional Water Quality Control Board (CalEPA) to conduct a screening level
                               investigation of soil and groundwater contamination associated with the site.


Site ID and                    The Ravenswood Industrial Area is made  up of 59  properties and occupies 130 acres of land.  The area overlooks
Characterization               wetlands and the San Francisco Bay at a location situated at the gateway to the technology-based Silicon Valley.


Risk Management &           The results of the Phase II investigation performed at the site showed contamination levels to be lower than expected.
Cleanup                       East Palo Alto is working with the California Regional Water Quality Control Board (CalEPA) to conduct a screening
                               level investigation of soil and groundwater contamination associated with the site.  From the process of determining
                               the extent of existing soil  and groundwater contamination,  it will  be  possible  to  identify  areas  where  more
                               comprehensive studies maybe needed.
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APPENDIX  C
SUMMARY  OF   PILOT  PROJECTS   ANALYZED
Community Planning
The Regional EPA assisted the city in efforts  to conduct community  outreach and education meetings to inform
residents  of the results  of the  EPA investigation. The Pilot has also  established the Ravenswood  Industrial
Stakeholders Group (RISC). The purpose  of this group is to  use  the  results  of sampling performed by EPA and
CalEPA to  develop land use and alternative redevelopment scenarios.   The  RISG will also  identify a process for
implementing the redevelopment plan.   The Pilot  met with  the  National Carpenter's  Union and  Opportunities
Industrialization Center  West to  develop ways  for both  organizations to provide  job placement and training for
handling hazardous materials. The Pilot plans to look for opportunities  to provide this training at other Brownfields
Pilots. The  Pilot plans to hold at least three seminars for community personnel designed to inform residents about the
surrounding wetlands,  the  Brownfields  redevelopment  areas,  and other  environmental  factors  affecting their
neighborhoods.  In connection with an existing grant that DePaul University received  from the National Institute of
Environmental Health Sciences, students from Palo Alto participated in a job-training program.  The students received
60 hours of hazardous material worker training, 48 hours of lead, asbestos abatement,  and  underground storage tank
(UST) removal training.  Seventeen area residents received this training and they will complete  90 days of on-the-job
training with a local environmental cleanup company.  There are potential full-time jobs available for  some of these
persons students at a local chemical  solvent recycling company.  Attempts are being made to increase outreach efforts
to other potential employers in the South  Bay areas, and to  expand this training program for the area surrounding the
RIA site.
Site Marketing
The Pilot plans to conduct outreach activities to attract businesses to the area.
Redevelopment
Approaches
Technology Applications
The site had originally been home to a hazardous waste recycling facility and also a pesticide manufacturer.  Initial
estimates were that it would cost $30 million to remediate the site.  A Phase II site investigation has been completed. It
showed that contamination levels were lower than expected.  Current estimates are that cleanup will range from $2
million  to $5 million.  Future efforts will focus on completing other necessary site assessment efforts  and beginning
remediation planning.  The Pilot plans to consolidate a number of small parcels (with multiple owners)  into a singe
parcel.  Because of the site's close proximity to wetlands, the Pilot stakeholders want "green" development that will not
degrade  the  adjacent wetland.  One of the  plans for redevelopment is to remove industrial blight and upgrade  a
debilitated access  road so that the  areas in East Palo  Alto  adjacent to the wetlands can  be used to enhance the
recreational use of this  area.  This  would include making improvements  that will allow  for the  use  of assorted
observation decks  for bird watching and pathways for hikers and bicyclists.


The Pilot plans to conduct a screening level investigation of soil and groundwater  contamination associated with the
site. Plans were made to use a Geographic Information System (GIS) for collecting a visual map-based description of
site conditions.
Project Financing
The amount of the Pilot grant was $170,000 (initially $125,000, and later $45,000).  Region IX EPA spent $300,000 for
the Phase Ii site assessment. No other sources of funding have been identified for the required cleanup or from the
total redevelopment process.
Legal/ Re gulatory
Initiatives
East Palo Alto's Redevelopment Agency's First Source Hiring Policy ensures that local residents will be trained and
interviewed first for jobs created through redevelopment.
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APPENDIX  C
SUMMARY  OF   PILOT  PROJECTS   ANALYZED
Community Involvement       Regional EPA assisted the city in efforts to conduct community outreach and education meetings to inform residents
                                of the results of the EPA investigation. The Pilot has also established a Ravenswood Industrial Stakeholders  Group
                                (RISG) that provides community input to  decision making. The purpose of this group is to use the results of sampling
                                performed by EPA and CalEPA to develop land use and alternative redevelopment scenarios. RISG will also identify a
                                process for implementing the redevelopment plan.   The  Pilot met  with the  National Carpenter's  Union  (United
                                Brotherhood of Carpenters) and Opportunities Industrialization Center West to determine ways for both organizations
                                to provide  job  placement and  training for handling hazardous materials handling.  The Pilot plans  to look for
                                opportunities to provide this training at other Brownfields Pilots.


Environmental Justice          Many of the efforts being performed by the Pilot are designed to address environmental justice issues.  Community
                                residents participated in a  job-training program. The students received 60 hours of hazardous material worker training,
                                48 hours of lead, asbestos abatement, and underground storage  tank  (UST) removal training, and other  UST  related
                                training.  Seventeen area residents received this training and they will  complete  90 days of on-the-job training with a
                                local environmental cleanup company. There are potential full-time jobs available for some of these students at a local
                                chemical solvent recycling company.  Attempts are being made  to increase outreach efforts to  other potential
                                employers in the South Bay areas, and to expand this training program for the area surrounding the RIA site.
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APPENDIX  C
SUMMARY  OF   PILOT   PROJECTS   ANALYZED
Pilot  Project:  Greenfield, Massachusetts
Key Elements
                               Characteristics Identified and How They Contribute to Sustainabilitv
Project Scope, Scale &
Goals
The Pilot Project is focused on an abandoned 145,000 sq. ft. machine tool manufacturing plant located along the Green
River, on which open containers of hazardous material have been identified. The property covers 13 acres.   The goals
of the project are to evaluate the environmental concerns at the site; explore an innovative cooperative model for site
assessment;  create redevelopment opportunities; and plan for the restoration of the site as  an asset to  a  blighted
neighborhood.
Community Profile             Greenfield is a small town with a population of 18,026. The town has an unemployment rate of 5.4% and has been
                               designated as an Economic Target Area by the Commonwealth of Massachusetts. The town has experienced a 37% loss
                               in manufacturing jobs between 1980 and 1990.
Pro gram/ Pro j e ct
Organization
The project will develop a cooperative partnership among the local government, State environmental agencies, private
consultants, and students from the University of Massachusetts.
Site ID and
Characteriz ation
Activities planned as part of this Pilot include: site investigation and remedial planning and determining future land-use
options for the site.
Risk Management &
Cleanup
                               No data available.
Community Planning
                               No data available.
Site Marketing
Several Possible uses for the site include a cultural center, office space, and a museum.
Redevelopment
Approaches
Redevelopment of the site could provide needed space for local business expansion.
Technology Applications
The project is focused on developing model approaches to reducing cleanup costs.  Models will be evaluated for
rep lie ability.
Project Financing
The  project will  identify  funding  sources  to  include private  sector developers who will assist in cleanup and
redevelopment.
Legal/ Re gulatory
Initiatives
                               No data available.
Community Involvement
                               No data available.
Environmental Justice
                               No data available.
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APPENDIX C
SUMMARY  OF
                  PILOT  PROJECTS  ANALYZED
                                                 C-19

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APPENDIX   C
SUMMARY   OF   PILOT   PROJECTS   ANALYZED
Pilot Project: Navajo  Nation
Key Elements
                               Characteristics Identified and How They Contribute to Sustainabilitv
Project Scope, Scale &
Goals
The  Pilot focuses on the former Navajo Forest Product Industries mill property, a 10.5-acre site that included  a
particleboard factory and millworks  with machinery and maintenance shops.  Five objectives of the project are to
identify all hazardous substances on-site & in groundwater; assess public health and environmental risks; educate the
community,  develop a remedial design; and, cleanup & revitalize the industrial complex.
Community Profile            The Navajo Nation mill site is located in a rural  section of NW  New Mexico with 2,293 residents, predominantly
                               Native Americans.  The mill complex shut down in 1995 resulting in loss of 300 jobs and annual sales over $20 million.
                               About half the population is impoverished with few other local employment options.
Pro gram/ Pro j e ct
Organization
The Pilot is led by Navajo Nation Environmental Protection Agency (NNEPA) who hired a full-time Pilot Project
Coordinator. Local residents/tribal members are involved.  There is also close cooperation with Federal EPA Region
IX.
Site ID and
Characteriz ation
The  site contains 32 buildings, hazardous and solid waste problem areas including PCB-contammated transformers,
capacitors and stained soil; discarded batteries; barrels of acids, solvents and petroleum products; and a wash trough
with unidentified solvent. A wood chip and particleboard dump area has smoldered in the past. A PA was completed
and a SI is planned.
Risk Management &
Cleanup
The Navajo Nation is planning a voluntary cleanup program removal response at the site once tribal general funds are
obtained. Pilot funding will be used for site assessment and developing a remedial design plan.
Community Planning
A community outreach effort is underway to identify local community needs and concerns through an  education
campaign in the Navajo language.  A local high school class plans to develop a video(s) of the site assessment and
cleanup efforts. Public tribal meetings are held as needed.
Site Marketing
                               No data available.
Redevelopment
Approaches
The Navajo Nation's Red Lake Chapter (the tribal equivalent to a county) is considering a lease of all or part of the
complex to a regional lumber milling company which will conduct operations under a new 10-Year Forest Management
Plan. Restoring milling activities would enable many of those laid off to return to work.
Technology Applications
The project is obtaining technical assistance from USEPA for site assessment and screening technologies. The plan is
to reuse as much of the existing facilities and machinery as possible.
Project Financing
The Pilot is financing much of the organizational, site assessment, and community outreach efforts.  Tribal meetings
are occurring to obtain tribal concurrence for remedial financing.
Legal/Regulatory Initiatives
                               No data available.
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APPENDIX  C
SUMMARY  OF   PILOT  PROJECTS   ANALYZED
Community Involvement       All activities are being led and conducted by tribal members who are also residents  of The Navajo Nation.   Local
                                residents are to be trained by USEPA to conduct site assessment and hazardous waste site cleanup. The local university
                                is assisting with videos of the complex for historical documentation.


Environmental Justice          Former mill operations  were  the livelihood of the local, socioeconomically distressed community.  A Majority of
                                residents are under 50 years old with only a high school education or less.
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APPENDIX   C
SUMMARY   OF   PILOT   PROJECTS   ANALYZED
Pilot Project:  New Orleans,  LA
Key Elements
                                Characteristics Identified and How They Contribute to Sustainabilitv
Project Scope, Scale &
Goals
The Pilot goal is to develop an inventory of Brownfields sites in the city to aid city planners, developers and investors
in restoring the properties. The immediate objectives were to identify sites; develop criteria to rank the sites in terms of
economic redevelopment potential; develop a basic cleanup process; and, generate redevelopment strategies for 5-10 of
the sites.
Community Profile             New Orleans is noted  for its cultural diversity with 65% of its more than 480,000 population of African American
                                descent. The city is located adjacent to two major waterways-the Mississippi River and Lake Ponchatrain, at the foot of
                                the "chemical corridor" whose port, rail, and highway systems  transport a high volume of hazardous materials. Since
                                October 1990, the city has emphasized economic development planning to revitalize major sections of the City and its
                                neighborhoods. Brownfields identification and redevelopment strategies were incorporated into the planning efforts in
                                1995. The city has been designated a HUD Enterprise Community.
Pro gram/ Pro j e ct
Organization
The  Brownfields program and Pilot Projects are coordinated by the city's Office of Environmental Affairs (OEA)
which is located within the city's Economic Development Division. This ensures coordination between the Economic
Development and Policy Planning staff and the Mayor's Environmental Strike Force. The OEA chairs the Brownfields
Consortium,  a  broad representation of state/city agencies, bankers, developers, and citizen groups. A professional
facilitator coordinates the day-to-day activities and meetings of the Consortium.
Site ID and
Characteriz ation
Through a series of community meetings and surveys of city public works components, 167 potential Brownfields sites
were identified and screened down to the top ten. The screening required several tiers of criteria that included location,
potential for contamination problems based on past use, windshield surveys, investment community requirements, and
actual Phase II testing data from an EPA mobile analytical lab. Several sites have USTs, asbestos, and potential lead
pollution problems.
Risk Management &
Cleanup
Liability issues  are to be addressed through EPA Letters of Comfort. The  consortium is charged with  identifying
sources of funding for site remediation on a site-by-site basis.
Community Planning
The Brownfields inventory and redevelopment strategy will be integrated into the comprehensive "New Century New
Orleans" Master Policy Plan and a subset Riverfront Strategic Policy Plan, to provide a policy framework that directs
and guides future development.  These plans also serve as a  stakeholders' consensus of citizens, professionals, and
politicians.
Site Marketing
The OEA and Brownfields Consortium have developed a draft Brownfields Marketing Plan that outlines five phases of
planning and activity for  (1) community participation; (2)  stakeholder involvement; (3)  "collaterals"  or information
management and presentation; (4) marketing initiatives; and, (5) public relations.
Redevelopment
Approaches
A variety of possible reuses will be considered based on community involvement and property owner, developer, and
lender discussions. Two sites are being considered by developers for residential or low-income housing.
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APPENDIX  C
SUMMARY  OF   PILOT  PROJECTS   ANALYZED
Technology Applications       The Pilot used EPA's mobile analytical lab to expedite Phase II field characterization of five properties within the top
                                ten. The city's planning and economic development GIS database is being augmented with Brownfields sites.


Project Financing              The consortium is charged with identifying sources of funding for remediation on a site -by-site basis.


Legal/Regulatory              No data available.
Initiatives


Community Involvement       The extensive role for community involvement is outlined in  the city's Brownfields Marketing Plan.  A professional
                                facilitator has provided effective support in coordinating and integrating community input.


Environmental Justice          Many of the  city's Brownfields  are  located near  transportation  routes  that are adjacent to low income, African-
                                American residential neighborhoods.   A  current  lack of information  on Brownfields  sites' history prevents new
                                development,  and the attendant jobs and training for neighborhood residents, from taking place. Historically, residents
                                have been  removed from  decision-making  about industrial and economic  activities  in the  community.  Public
                                involvement in site cleanup and redevelopment plans will address these problems.
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APPENDIX   C
SUMMARY   OF  PILOT  PROJECTS  ANALYZED
Pilot Project:   Oregon Mill Site Conversion,  OR
Key Elements
                               Characteristics Identified and How They Contribute to Sustainabilitv
Project Scope, Scale &
Goals
This rural area Pilot targets 9 abandoned mill sites located in 9 different towns in Oregon, which cover a combined
total of 550 acres.  The objective  of this Pilot is to rehabilitate these vacant and abandoned mills into productive
industrial/commercial properties that will enable  surrounding communities to attract business that bring new and
diverse employment opportunities.
Community Profile             Since 1988, cutbacks and closures of 119 lumber and wood product facilities occurred in 23 primarily timber-dependant
                               rural communities. These closures have economically devastated the communities by depressing mill property values,
                               reducing the tax base, creating abandoned infrastructure, decreasing family incomes, and  increasing the  focus on
                               greenfields for any new development. In many communities, these mill sites are the only zoned industrial property
                               within designated growth boundaries.
Pro gram/ Pro j e ct
Organization
The project organization is a public/private partnership. It is managed by a non-profit corporation with expertise in
rural community business development strategies, operating under the overall coordination of the State Economic
Development  Department, and supported by a private utility, bank, and law firm as well  as  other  State/Federal
agencies. A project advisory committee, consisting of representatives from the partnership groups as well as others
with particular expertise, has been formed. Due to the geographic distribution of sites, Local Action Committees exist
for each site.  These committees consist of city/county/local economic development groups representing citizens &
businesses.
Site ID and
Characteriz ation
Most sites have combined, and completed Phase I environmental assessments with wetlands determinations and Phase
II Assessments with wetlands delineations.
Risk Management &
Cleanup
The  Pilot is evaluating the potential for using generic cleanup options to help  developers assess  cleanup  liability,
financing options, and development risks; and to establish cleanup standards  for similar abandoned mill sites.  The
Pilot is also creating a computer model to measure cost/benefit of various cleanup options.
Community Planning
Local Action Committees (LAC)  are responsible  for developing redevelopment plans tailored to  each  site  that are
consistent with their  economic development plans and that consider land use,  wetland mitigation, cleanup, and
redevelopment incentives. Each LAC will create  outreach plans to  ensure broad  community input to  cleanup and
redevelopment efforts.
Site Marketing
The  project  organization and composition  of partners  is  heavily focused  on  rural/urban  site  marketing and
redevelopment. The LACs are developing marketing strategies as part of local redevelopment plans.
Redevelopment
Approaches
Site-specific reuse plans  consistent with local  redevelopment plans/opportumties/strategies are  being developed,
infrastructure needs, environmental land-use planning requirements, and goals of developers/private property owners
are key components of the project effort.
Technology Applications
                               No data available.
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APPENDIX   C
SUMMARY   OF   PILOT   PROJECTS  ANALYZED
Project Financing               Project funding conies primarily from partnership members and EPA grants. Other state/Federal programs are being
                                leveraged. Pilot plans include privately financed site cleanup as part of the redevelopment effort.


Legal/Regulatory              No data available.
Initiatives


Community Involvement       Local Advisory Committees coordinate community awareness, input and participation.  Public utilities support the
                                publication of a Project Newsletter  circulated throughout affected communities to increase awareness  of ongoing
                                issues/developments.


Environmental Justice          The Pilot is emphasizing community awareness programs to address risk communication with local citizens.
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APPENDIX   C
SUMMARY   OF  PILOT   PROJECTS   ANALYZED
Pilot Project:   State  of Rhode Island
Key Elements
                               Characteristics Identified and How They Contribute to Sustainabilitv
Project Scope, Scale &
Goals
The  Pilot focus  is on 50 potential Brownfields sites located  in multiple  communities within the watersheds  of the
Woonasquatucket and Blackstone Rivers. Site inventories are incomplete and are not cross-referenced with economic
developmental potential. The goal is to create a model ecosystem-based program to return sites to beneficial use.  The
objectives include  coordination with multiple State and local agencies, providing a degree of certainty in levels of
contamination, and the leveraging of additional resources.
Community Profile
The project involves two urbanized areas and three rural towns in the north-central portion of the State. Historically,
these communities were formed from villages that grew around mills along the rivers. After decades of heavy industrial
use, then a rapid decline in mill industries, many contaminated properties are left for decay.  No demographic data is
available.
Pro gram/ Pro j e ct
Organization
Because  most  of the  affected  communities  have only minimal organizational infrastructure, the Rhode  Island
Department of Environmental Management (RIDEM) has taken the lead in coordination and implementation. Other
state and local agencies, the RI Port Authority and Economic Development Corporation (Port Authority) and citizen
action groups support project implementation and communications. For local municipalities, the focus is  on either the
Planning or Economic Development offices for coordination.
Site ID and
Characteriz ation
RIDEM conducted a regional survey in which municipalities  nominated 120 potential sites.  RIDEM then screened
these sites down to 50 and conducted Phase I Baseline Property Surveys. Stakeholder roundtables prioritized the sites
and selected the top 24 sites based on Phase  I data, community concerns, environmental threat, and potential reuse.
Phase II site assessments/remedial evaluations are being conducted by RIDEM with more underway. One key is the
regional coordination to identify, screen & prioritize sites. At one site,  RIDEM & EPA are conducting "targeted
assessment."
Risk Management &
Cleanup
The Pilot is leveraging site cleanup with others (ex. agreement with prospective purchaser to install monitoring wells
and conduct analytical testing; U.S. Coast Guard removal action of leaking LIST into river).  The State  "Industrial
Property Remediation and Reuse Act, 1995" provides documented future use-based cleanup objectives, liability releases
under certain situations, and covenants not to sue based on site settlement agreements.
Community Planning
Although communities  have Community Master Plans,  trying to integrate Brownfields into the existing plans is
difficult  and time consuming.  RIDEM is  working  with established community action  groups to involve  the
community in planning processes (ex. The Providence Plan for the Woonasquatucket River Greenway Project).
Site Marketing
The  "Rhode Island  Mill  Building and  Economic Revitalization Act, 1996" provides  economic  incentives  and
streamlined permits process to stimulate reuse & redevelopment of former mill sites.
Redevelopment
Approaches
The  Pilot is taking an ecosystem management approach to  redevelopment within the  watershed.  The focus  is on
creating  employment opportunities  and upgraded affordable  housing for low  income  residents in Brownfields
neighborhoods. The Narragansett Knitting site being considered for a high-tech incubator project.
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APPENDIX  C
SUMMARY  OF   PILOT  PROJECTS   ANALYZED
Technology Applications       No data available.


Project Financing              In addition to leveraging with community economic development funds, the State's Industrial Property Act authorizes
                                a revolving fund  created by a vehicle  tire  storage, remediation and recycling program and an $8  million initial
                                appropriation.  The State's Mill Site Act provides a  series  of tax  credits for  owners/operators of "certified" mill
                                buildings.


Legal/Regulatory              The State has passed two key laws to stimulate remedial investigation, cleanup and reuse of industrial  sites and former
Initiatives                      mill site buildings.  Provisions of these laws address liability, cleanup standards, site closure, and financing vehicles.


Community Involvement       Community involvement is primarily through municipal agencies and existing community action groups. Creation of
                                new, Brownfields focused groups is discouraged due to historical distrust between citizens and government agencies.


Environmental Justice          No data available.
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APPENDIX  C
SUMMARY  OF   PILOT   PROJECTS   ANALYZED
Pilot Project: Trenton,  NJ
Key Elements
                                Characteristics Identified and How They Contribute to Sustainabilitv
Project Scope, Scale &
Goals
Trenton's Pilot focuses on 15 Brownfields sites on 23 acres. It has also targeted more than 600 acres within an urban
EZ having potential Brownfields. It is seeking to engage the entire community, especially affected neighborhoods, to
identify the problems, opportunities and resources  associated with the sites;  and to  identify financial resources to
develop a comprehensive strategy for site assessment, cleanup and reuse.  The goal is to serve as model for small,
former industrial cities, create a model for institutional change in the overall site remediation process, and be a model
for using community development corporations and others in innovative technical & managerial processes.
Community Profile             Trenton, a city located in west-central NJ with 89,000 in population, was a prominent 19th century manufacturing
                                center that has greatly declined, leaving  a large number of potential Brownfields sites. A large portion of the city's
                                minority populations live in neighborhoods surrounding vacant industrial sites, with unemployment between 15 and
                                25% and a poverty rate of about 18%. The city also has several miles of riverfront property along the Delaware River.
Pro gram/ Pro j e ct
Organization
The  city's Dept. of Housing and Development has a lead role with several primary groups as partners - the BEST
advisory council, a non-profit community development corporation, the  Eco-industnal park roundtable discussion
group, and  the Trenton  Enterprise  Initiative Coordinating  Committee.  The  partnership also includes other key
university and community development organizations.
Site ID and
Characteriz ation
The  city created an Environmental Assessment Plan based  on the experience of the NJ State ECRA and ISRA
programs. All 23 acres  of Pilot Project properties  have been assessed.  Cleanup is underway at two sites (12 acres
combined). A proposal has been made to the State to  amend its ISRA program to extend grant funding to include
remedial investigations  to better  determine the extent of contamination  and the cost of remediation -  essential
information to market the site for privately financed remediation.
Risk Management &
Cleanup
To  overcome developer fears of liability and to kick-start restoration efforts, the City is taking aggressive actions to
acquire Brownfields sites through tax foreclosures, sale of tax certificates, condemnation, or eminent domain if needed.
The city is then able to leverage State/Federal funds  for assessment, cleanup and reconstruction.  It then enters into
lease-purchase arrangements with private developers who establish businesses on site. NJ ISRA allows both permanent
& non-permanent cleanups to either  residential or  less  stringent  standards.  Also  the  State uses engineering and
institutional controls to reduce risk to 1-ppm; and also has a special cleanup flexibility for "historic fill" sites.
Community Planning
Brownfields program  efforts  are  being coordinated with the Trenton Enterprise Initiative planning  process  that
includes representatives from every sector of the community.
Site Marketing
The  city is working closely with private developers and community development corporations to market sites.  City
ownership and liability are seen as a big benefit.  Ideally, the city has interested developers and projects lined up before
the transfer of property. For each site, the city performs environmentally-related market analyses to identify industries
suitable for sites.
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APPENDIX  C
SUMMARY  OF   PILOT  PROJECTS   ANALYZED
Redevelopment
Approaches
Approaches are tailored to individual sites depending on acreage, existing building capacity, and location. Examples
include an upscale candle manufacturing plant, a food processing plant with retail outlet & cafe, a performing arts
center and YMCA, and a community service supermarket, drugstore &  dry cleaner.  An Eco-Industrial Roundtable
Discussion Group has been formed to explore the concept of eco-mdustrial parks, promote ideas for projects in the
city, and to recruit "green businesses."
Technology Applications
The project is using phy to remediation at one site and exploring the eco-industnal parks concept.
Project Financing
Progress of the Pilot so far has primarily been due to Federal and State grants. Nearly all site assessment and site
cleanup has been accomplished through grant funds. One site that the city cleaned-up will be sold/leased to private
business; proceeds will be used to establish a Municipal  revolving fund  for additional remediation. The project has
leveraged  the  UEZ  Assistance  Fund,  UDAG  repayment  funds,  DEP/EDA  loans  &  grants,  and  private
developer/foundation money use to access technical and regulatory assistance.
Legal/ Re gulatory
Initiatives
The  city is working with  State agencies to restructure NJ's Industrial Site Recovery Act (ISRA) to include remedial
investigations, to restructure loan repayment terms to coincide with incremental project revenues, and to promote new
legislation to create State "Environmental Opportunity Zones."
Community Involvement
Using grant funds, the city has hired Isles, Inc., a non-profit community development corporation that coordinates and
implements much of the City's community outreach  and communication efforts.  Emphasis is placed on two-way
communication and citizen involvement through community advisory groups; and University/Federal agency/technical
institute support in risk communications.
Environmental Justice
The city's emphasis is on Brownfields sites in low and moderate income, minority neighborhoods. The sooner sites are
cleaned-up, the sooner blighted areas can be restored, depressed properties values increased, and overall quality of life
improved. The cleanup process includes training and use of local residents. Community meetings are used to engage
residents in the process, seek their input, and educate them on the nature of hazards and potential remedies. The city is
developing a green curriculum in schools; exploring green  job opportunities for local residents through community
college & state college assistance.
                                                                         C-29

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APPENDIX   C
SUMMARY   OF  PILOT  PROJECTS  ANALYZED
Pilot Project:   West Central  Municipal  Conference
Key Elements
                               Characteristics Identified and How They Contribute to Sustainabilitv
Project Scope, Scale &
Goals
For this Pilot, the goal is to select two publicly-owned sites and two privately-owned sites for redevelopment. The Pilot
created  a Rapid Response Team (RRT)  comprised of experts from the legal, environmental, real estate, community
involvement and regulatory fields.  This  team provides timely expertise and guidance  to the major stakeholders
associated with the Brownfields redevelopment process, including property  owners, developers, real estate brokers,
community members, lenders and municipal officials. The Pilot is also working to establish a Brownfields Prevention
Program (BPP) that identifies ongoing industrial activities that have the potential for creating future Brownfields.  The
BPP is also designed to create a strategy for strengthening community-municipal-mdustry partnerships to encourage
environmentally sound community development.
Community Profile             The West Central Municipal Conference (WCMC) communities are mature "inner ring" suburbs that have recently
                               experienced a steady loss of jobs and population as businesses have relocated to "greenfields" sited in more rural areas.
                               Left behind are an increasing number of abandoned and under-used industrial sites, many of which are contaminated
                               with hazardous  substances.  The WCMC is a regional organization that is comprised  of representatives from  the
                               member municipalities.
Pro gram/ Pro j e ct
Organization
The WCMC is a regional council comprised of 36 municipalities that cover a total area of 200 square miles in suburban
Cook County,  west of Chicago.  Members  of the  RRT  are  responsible  for operational  details  associated with
implementing the operational elements of this Brownfields project. They visit the property owners and follow through
with the other actions required for redevelopment of the Brownfields areas.
Site ID and
Characteriz ation
A total of four sites have been identified. The first is in the city of Oak Park and involves the conversion of a 12,000
square-foot store front style retail building into a strip mall.  The second project is a one-acre site in the Town of
Cicero; the goal is to develop a comprehensive environmental assessment and site redevelopment plan.  The third site
is an abandoned gas station in the Village of Bellwood.  The fourth site is  located in the Village of Schiller Park. The
owner of this property has offered the  property to the  village  at no cost.  However, the Village wants to perform
sampling at the site before accepting the property.  If analytical results are  found acceptable, the property will be used
for storm water retention, ponds, public parking, a street extension and other still-to-be-defined private development.
Risk Management &
Cleanup
Each of the identified properties has different contaminants, and each property poses different risks to public health
and  the environment.   As a result,  there likely will be individualized sets of cleanup procedures for the  specific
contamination situation present at each site.  The gas station building in Bellwood has been razed and plans are being
prepared for the removal of two 10,200 gallon, three 3,000 gallon  and two 560 gallon underground storage tanks.
Assessment activities, including the review of analytical laboratory  data resulting from media sampling,  have been
performed for selected sites.
Community Planning
The  Pilot has developed an outreach program that targets municipalities, businesses, civic groups  and community
groups. Other community planning activities may be associated with the internal operations of the member municipal
governments.
                                                                       C-30

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APPENDIX  C
SUMMARY  OF   PILOT  PROJECTS   ANALYZED
Site Marketing
Before a site is selected for inclusion for consideration within the project, it must have some inherent marketability,
and be included as an integral part of the redevelopment process being implemented by WCMC. Site identification is
performed by a number of outreach activities.  After identification, the RRT visits the owner to determine possible
interests in redevelopment of the property.
Redevelopment
Approaches
After sites  have been identified and  selected,  members  of the RRT interact with  property owners  and  other
organizations, as necessary, to move toward implementation of the selected redevelopment.
Technology Applications
EPA Region V used their Mobile Laboratory to conduct limited surface soil analyses to assess possible environmental
problems at selected locations within the WCMC Pilot target areas.
Project Financing
The Pilot is actively investigating alternative financing mechanisms to fund cleanup and redevelopment of Brownfields
sites.  A specific interest is identifying public sector financing methods, that hold promise for site cleanups.  Examples
include Community Development Block Grant program, Empowerment Zones and Tax Increment Financing, and the
Illinois Development Finance Authority. Through discussions with the Department of Commerce, a number of grants
were identified that could be used by municipalities for the cleanup of Brownfields properties.  Through the Economic
Development Administration's Technical Assistance Program, funds are available for inventorying potential sites,
performing market analyses, and Phase I Assessments. Pilot personnel are also working with local lending institutions
to develop  a revolving loan fund.
Legal/ Re gulatory
Initiatives
The Illinois EPA has indicated its willingness to process Brownfields sites through the Illinois Pre-Notice site Cleanup
Program.  The Pre-Notice Program allows site owners to remediate contaminated sites under the guidance of the State
agency, and receive a release from responsibility for future corrective or preventative measures.
Community Involvement
The  Pilot has developed an outreach program that targets  municipalities, businesses, civic groups and community
groups. Control and direction of the Pilot rests with the WCMC, a regional construct comprised of personnel from
the member municipal governments.  Community involvement in this Pilot's redevelopment process  is reflected to the
extent that community input flows through the member municipalities, and that input is obtained by WCMC's outreach
program.
Environmental Justice
The  municipalities  that comprise the WCMC represent a wide range  of ethnically and socioeconomically diverse
populations.   In general,  community redevelopment activities are  designed to improve  the conditions in inner-city
environments, the place where minorities and lower-income populations tend to be concentrated.
                                                                         C-31

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APPENDIX   D
PROGRAM   INFORMATION
                                      SOURCES
u -
Source
Americans for Indian Opportunity
Bank of America Brownfields Report
The Brownfields Center
Clean-start Properties Unlimited
Coalition for Healthy Cities
Center of Excellence for Sustainable
Development (CESD) Industrial
Ecology
Fink Zausmer, Brownfields Page
Global Business Network Homepage
Institute for Responsible Management
Brownfields Pilots' Database
International Development Research
Centre
National Environmental Justice
Advisory Council Homepage
in
Sponsoring Organization
Americans for Indian Opportunity,
Inc. (AIO)
BankAmenca Corporation
Carnegie Mellon University
Clean-start Properties Unlimited
Coalition for Healthy Cities and
Communities
US DOE Center of Excellence for
Sustainable Development
Fink Zausmer, PC
Global Business Network (GBN)
The Institute for Responsible
Management, Inc.
International Development Research
Centre, Canada
TetraTech EM, Inc. (as a consultant
to US EPA)
Description
Serves as a catalyst for new concepts for Native peoples. Based around
traditional tribal values, AIO promotes modern ways to help deal with
complex issues of 21st Century. Has worked with EPA to assistTnbes to
identify Brownfields on Tribal lands.
Issue papers related to sustainable development, urban sprawl,
conservation planning, private sector financing for Brownfields, and a
bibliography.
Discussion of Brownfields development, urban renewal, infrastructure and
urban sprawl issues. Detailed case study information provided.
List of available properties and characteristics, marketing information, State
Brownfields programs, special interest reports, case studies, and references.
Describes an initiative to improve health and quality of life of cities and
communities at the local level. This is done by organizing business,
government, and health sectors to address local issues and needs. Through
"www.lnvalley.org" the site includes links to community redevelopment
projects and other information about the international healthy
cities /communities movement.
This web site provides information to help communities design and
implement innovative strategies to enhance the local economy, local
environment and quality of life. US Department of Energy's Office of
Energy Efficiency and Renewable Energy created the Center of Excellence
for Sustainable Development. The site contains substantial information on
sustainable development.
Federal and State environmental laws and Brownfields related legal cases.
GBN is a unique network of organizations and individuals committed to
re-perceiving the present in order to anticipate the future and better
manage strategic response. The members host meetings, conferences and
produce and/or identify relevant publications. Through these activities
their objectives include exploring emerging trends, delving into
diverse/challenging ideas, generating collaborative thinking about the
business environment, and enhancing learning and networking among the
membership. The group also provides consulting and training services.
Comprehensive Brownfields information including site assessment,
remediation, land use/development, financial, and outreach. Pilot's
Newsletter.
Information on sustainable use, economic programs, international research,
sustainable economy and environment issues, and a catalogue of
publications.
Provides information about the efforts of NEJAC and other environmental
justice topics.
Reference
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www.prcemi.com/nejac
                                                                          D-1

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APPENDIX  D
PROGRAM  INFORMATION  SOURCES
u -
Source
Northeast-Midwest Institute
Environmental Quality
President's Council on Sustainable
Development
Santa Monica Sustainable City
Smart Growth Network
Sustainable Chattanooga
Sustainable Communities Network
Sustainable Minnesota
US Conference of Mayors Homepage
US DOE, Center of Excellence for
Sustainable Development
US EPA Brownfields Homepage
US EPA Brownfields Information
Management Database
US EPA Environmental Justice
Homepage
US EPA Region 5 Brownfields
Homepage
US HUD Habitat II ( Best Practices)
Database
Wisconsin Brownfields
World Resources Institute
in
Sponsoring Organization
The Northeast- Midwest Institute
The White House
City of Santa Monica, CA,
Environmental Programs Division
The Smart Growth Network
Chattanooga Online
Sustainable Communities Network
Partnership
ME3 - Minnesotans for an Energy
Efficient Economy
US Conference of Mayors
U.S. Department of Energy
US EPA Headquarters
US EPA Headquarters
US EPA Headquarters
US EPA Region 5
The Together Foundation and the
United Nations Centre for Human
Settlements (UNCHS)
GZA Geo environmental
Technologies, Inc.
World Resources Institute
Description
Discussion of Brownfields reuse and financing issues, economic
development, case studies of lessons learned and an overview of Federal
legislation.
Issues of national vision and policy for sustainable development,
information on the National Summit for Sustainable Development.
Provides a description of the Santa Monica Program including resources
and policies, as well as open space programs, social science, and economic
development.
Information related to eco-indus trial park development, case studies and
urban sprawl.
Extensive discussion of issues related to sustainable development and
project related information on specific Chattanooga projects.
Information on community resources, natural resources, economy,
government activity and case study data.
Discussions of energy related issues, sprawl, economic and environmental
costs of sprawl.
Collection of information from the city government's perspective.
Includes Brownfields information obtainable through the homepage's
search engine.
Sustainable redevelopment issues including: open space, TDR, land trusts,
transit oriented development, and urban forestry.
The focus of US EPA's information on the Internet relating to
Brownfields.
Computerized database of EPA Brownfields program information and
detailed summaries of each Pilot Project.
Provides information relating to EPA's environmental justice program.
Describes efforts and programs in Region 5 relating to its industrial land
reclamation program.
A searchable database containing proven solutions to common urban
problems facing the world's cities today. The sponsoring organizations
have compiled this collection of Best Practices information that has been
submitted by communities from around the world. The information was
first presented at the United Nations Habitat II City Summit held in June
1996.
Sections devoted to land use, liability issues, State regulations and
Wisconsin programs.
Topics include sustainable trade, environment and health issues, business
and environmental links Also available are portions of "World Resources,
1996-97, A Guide to the Global Environment" including "Part I -The
Urban Environment."
Reference
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www.usmavors.org/

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(Access via EPA's intranet only)
www.epa.p-ov/swerosps/ej

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www.bestpractices.org

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                                                                        D-2

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APPENDIX   E
SUMMARY  OF   AGENCY   INTERVIEWS
                           The following four sections are a summary presentation of the information that was collected for this study from primary
                           sources through interviews with selected representatives of Federal agencies, municipal governments and individual Pilot
                           Projects.  For purposes of this presentation, the original interview notes have been collected and organized under major
                           headings to correspond to specific issue areas determined to be important to this exploratory phase of the study.


                           Although the material presented here is  in the form of declarative statements, these are summary in nature and do not
                           represent direct quotations attributable to any  single individual within the group of respondents. Editorial modifications
                           have been added, where necessary, to disguise the original respondent or to  classify, condense, clarify, or  combine the
                           information under each of the headings.


                           1. Summary of EPA Sources


                           Number of respondents:    7


                           1.1   Definition of Sustainability  (Sustainable Development)


                           •    There  are two  vastly  different issues:  1)  to use  the  Brownfields Pilot Program to catalyze  and sustain the
                                redevelopment process  itself; and 2)  as a  secondary outcome or objective of the process. Brownfields should
                                contribute to the environmental and socioeconomic sustainability of the Pilot cities.


                           •    An appropriate  definition of sustainability can be found in the Brundtland Commission report; development that
                                meets the needs of the present without compromising the ability of future generations, etc.


                           •    The requirement to be  sustainable represents a potential burden on Brownfields  development, requiring a greater
                                standard that greenfields development does not have.  Brownfields do not need a higher standard that discourages
                                redevelopment and stimulates greenfields or fringe development.  Therefore, we should not measure  sustainability
                                or require it on the Brownfields property/project scale.


                           •    Sustainability should further the Brownfields effort, not hinder it by imposing strict requirements and decreasing the
                                chances  for  success.   It  should  not  become a yoke  around  the  development process, impeding  cleanup and
                                development possibilities.


                           •    There  is  a need to look  for incentives  to  encourage  reuse and  development  whether or not it is sustainable.
                                Brownfields shouldn't focus solely on sustainable reuse.


                           •    Sustainability requirements are extremely  important issues, but  they do  not necessarily always  relate to the
                                Brownfields issues.
                                                                   E-1

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APPENDIX  E
SUMMARY  OF   AGENCY
                                              NTERVIEWS
                                 There is a need to balance sustainable land use policy with the economic requirements of the community.


                                 Sustainable development implies  improved land use planning to integrate mixed use, urban growth, greenspaces,
                                 transportation, etc.


                                 Sustainable development incorporates a Smart Growth strategy.


                                 Sustainable development can be combined with other aspects of long-term planning, such as public transportation
                                 policy, incentives to develop and  use public transportation, workforce training programs, greenspace development,
                                 university internship programs, environmental cleanup, etc.


                                 The eco  - industrial  park is an example of an attempt to achieve sustainability at the project level; applying the
                                 efficiency principals  and practices of the industrial ecology model.  Eco-mdustrial parks are economically more
                                 efficient  than  the  alternative.  They tend to create interdependences among business  elements which  enhance
                                 community stability (i.e. interdependent businesses are less likely to move  if they are in close  proximity to the other
                                 businesses on which they depend).


                                 A sustainable development will provide goods and services that local people will buy at prices  they usually pay.


                                 Sustainability refers to something that reflects community desires  and values, and positively sustains and supports
                                 the community in the way in which it wants to be supported.


                                 An example of a sustainable development is found  in the Jamaica  Plains Neighborhood Development Corporation
                                 project. This project attempted to replicate the number of jobs in the community that were lost when the original
                                 industry closed.  The experience gained from the initial project was leveraged to develop additional projects, such as
                                 a multiple use center  for the neighborhood.


                                 A key element for sustainability is the need for the support of both the political hierarchy and the general public.
                                 The public push is necessary to get the political leadership committed to the project.


                                 A project does  not  necessarily require the immediate  commitment of a developer,  but it does  require the full
                                 commitment of the local government.    Sustainability hinges on a commitment by the local government to make
                                 things work.


                                 The interim use of  property may be  the best choice  for  Brownfield property in lieu  of long-term sustainable
                                 development.  Interim use is based on the expectation that funds will be there in the future to finish the cleanup, but
                                 meanwhile the site is in use and generating revenue, even though a total cleanup for residential development would
                                 not have been practical.


                                 Brownfields Pilots are a great opportunity to bring together coalitions of groups with common goals, among which
                                 sustainability is a major theme and  is incorporated into the groups'  agendas.  Sustainability is introduced to the
                                 Brownfields project through the efforts of these groups.
                                                                    E-2

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APPENDIX  E
SUMMARY  OF   AGENCY  INTERVIEWS
                           •    The basics of the Brownfields  Pilot process  are the  identification of candidate sites, assessment of potential
                                contamination, and the beginning of the redevelopment planning process.  The consideration of sustainability is a
                                part of the Brownfields Pilot Project Award application process however, most of the Pilots have not yet reached
                                the stage where sustainability is a concern.


                           1.2  Sustainability and Self-sustainability


                           •    Sustainability can be seen as a hierarchy moving from the most extreme case of self-sustamability, a long-term closed
                                loop  process at one end (e.g. an  eco-industrial park  where the waste products from  one industry are used as
                                components in the production process  of others), to  the opposite extreme of a short-term environmentally friendly
                                development (e.g.  the  business  that is  essentially environmentally friendly - not really meeting the  criteria of
                                sustainability - but operating in an environmentally sound way) at the other end.


                           •    The Brownfields  sustainability approach should be: first do  no harm; then the further  up  the continuum of
                                increasing sustainability we can move from there, the better.


                           •    It is necessary that all projects eventually become self-sustainable through  a local government - private  enterprise
                                partnership structure.


                           •    Ideally, the Pilots would maximize leverage of the Federal government's involvement and  funds to develop a project
                                and then strive for  "self-sustainability."


                           •    The Federal role should  serve to change the dynamics of the  process and then be withdrawn. The  Federal "Big
                                Brother" notion dooms a project to failure.  The Brownfields Program should be able to go out of Business in 5
                                years in favor of sustaining private development and local control.


                           •    The level of project sustainability will vary according to the level of government input required.


                           1.3  Conceptualization of Brownfields Initiative


                           •    Chicago began the Brownfields  process  when  it conducted a large  forum on the Brownfields issue.  They were
                                essentially looking for something creative to address the urban blight problem.  The political structure of the city put
                                the force of commitment behind the program, and the  municipal government issued bonds to finance Brownfields
                                identification and assessment efforts. This effort really spawned the Brownfields concept.


                           •    Brownfields  is a different program model and it is not completely defined. The paradigm is still being assembled in
                                a pattern that is different  for every community.


                           •    Every project is so unique and the available resources (especially funds) are so fractionated that each project has to
                                develop its own distinct approach and there is little similarity between them.


                           •    The Brownfields process  is very different from the approach common to superfund sites.  Brownfields is  more of a
                                "removal" exercise, (i.e., not a single process or strict procedure, but rather an assortment  of processes and measures
                                to be taken as various situations arise).
                                                                    E-3

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APPENDIX  E
SUMMARY   OF   AGENCY   INTERVIEWS
                                 The Brownfields process is an iterative one - unlike the more straight-line superfund approach - where key elements
                                 interplay as the situation develops.  There are a number of parallel processes involved; all of which are going on
                                 simultaneously during a project.


                                 The Brownfields process uses a different paradigm; it is a locally driven initiative. The funding is distributed by the
                                 Federal government to help  initiate or catalyze the process, but control remains with  the local jurisdiction  to
                                 determine the desired outcomes.


                                 The  community's  influence  on the Brownfields  process can include the community's master planning, zoning
                                 decisions that dictate outcome, stipulations of the community, and the determination of the extent of contamination
                                 and the appropriate level of cleanup.


                                 There is a need to reduce the perception that Brownfields are a Federal problem because of CERCLA liability.


                                 Brownfields are simply a particular type of  real  estate development.  As  people get more sophisticated about
                                 contamination assessment and cleanup, the fear of liability can  be overcome.


                                 Don't think of Brownfields only in terms of their own context, but in the greater context of economic development.


                                 Brownfields sites can  be  conceptualized according to a matrix that characterizes two  criteria:  1) the  extent  of
                                 contamination, and 2) the  inherent redevelopment potential, or marketability of the  site. The matrix establishes two
                                 polar extremes with high contamination sites in a bad market environment at one end, and marginally contaminated
                                 or low contamination, good market potential  sites at the other end.  The remaining boxes in the matrix represent
                                 varying levels of contamination combined with different degrees of marketability and represent approximately 80%
                                 of all of the sites that might be considered. Each box in the matrix has a different general strategy attached to it.
                                 The matrix, when plotted, forms an approximation to a bell curve.


                                 There are three categories of property: 1) sites that would be  developed anyway because of some aspect or quality
                                 like a waterfront; 2) sites that, but for a concerted effort, would not normally be redeveloped (strategic sites), and 3)
                                 the remaining sites that have little or no prospect for development (95% of all sites).


                                 It is essential to understand the real estate market; to match the right property to the right development use, and to
                                 know what catalysts are needed to stimulate development of the project.


                                 There may be good reasons  to invest in an individual property despite conditions  of site contamination or other
                                 marketability considerations.  A property may be  important,  not because of the quality of the property itself, but
                                 because it is centrally located or is part of another parcel that, when combined, collectively becomes important.  It
                                 also  may be important to  the redevelopment  of other  neighboring parcels, or other parcels  in the greater
                                 neighborhood.


                                 The EPA program is there to create the initiative; however, it  is also necessary to let the local communities take the
                                 program lead and run with it through completion.
                                                                    E-4

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APPENDIX   E
SUMMARY  OF   AGENCY   INTERVIEWS
                           •    Education of the public is the key to helping local government bodies understand that if the site is not on CERCLIS
                                and doesn't pose an immediate removal problem, then EPA is not interested.  The entire problem can be handled
                                locally without EPA intervention.


                           •    The  Brownfields program  represents an opportunity  to expand  the  collaboration  of the  multiple, varied
                                governmental agencies that are involved in urban redevelopment.


                           •    The program affords the opportunity to level the development playing field between the urban center and the urban
                                fringe.


                           1.4  Key  Brownfields Program Elements  and Objectives


                           •    The goal is  to minimize the Federal  role and involvement in Brownfields cleanups.  The objective is to  keep
                                Brownfields projects as local solutions.


                           •    EPA's role is to demonstrate the environmental benefits of Brownfields.


                           •    Government funds are there as the impetus, but continued support and control  of the  project is the responsibility of
                                the city or the municipality.


                           •    The goal is to shift the breakpoint from a reliance on public investment (or minimized funding) to a point where the
                                free-market forces can take over.


                           •    Credibility is a key issue.  The Brownfields Pilot Programs need to create an immediate (less than 5 years) success to
                                be noticed and to develop credence, but at the same time, the program requires  a long-term plan (more than 5 years)
                                in order to be fully successful.


                           •    A key element is the perception or fear of contamination.


                           •    The context of the site is a key factor and is specific to each site individually.


                           •    Risk communication to the public is a key issue.


                           •    Some examples of key technical elements of the Brownfields projects would include: the size of the property (large
                                lots are required for manufacturing uses), the level of contamination present, and the determination of appropriate
                                reuses of the site.


                           •    A primary social concern is the retention  of the  existing character of the neighborhood (i.e. don't drive out the
                                original residents).


                           •    The community goal is typically to create jobs by bringing in new business that is environmentally sensitive (green
                                companies) or at least regulatory compliant industries.
                                                                   E-5

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APPENDIX   E
SUMMARY   OF   AGENCY   INTERVIEWS
                           1.5  Brownfields Project Organization
                           •    Projects depend heavily on the presence of a strong Working Group, Advisory Group, or Steering Committee. This
                                allows all participants and stakeholders to be represented and sitting together under one structure (e.g. chamber of
                                commerce,  community groups, grassroots  groups, banking  organizations,  state agencies,  Federal Brownfields
                                program, and city groups or local committees.


                           •    The Brownfields program is a very grass-roots effort and is  very dependent on the  personalities of the people
                                involved.  The program requires the successful involvement of a number of people in the community to make the
                                program work.


                           •    Important stakeholder groups include: city officials, scientific and technical personnel, and someone to translate the
                                scientific and technical results to the community groups.


                           •    Local politicians and government bureaucrats need to define their  roles with respect to the project  and their
                                constituents.


                           •    Example:   The  Birmingham Pilot is unique in the way they tied the Brownfields  Program together with other
                                Federal/state/community assistance programs  (i.e., HUD Empowerment Zones); under a single city department
                                manager/coordinator; and minimized many of the bureaucratic problems that other projects have faced as a result of
                                different city departments  having responsibility for different economic aspects of the project.


                           •    Example:  The Pnchard Pilot tied together  superfund  and health, and water issues as  well as academics from the
                                local  area to build a unified  project.   The perspective here is to see that Brownfields are  one  element of a
                                comprehensive puzzle for urban area revitalization.


                           •    Example:  The Charlotte Pilot is emphasizing the financial industry tie-in by putting together a number of national
                                banks  to create  a sympathetic  consortium of banks that  understand the potential for development, Brownfields
                                redevelopment issues, and the unique funding needs.


                           •    Example:  The Atlanta Pilot has had some success combining Empowerment Zones with  the Brownfields Program.
                                They are working to increase ties to other city programs.


                           •    Example:  The Chattanooga Brownfields effort has had some success with tie-ins to the business community and
                                especially to the TVA.


                           •    Example:  The Knoxville Pilot  has remained focused on just the downtown district itself.  This has been a plus for
                                the success of the project.


                           •    Example: The Rhode Island Pilot master planned the downtown development of Providence.


                           •    Example:  The New Orleans Pilot is utilizing a community involvement model.
                                                                   E-6

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APPENDIX  E
SUMMARY  OF   AGENCY   INTERVIEWS
                           •    Example:  The Niagara Falls Pilot, one of the newest, has  focused on the process of public awareness and public
                                education.


                           1.6  Distinction Between Urban and Rural Brownfields


                           •    Urban sites are much more connected and vulnerable to what happens in the surrounding region then are rural sites.
                                They tend to be more fragile in terms of the influence of the surrounding context, even when the contamination is
                                removed.


                           •    The stability of the surrounding communities  (neighborhoods)  is not as guaranteed in urban areas.  What may be
                                there now could easily change into something undesirable at a later time. Rural areas tend to be more stable.


                           •    Urban sites need a regional strategy for successful development - regional in the sense of looking at more  than just
                                the site itself.  There is a need to consider the entire area or region  around the site.  Bridgeport for example, has
                                been successful in attracting businesses  back into the city because they are taking a regional, multi-site approach.
                                The sites are viewed as interdependent.  They are also dealing with small parcels; the idea of assembling small parcels
                                gives the developer more acreage to deal with and makes the site more marketable.


                           •    The two types of projects are completely different; all of the important elements are changed: 1) there is less public
                                opposition to development in rural areas; 2) taxes are higher in the city; 3) the process to get development approved
                                is subject to more requirements in the city as opposed to the suburban fringe, usually a much speedier process, and
                                the  rural  "greenfleld"  represents  the easiest and  fastest  of the three;  4)  most  cities  have antiquated zoning
                                restrictions; and 5) local governments are less willing to subsidize redevelopment in the center city, but will accept
                                extensive local subsidy for new development on the fringe.


                           •    The key to urban Brownfields is that urban businesses are generally not large and their needs are vastly different than
                                suburban industries.


                           •    Small, urban businesses generally do not have the resources to address contamination issues.


                           •    Banks do  not like to  lend money  to small  businesses moving into  potentially contaminated areas or particularly
                                undesirable parts of the urban environment.


                           •    Typically, improvements to inadequate or antiquated urban infrastructure are not subsidized while new infrastructure
                                in rural or fringe areas can be subsidized as part of the total development.


                           •    The nation is predominately urban, but there are  some small communities that  also represent good Brownfields
                                candidates.


                           •    The difference between the two is not really tied to the size (acreage) of the project, but is more related to  the level
                                of resources available at the local government level.


                           •    For the most part, rural governments  do not have the infrastructure that larger metropolitan governments have.
                                                                    E-7

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APPENDIX  E
SUMMARY  OF   AGENCY   INTERVIEWS
                           •    State projects, such as Rhode Island and Maine, are set up in areas where the rural infrastructure is inadequate, or to
                                take advantage of a state level capability that is not available in the smaller cities, such as marketing potential.


                           1.7  Brownfields Redevelopment Strategies


                           •    The process starts with a well-defined problem; the important issues will develop from there.


                           •    There should be an emphasis on development strategies based on interconnected greenspaces in the urban center
                                and across larger urbanized areas.


                           •    The process also  needs to be  focused on improved development in the  suburban fringe as well as in the urban
                                center.


                           •    A primary concern  is with the effect of land use and development patterns on environmental quality and land
                                consumption.


                           •    Open space development can be an inducement to other kinds of development. Open greenspace and parks  are
                                missing in the urban center; a park in the right location can enhance surrounding property values.


                           •    Normally public taking is used as a last resort; cities do not want to take on the additional liability.


                           •    Use of public taking could give the impression that getting involved with the program will result in a public taking
                                and would tend to discourage owners from wanting to become involved.


                           •    Use of public  ownership methods such as taking  (for tax arrears, addressing public health threats, and property
                                consolidation), outright public purchase, or some joint pub lie-private holding is a preferable strategy.


                           •    Bridgeport, in a few instances, used a strategy that involved the owner demolishing the  structure and conducting a
                                cleanup, then transferring ownership to the city for $1. This transfers the liability allowing the  owner to remove a
                                contaminated site from his inventory (normally an already depreciated site).  Advantages accrue to both the owner
                                and the redevelopment program.


                           •    Subsidized development occurs in the suburban fringe but is absent from the center  city.  The older city structure is
                                assumed  to  have  an  infrastructure advantage, but often,  the  center city infrastructure  is  not sufficient to
                                accommodate modern construction (lot size, sewer hookups, telecommunications, etc.). Cities  are often  not as
                                willing as suburbs to subsidize infrastructure.


                           •    The public (or community) needs to be  aware  of the proposed future vision and  the overall impact  of  the
                                development plans.


                           •    It is important to build exchanges with other cities (especially internationally).


                           •    Infill development can be more sustainable than greenfield development because of improvements in transportation
                                and transportation related impacts.
                                                                   E-8

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APPENDIX   E
SUMMARY   OF   AGENCY   INTERVIEWS
                           •    There is a need to concentrate on  developing more incentives  and trade-offs to encourage Brownfields  in-fill
                                development (for example, create Clean Air Act credits for Brownfields in-fill development).


                           •    Supplemental Environmental Projects (SEPs) are special  agreements among EPA, DOJ and responsible parties to
                                reduce non-compliance penalties by  taking other "positive actions."  These can be a mechanism to stimulate and
                                fund Brownfield site assessments, but cannot be extended beyond  the assessment phase.  A good example of a SEP
                                is the Sherwin-Williams agreement by which the fine to Sherwin-Williams was reduced by its commitment to pay for
                                Brownfields environmental testing and cleanup of a former foundry site.


                           •    The extensive construction of greenspace and community gardens can be important as interim uses development.
                                One example is the Project for Public Spaces in New York City.


                           •    At least half of the current Brownfields  Pilot Projects have a waterfront element.  This is considered an inherently
                                valuable feature.


                           1.8  Incentives to Stimulate Emerging Technology


                           •    The vast majority of sites  are relatively small and are owned by small to medium sized businesses that do not have
                                the resources  necessary to characterize  the  sites  and address the contamination. As  a result, there is  a push to
                                seriously consider using field screening methods that are less costly and would allow businesses to get an idea of
                                what is there so that they could make sound business decisions on how to proceed.


                           •    It is important to try to find matches between the cleanup  technology employed and the business uses proposed.


                           1.9  The New Urbanism Concept


                           •    The New Urbanism incorporates the general belief that the built environment does not have to be unsustainable.


                           •    There is a greater tolerance  for new approaches to property development; the merging of environmental policies
                                with spatial development policies is a key element.


                           •    The primary question for development is: How do we reintegrate this piece of geography back into the society?


                           1.10 Strategies to Attract Business  to  the Urban Gore


                           •    It is a difficult process to identify and induce  green businesses to come into Brownfields areas.


                           •    Demographic  change  represents an opportunity to redevelop  inner city  neighborhoods.  As  the  American
                                population ages, the baby  boomers get older, and their children grow up,  there will be a tendency to want to  move
                                out of the suburbs which are less friendly to older people and less convenient or desirable.  In the urban center, daily
                                life services  are closer and more accessible by foot. In New York City for example, there is less need for retirement
                                homes  - older people can live well  into their  later years and still function without assistance  because necessary
                                services are close at hand.
                                                                   E-9

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APPENDIX  E
SUMMARY  OF   AGENCY   INTERVIEWS
                           •    Andreas Duary addresses the issue of what cities can learn from the suburban development experience that will help
                                in developing new strategies.  Some examples include the need to raise standards in the urban core - to reflect new
                                social conditions found in the suburban fringe; the employment of modern management techniques; the recognition
                                of changing cultural conditions or standards (i.e.,  lifestyle, convenience, transportation, recreation, etc.), and the
                                need to emphasize a pedestrian orientation - the advantage the city has over the suburbs.


                           •    One possibility is to consider trading clean air act credits among various industries.


                           •    Michael Porter in the Competitive Advantage of Center Cities emphasizes attractions such as  sports, amenities, arts, and
                                education that are found in center cities.


                           •    There are also funding opportunities available to cities that are not available to the suburbs such as Section 108 loan
                                guarantees, ISTEA, CMAC, and the Community Reinvestment Act.


                           •    Todd Zimmerman describes three categories of people moving into the center city: 1) the Risk Takers (young, new
                                college  graduates, the arts community, the gay community) who are the first to move into a decayed urban area; 2)
                                the Risk Aware  (more middle class and young urban professionals with middle class orientation) who  follow-on as
                                the second  wave of in-migration;  and 3) the Risk Averse - more settled, older Middle  Class  (dentists, doctors,
                                lawyers, etc.) move in finally and the first group  moves out. The marketing requirement is to find out what attracts
                                these individuals and groups.


                           •    Not all  green businesses are especially aesthetic additions to the local community; for example, a recycling plant does
                                create jobs, but it is not necessarily an attractive addition to a community.


                           •    Everyone's preference is to locate a pristine company in the new development.


                           1.11 Approaches to International Exchange


                           •    Multiple examples exist to contend with the opinion that the U.S. is too advanced to learn anything from foreign
                                countries and that foreign approaches can be successfully transferred to U.S. Cities.


                           •    Realistic policy interaction with other countries is possible and is  especially useful for developing new ideas in areas
                                such as  labor retraining.


                           •    The ICMA is preparing four case  studies  of European Projects  including the Westergasfabnek in  Amsterdam,
                                Emscher Park outside  Duisburg, Germany,  the Toronto Waterfront Redevelopment, and the Groundwork Trust
                                Project  in Birmingham, UK.


                           •    A key source of information is found in the work of E. Verhagen, especially on the Westergasfabnek.


                           •    The most probable impetus  for a more advanced development of these concepts in Europe is a greater and more
                                immediate land use  pressure that forced consideration  of alternatives. This required the definition of a broader
                                context and the creation of a holistic approach to reintegrate Brownflelds properties into the  community.  The
                                                                  E-10

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APPENDIX   E
SUMMARY   OF   AGENCY
                                              NTERVIEWS
                                European communities have been able to harmonize their industrial and spatial development policies to a greater
                                extent than in the US (i.e. planning goals  focused on environmental concerns and mixed use zoning to support
                                transportation corridors and open "green" space).  State structures, cultural environment, and regional planning also
                                factor into this development.


                           •    The "Best Practices" approach can be successfully translated from European Projects to the U.S.  Some examples
                                include: Cape Charles, VA which is applying best practices concepts learned from its experience with several foreign
                                projects  and  has incorporated the  eco-mdustrial  park concept that was  first developed as a  part  of the
                                Westergasfabnek project; and Portland, OR which has developed a sense of place through harmonized land use
                                management and social practices, and by integrating environmental  concerns and land use policies into the
                                community planning process as a whole.


                           •    Some  examples of potential  international  partnerships between cities  include:  Portland, OR and  the  German
                                Emscher Park project, and the Toronto Waterfront and Baltimore Inner Harbor Projects.


                           •    The most common theme throughout international development planning is interconnected greenspaces to protect
                                riparian and other environmentally sensitive areas.


                           •    Capital funding for many European projects comes from a kind of mim-superfund trust for site assessment and
                                remediation administered by the individual States.


                           1.12 Community  Awareness.  Understanding  of  Health  Risks,  and  Acceptance  of  Cleanup

                           Options


                           •    Many of the Pilot Projects have not yet reached the point of establishing cleanup standards.


                           •    The community as a whole should be involved in cleanup decisions when they are made.


                           •    In those cases where the city has not identified the high profile sites, a public advisory group (committee) is formed
                                to develop screening criteria and identify the high priority attributes.  The committee then reviews the candidate
                                sites according to these criteria and selects those to be recommended as the highest priority.


                           •    Some criteria that would be useful to pnontization include marketability, contamination, and proximity to other high
                                profile sites.


                           •    Familiarity is one important element. When people have lived next to a site for ten or twenty years, it tends to make
                                the site seem less of a threat.


                           •    With a Brownfields project, people automatically start considering the potential for jobs and health issues  tend to
                                become less important.


                           •    The level of concern for health issues in a Brownfields Project is generally less than for superfund sites.
                                                                  E-11

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APPENDIX  E
SUMMARY  OF   AGENCY   INTERVIEWS
                           •    It is important to tie the cleanup levels to proposed future land uses to overcome differences between stakeholder
                                groups on the level of cleanup.  Communities will sometimes opt for a less than perfect environmental outcome in
                                trade for a more positive economic outcome.


                           •    There is a need to demonstrate a commitment on the part of the city, State, or Tribe (these are the only entities that
                                can  apply for  a Brownfields Grant)  to clean up  and then redevelop  the  site  with environmentally responsive
                                businesses that will not continue to contaminate the surrounding area.


                           •    The local populations are apprehensive that once  the original  source of contamination has been removed, the
                                redevelopment of the site may result in a new source of contamination.


                           1.13 Risk Factors and Indemnification


                           •    The focus is on the redevelopment of contaminated land versus the requirement to cleanup to unrealistic  levels.
                                This requires the community to have greater risk acceptance levels based on an understanding of comparable risks.


                           •    When the Phase I and Phase II assessments are completed, there is a need for someone to explain the assessment to
                                the public at large; a need to explain what has been done. It is  up to the city to translate the results to the business
                                and the equity market communities.


                           •    One critical requirement is that there must exist, within the stakeholder community, the capability to clearly and
                                simply communicate risks to the public without raising undue hopes, expectations, or fears.


                           •    Institutional  controls  may  be  required to  address future  (long-term) liability due to contamination.  There  is
                                however,  a question of the next developer or owner recognizing the prior containment  strategy,  and having
                                sufficient funds to address the contamination;  otherwise it may simply be ignored.  Any  strategy must provide for
                                permanent disclosure.


                           •    There are currently seven  different policy initiatives to deal with  insurance.   The question is what types of
                                indemnification does the municipality require, or  offer.  There will always be  some  risk unless you move  to a
                                permanent deed/zoning strategy.


                           1.14 Community Involvement


                           •    The community cannot be allowed to be the sole driver in the Brownfields process.  A high community priority site
                                may not necessarily be a highly marketable development priority.


                           •    It is important to help the community understand what the developers needs may be.  Likewise, developers vary in
                                their degree  of sensitivity to community  attitudes  and desires;  some recognize  the  benefit of early community
                                involvement to prevent added costs or delays.  Such costs and delays  are usually the  result of late community
                                involvement that typically results  in community opposition to the  project.


                           •    The preparation of an application  for a Brownfields Pilot  grant  forces groups  within  the community to  come
                                together in order to address the requirements of the grant application and write the grant itself.
                                                                  E-12

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APPENDIX  E
SUMMARY  OF   AGENCY   INTERVIEWS
                           •    Community pride is definitely a motivator for local community group involvement.


                           •    The personality and commitment of local people  is reflected in a focus on the  desired outcome, as opposed to
                                simple process oriented enumeration.


                           •    Participation by groups with agenda other than redevelopment can place too many requirements or expectations on
                                the process - becoming an impediment.


                           •    Local  partnerships are  critical for effective  communication, community endorsement,  and  the location  and
                                identification of resources.


                           •    It is important to make certain that realistic expectations occur from the outset of the project.


                           •    Some  developers who  have had tremendous success working with  communities,  seem  to  want  community
                                participation, and will consider the needs of the community. They recognize that there is an advantage to becoming
                                a part of the local community.


                           •    One of the qualifying criteria for a Brownflelds program grant is that the project demonstrates community support
                                and participation. This means that Brownflelds Pilots usually have serious community involvement as a part of their
                                plan. We would not expect to find a lot of community opposition.


                           •    If the  municipal government leaders  see that the  proposed plan is  the result of some communication with and
                                involvement of the local community then, they are more inclined to support it.  Otherwise, it simply gets lost in the
                                bureaucracy.


                           •    It is necessary for the public to express its support in order to stimulate local government officials to further the
                                plans and interests of the project.


                           •    The local politician is responding to a need to get reelected. He is more likely to address the immediate concerns of
                                local business (such as tearing down a building or building a parking lot next door)  than to respond to a Brownflelds
                                Master Plan that has no public pressure behind it with proposed results that will not be evident for several years.


                           1.15 Environmental Justice


                           •    The concern for environmental justice has spurred the formation of public groups that have provided input to the
                                Brownflelds project planning process.


                           •    The basic idea  is that communities should have a say in what is to be done in their area and that communities should
                                be involved before any decisions are made.


                           •    The most serious problem  is convincing investors  and developers that the  environmental justice community has a
                                legitimate claim to being included in the development project.
                                                                   E-13

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APPENDIX   E
SUMMARY   OF   AGENCY   INTERVIEWS
                           •    Attention to environmental justice issues is seen as a hindrance to the development process.


                           •    EPA has  established the National Environmental Justice Advisory Council to assist the  States, regions, and local
                                projects with the important environmental justice questions.


                           •    A primary concern is  that Brownfields is viewed by the community as a "Big Government" or  "Chamber of
                                Commerce" move to create new business without regard to the specific needs or concerns of the local community.


                           •    There is a concern that a new company will move in replacing a previous  company that abandoned the Brownfields,
                                but there will be no change to the quality of life for the residents of the immediate community.


                           •    Gentnfication may not be of as much concern as everyone makes it.  We should be more  concerned with the rapid
                                loss  of middle  class population  in urban areas. It was the middle  class that was  there in  the first place, when the
                                urban core deteriorated and the  lower income neighborhoods replaced them. The city needs the surplus income of
                                the middle class to support other enterprises in the central city. The effort should be to establish mixed use, mixed
                                income developments that will encourage the middle class back into the city and provide for lower income residents
                                already there.


                           1.16 Barriers to Brownfields Development


                           •    The perceived or real threat of CERCLA liability represents an important barrier to Brownfields development.


                           •    A lack of awareness  (on the part of municipality and private  property owners) of  the process  involved in
                                determining if a site is on CERCLIS.


                           •    For TSD facilities, the inability to segregate portions of a site for sale, lease, or transfer for redevelopment.


                           •    Racial conflict, especially over neighborhood gentnfication is an important factor.


                           •    The absence of relevant Brownfields legislation is a major barrier.


                           •    The absence of innocent landowner and  prospective purchaser protections are a major problem for  Brownfields
                                development.


                           •    The absence of statutory liability release poses the greatest barrier to Brownfields redevelopment.


                           •    A lack of legislation is a major barrier to the development of the revolving loan fund.


                           1.17 Legislative and Regulatory Issues


                           •    Unknowing landowner defense legislation is currently being drafted to provide innocent landowner liability waivers
                                or hold harmless covenants that will be important to Brownfields redevelopment.
                                                                  E-14

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APPENDIX  E
SUMMARY  OF   AGENCY   INTERVIEWS
                           •    EPA is just beginning to look at contiguous landowner protection in the context of Brownfields redevelopment.
                                The key is defining innocent landholder liability and contiguous (neighbor next door) issues.


                           •    The CERCLA (Superfund)  enforcement perspective involves a two-tiered approach consisting of: privately funded
                                assessments and cleanup; and Federally funded cleanup with subsequent cost recovery action.


                           •    Congress has not really dealt with the indemnification issue directly.


                           •    The current CERCLA liability scheme is not going to change (i.e., the owner is liable).


                           •    EPA has interpreted CERCLA as allowing  for the reduction of a site into operable units that can be addressed
                                separately. As cleanup of operable units is completed, the size of the site can be reduced. This is not possible under
                                RCRA.


                           •    The Superfund program is being adapted to address Brownfields by allowing flexibility in the areas of "total
                                enforcement" and "cost recovery."


                           •    New tools  available to the  Brownfields program include  Comfort/Status Letters and Prospective Purchaser
                                Agreements  (PPAs).  EPA Comfort Letters  can  serve  private parties  better than State Voluntary Compliance
                                Agreements.


                           •    By definition, RCRA only applies to operating or closed TSD facilities, and therefore most Brownfields would not
                                be subject to RCRA requirements. Exceptions would involve "clean closed"  sites, and Generator and Transporter
                                sites that are not "clean closed" and have minor contamination.


                           •    The most common RCRA  problem at Brownfields sites is leaking underground  storage  tanks (LUSTs). These  are
                                best addressed at Genera tor/Transporter sites through State Voluntary Compliance Programs since States typically
                                enforce waste oil.


                           •    Forty States currently have  Voluntary Compliance/Cleanup Programs (VCPs).   Minnesota is believed  to have the
                                most comprehensive and progressive of these programs. The VCPs offer flexible  covenants for lenders.


                           •    An important aspect is the consideration of what aspects of Federal policy are actually contributing to the formation
                                of Brownfields or increasing urban sprawl. There are several ongoing efforts being directed at the identification of
                                these policy or regulatory issues.   One  example is that the cost of permitting rises in non-attainment areas, thus
                                greenfield areas (more likely to be in attainment areas) are  less costly and more  attractive to developers. Another
                                illustration can be  found in the  use of Federal dollars to fund highways in urban areas.  This  tends  to facilitate
                                commuting from longer distances and increases sprawl development in the suburbs.


                           1.18 Brownfields Success Criteria


                           •    Because every Pilot has its own objective  and strategy, it is difficult to  establish a single measure  of success.
                                Concrete  measures, such as the  number  of  sites turned around, the number of new jobs created, the number of
                                public groups involved, or the extent of public acceptance are usually preferred.
                                                                   E-15

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APPENDIX  E
SUMMARY  OF   AGENCY  INTERVIEWS
                           •     The most important factor is the project manager for the municipality.  There is a need for a strong manager who
                                 can move the process along.


                           •     The municipality needs a good understanding of what it is going to do,  what barriers may exist, what resources are
                                 required to accomplish the plan, and what resources it has available, especially funding.


                           •     A comprehensive plan is essential including a strategy for how the property will be used, how to market it, and how
                                 to identify prospective new owners.


                           •     The project is likely to fail unless all necessary components, especially funding, are anticipated and addressed early in
                                 the process.


                           •     Ultimately, it comes down to finding the money and involving the community.


                           •     Successful communities promote mixed-use  development, pedestrian oriented development, the concept of the 24-
                                 hour city, and are able to tap into emerging fields in Real Estate.


                           •     The use of an advisory council or advisory board,  or a Brownfields working group that represents the community of
                                 interest associated with a project is thought to be highly correlated with the success of a project.


                           •     For success, there must be local motivation, technical capacity, and environmental and financial awareness.


                           •     Strong marketing skills and strategies are needed to develop the rationale  for why if s important to a business or
                                 industry to move back into the urban center.


                           •     The  developers who are brought in must  not have  or propose  businesses that will contribute  further to the
                                 environmental or socioeconomic problems of community.


                           •     The role  of risk communication is critical to the success of the Brownfields project as  it relates to the  participation
                                 and acceptance of the public of the proposed plan.


                           •     Local project  leaders need to  address  the  community  leaders and  discuss the results of their efforts  and the
                                 proposed plan.


                           •     The community often has larger expectations for  Brownfleld project outcomes.  These are driven by concerns with
                                 high levels of unemployment, aesthetics, quality of life issues, crime,  and  safety. These often reflect the  community's
                                 differing view of "environment."


                           •     The  community needs to understand the reality  of the  situation  in order to  avoid  developing false hopes  and
                                 unrealistic expectations for the project outcomes.


                           •     Realistic expectations are a key to making the whole process work.
                                                                   E-16

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APPENDIX   E
SUMMARY   OF   AGENCY   INTERVIEWS
                           •    There is a need to get the private funding right up front and not wait or depend on public funds and grants.


                           •    The Federal funding of a Pilot is seen by the development and investment communities as the good housekeeping
                                seal of approval; it demonstrates the "value" of a given project.  Other sources of support may become available to a
                                project because it has been designated as a Brownfields Pilot.


                           1.19 Weaknesses in Brownfields Projects - Failure  Indicators


                           •    The greatest weakness in the existing program, from a Federal perspective, is that many people feel Brownfields is a
                                superfund program; and the superfund program people feel that it is just another initiative that gets in the way.  It is
                                important to see Brownfields as a comprehensive, multi-media, compliance development program and not just as a
                                superfund cleanup program.


                           •    A serious drawback  is  the prevalence of limited project resources, unfunded government mandates, and differing
                                agendas among the various agencies and stakeholder groups. The $200,000 grant sounds like a lot of money, but this
                                is not sufficient to actually accomplish the program.


                           •    The Brownfields effort requires time to develop and this  contradicts the need to achieve a quick success that will get
                                public  and developer attention. There  is a reason that Brownfields have become Brownfields and this process has
                                taken place over a long period of time.


                           •    Political pressures can cause a tendency to go for the immediate advantages of a quick fix rather than to a long-term,
                                integrated plan.


                           •    The programs should be based on a five-year plan, this allows time to develop the property and determine if there is
                                any real interest.   This interest is developed over a longer period of time, not in the short-term.


                           •    The  potential benefits (i.e., CAA credits, CMAC environmental enhancements,  etc.)  are not  really  obvious in
                                Brownfields development. The inability to identify the environmental benefits of Brownfields redevelopment could
                                be the Achilles heal of EPA's Brownfields Initiative.


                           •    The project is spending a fair amount of money and not meeting milestones; no productive outcomes.


                           •    Public participation starts falling away.


                           •    In one example, the project fell eight months behind schedule and now the business community is beginning to
                                have questions.  The EPA regional office is getting calls from the financial supporters and private development
                                community looking for reassurance that the project will proceed before they are willing to put any additional money
                                into the project.


                           •    A number of cites have become overly focused on the EPA Brownfields Pilot Program and continue to resubmit
                                applications.  Some  of these  municipalities have taken no action without the EPA grant, even though they have
                                already identified Brownfields properties.  Communities must address Brownfields problems  whether or not they
                                receive an EPA grant.
                                                                  E-17

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APPENDIX   E
SUMMARY  OF   AGENCY   INTERVIEWS
                           •    Pilots  don't  adequately  establish  relationships  between  local project  leaders and  EPA.  This represents  a new
                                relationship for EPA - EPA previously dealt with the state level.


                           •    A number of programs use outside consultants who are not familiar with the community and, using a standard pre-
                                written format, fail to capture the necessary qualities and address the criteria required for a successful program.


                           •    Unrealistic expectations among community groups and local politicians.


                           •    Projects  often miss a lot of available money through failure to look  for other funding sources such as real estate
                                development loans or accessible transportation money.


                           •    There is  a need to attract outside investors in groups to assure the continued success of the project.


                           •    One major source of weakness is that projects  fail to understand and apply basic real estate fundamentals.


                           •    The states do not have the money  or the resources to hand-hold the local efforts or to create new incentives;  so, the
                                local project is faced with abandoned properties and pressures for a quick turn-around.  The states need to provide
                                support through broad economic development programs, tax incentives, etc.


                           •    For the local community, the problems are centered around developing ways to sustain the development process,
                                once it has been started.


                           •    There  is apprehension that no matter what the history of the site, the site  assessment and cleanup will result in
                                greater problems and costs than  developers  are prepared  for; and therefore  developers  tend to  shy away from
                                anything other than new greenfield development.


                           •    Potential developers assume that no matter what the site history, there could potentially be a problem. The fear is
                                that something will spring up and  cause problems at some later time,  even if the property is found to be minimally
                                contaminated.


                           •    Especially in the southeast US,  the perception of contamination and public safety concerns  pose the greatest barrier
                                to any kind of development.


                           •    The general position of potential developers is that it is better not to  address this particular property - because if I
                                do it's going to cost me big time.


                           2.  Summary of Non-EPA Sources


                           Number of respondents:     5
                                                                  E-18

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APPENDIX  E
SUMMARY  OF   AGENCY   INTERVIEWS
                           2.1   Definition of Sustainability (Sustainable Development)


                           •     Sustainability is linked to  the culture and history of the community.  Sustainable development must be based on
                                 community involvement.  It should reflect the values and principles of what the community wants - at all levels.
                                 The tie  between the community environment and sustainable  development helps  the project "stand the test of
                                 time."


                           •     A sustainable community or a livable community obviously requires that you provide jobs, education, security, and  a
                                 place where people can get services. There is also  a need to provide recreational  resources, including historical,
                                 cultural and natural resources; therefore greenspace plays a major role. These are necessary factors to draw people to
                                 the community and make it a place where people want to live.


                           •     There are two keys  to Sustainability: 1) a good  environmental baseline survey (EBS), and  2) the buy-in  of the
                                 regulatory agencies and the local community.


                           •     Standard economics is unable to value and portray the sustainable community because economic models  are overly
                                 driven by cost measurements. Sustainability must include social, cultural, aesthetic, ecological, and other values.


                           •     A small informal hands-on project may not seem like much, but it creates a social structure, vision, and commitment
                                 from which sustainable communities can evolve. For example, most urban areas have a run-off problem - the more
                                 greenspaces, the less  runoff- so clearing and planting vacant lots, even though a very small project,  is actually doing
                                 something to contribute to longer-term Sustainability.


                           •     It is necessary to accept that  there are groups within the community that  will understand  that  they have to do
                                 something - but then do something small (e.g. use greenspace as an interim measure).  If you  get some people  who
                                 want to  do something,  however small,  then you  have, in effect, created  a grass roots movement  and that can be
                                 sustainable.


                           •     A sustainable  project depends  on  the degree to which Brownflelds is integrated with other issues to  affect the
                                 Sustainability of the community on a broader basis.  Some communities are sophisticated enough to do  this —  they
                                 key in on a critical mass of intelligent people, worklife issues, greenspace, job creation and transportation.


                           •     The perspective  is that in any  sort of community planning process, careful consideration should  be given to the
                                 range of resources that exist in the community, and that protection and  accessibility are important to gaining the
                                 public's understanding and appreciation of these resources, in order to protect, preserve or restore them  for future
                                 generations.


                           •     The definition of Sustainability will vary from community to community.


                           •     Too much emphasis on Sustainability as a concept or goal creates problems because  no one actually understands
                                 Sustainability or how to achieve it.


                           •     The key  is to create jobs, re-train workforce, prevent crime, provide good housing, and attract companies  that
                                 comply with environmental laws and eliminate pollution.
                                                                   E-19

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APPENDIX  E
SUMMARY   OF   AGENCY   INTERVIEWS
                           •     The question is: Is it sustainable if you just focus on jobs? A satisfactory quality of life depends on an ecological
                                 component being there.  Quality of life includes not misusing the resources and using them in a way that preserves
                                 and protects them.


                           •     A part of the definition of sustainability includes a satisfactory quality of life (both living and working life).


                           •     A sustainable community should be well integrated with nature. Ecological factors also have benefits for economics,
                                 property values, aesthetics, etc.


                           •     Energy use is one tool for measuring sustainability.  It is easy to measure the effect on the environment.  This could
                                 be calculated either for the project or the community level.  A number of State energy offices have been very active
                                 in sustainability efforts.


                           •     It's not necessary to describe or understand sustainability in order to  do those things that contribute to it.


                           •     It is important to recognize  that things can adapt or change over time.  Consider how things were made and what
                                 happens to them as the community evolves.  There is a need to think about or address the project from a life cycle
                                 analysis perspective.


                           •     From a local standpoint, sustainability is whatever is "doable".


                           •     Sustainability needs to involve youth in the process in order to begin to ingrain sustainability principles at an early
                                 stage.


                           2.2   Sustainability and Self-sustainability


                           •     The important question is not if the development is sustainable; but can the community sustain the development?
                                 For example,  a former blue-collar town that has lost both industry and jobs now has a bright new recreational
                                 development.  However, the community may not have the income to support this activity over the long term.


                           •     Sustainability should be considered as a process as  opposed to an  outcome.  The Burlington, VT project is one
                                 example of sustainability being addressed as a process.


                           •     Sustainability can cover the full spectrum of projects all the way to the completely self-contained.


                           •     Self-sustainability cannot be forced at the project level because it could turn off a lot of communities and pose an
                                 insurmountable barrier to redevelopment.


                           •     It is surprising what can be done toward establishing sustainability at the project level.  ECo-industrial parks  appear
                                 to be working as a concept.
                                                                   E-20

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APPENDIX  E
SUMMARY  OF   AGENCY  INTERVIEWS
                           2.3   Conceptualization of the Brownfields Initiative


                           •     We have a tremendous opportunity to correct development problems that have been created over the last 200 years
                                 and the opportunity was unanticipated.  Brownfields are really a consequence of CERCLA legislation.  Now, as a
                                 result of this, we are asking fundamental questions about the way development itself takes place.


                           •     Brownfields is a messy process.   It is not really a straight-line process, but describing it as a linear project would
                                 probably be only about 70% correct.


                           •     Each Brownfields project is unique.  Every new factor - different land, ecology, business community, etc., changes
                                 the number or composition of stakeholder groups.


                           •     Anytime there are more than two stakeholders involved, the process becomes an iterative one.  Whatever the
                                 development vision, it is not always shared by all players.


                           •     Brownfields are actually an effort to really work in economically depressed and under-served areas where there has
                                 been a lack of economic capacity.  The effort is to have the Federal Government work with these communities to
                                 rebuild economic vitality. The objective is to address a wide variety of community services.


                           •     Every Brownfields project is essentially a real estate deal. Somehow this has to be brought forward to the attention
                                 of municipal and project people.


                           •     By focusing on the Brownfields  issue,  you are  dealing with only  a small  part of the problem of inner  city
                                 development.


                           •     Congress has essentially reached the maximum of its funding of community grant programs.  Now, communities
                                 look to programs  like Brownfields to get funding.  This is primarily a political issue.  The City Council and Mayor's
                                 approach is that if Brownfields  will get us money, then if s a Brownfields site.   Communities will call a  site a
                                 Brownfields site if that is  what will stimulate attention and provide funding.  They will then use these funds for
                                 other problems that are more pressing.


                           •     Distressed  communities are more likely to identify Brownfields  sites within the community in order to  obtain
                                 funding.


                           •     Non-distressed  communities  may tend to feel  that they have nothing to gain by identifying Brownfields in their
                                 community. There is an unpleasant stigma associated with Brownfields - it becomes a symbol of decline.  Successful
                                 communities tend not to want this negative connotation.


                           •     Brownfields are a  contributing factor, but are not really a dominant factor in impeding development. A number of
                                 other conditions are more  decisive including economic decline, changes in living patterns, increased poverty, crime,
                                 drugs, low market potential for reuse of the properties, etc. These become higher priorities.
                                                                   E-21

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APPENDIX   E
SUMMARY   OF   AGENCY  INTERVIEWS
                           •     There is a complaint that environmental regulation has a chilling effect on development by labeling a property and
                                through concerns over site assessment and cleanup costs, liability, third-party risk, etc. However, in a HUD study of
                                51 different projects, the finding was that environmental issues - all else being equal - were not a  decisive factor in
                                the creation of Brownfields or as an impediment to cleanup.


                           2.4  Key Brownfields Program Elements and Objectives


                           •     There is a need  to take  each Pilot and find the transferable elements that are a part of it.  Then, combine those
                                transferable elements together to create a guide for other communities to follow, especially small communities.


                           •     The goal is for the Brownfields process to plant the seeds for long-term growth of the community and an improved
                                quality of life.


                           •     There is a  great deal of variation in the way communities do  economic development.  Not all communities do
                                economic development planning and marketing, or do that well at it if they do it.


                           •     New York City is an example of a community that does not specifically do economic development programs - they
                                don't really need to.


                           •     If s okay to think small as long as enough people do it


                           •     Putting a Brownfield back into  active use may mean putting something green on it - it is not always necessary to
                                construct something.


                           •     Regional equity or the idea that  development in one place does not create new Brownfields elsewhere is a concern.
                                A number of the Smart Growth Models address this issue. Montgomery County, MD model may be useful in terms
                                of land, farm preservation, and  transferable development rights.  Minneapolis-St.  Paul uses a regional approach to
                                development (especially transportation and tax structure). Portland, OR employs growth boundaries as well as local
                                ordinances  and a zoning plan.


                           2.5  Role of Federal Programs in Redevelopment


                           •     Federal programs need to be responsive, supportive and adaptive to local community needs.   Programs should be
                                flexible and responsive.


                           •     The Federal Government cannot make decisions on what local community's  value.  It cannot tell local communities
                                what is best for them.


                           •     Federal agencies  can assist with leveraging and consensus building, as well as  education and public  outreach to build
                                awareness.
                                                                  E-22

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APPENDIX   E
SUMMARY   OF  AGENCY  INTERVIEWS
                           2.6  Agency Approach to Brownfields — Department of Defense


                          •     The Department of Defense (DOD) role in Brownfields redevelopment is limited.  Its primary activity is through
                                Corps  of Engineers public works support  to  communities.   The  Corps of  Engineers is  not an  economic
                                development agency.


                          •     Existing Corps of Engineers development projects  were severely lacking in  environmental focus.  The major
                                emphasis seemed to be entirely on brick and mortar activity. The Corps found it necessary to include an ecological
                                component.


                          •     The ecological component gave the Corps a part to play and  made  use  of some of the authorities that it had
                                developed over the past years.


                          2.7  Agency Approach to fir own fields — Department of Energy


                          •     The Department of Energy's (DOE) primary activities with respect to Brownfields redevelopment are in the areas of
                                environmental management and the transfer of technology.


                          •     The Center of Excellence  for Sustainable Development is now a support  office  within  the Office for Energy
                                Efficiency (OEE).   The function  of this organization  is to develop technical information tools and make them
                                available to the general public.


                          •     Brownfields are of interest to DOE because  they generally already have infrastructure in place that creates  energy
                                efficiency requirements (e.g. existing roads, traffic congestion, reduced vehicular mileage, building efficiency, etc.).


                          •     DOE is no longer involved in FUSRAP sites.  These have been turned over to the Corps of Engineers.


                          •     DOE's present concerns are with the environmental management of its big sites such as the Idaho site - about the
                                same size as the state of Rhode Island -  Hanford, and Savannah River. The Oak Ridge site has been doing some
                                very positive things with economic redevelopment.


                          2.8  Agency Approach to Brownfields — Department of Interior


                          •     The primary emphasis of the NFS is to protect natural/cultural resources.


                          •     Practically all NFS programs are driven by grass roots action, or requests for assistance from another agency.


                          •     The general approach is to go into a community and work with local organizations on a short-term basis (usually one
                                or two year's duration). The purpose is to build a vision of resources and resource use, help  develop  a focused
                                implementation strategy, and provide short-term technical assistance.


                          •     The current NFS role or  participation on the Brownfields Task Force is limited with no foreseeable potential for
                                new roles.  The primary NFS contributions to the Brownfields effort are: 1) it provides either funding or technical
                                assistance  to supplement  committees (through  local agencies), other partners,  public agencies,  non-profits,  or
                                                                 E-23

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APPENDIX   E
SUMMARY  OF   AGENCY   INTERVIEWS
                                community groups which have  limited resources;  and 2) it  participates in two specific Brownfields Pilots  in
                                Lawrence, MA and Providence, RI.


                           •    In contrast to the Brownfields program that is a much more top-down oriented process, the Park Service approach
                                is based more on  grass roots organization -  driven by the local partnerships in the communities.  NPS is usually
                                involved with trail organizations, local public  agencies, watershed groups or the friends of a river or resource - non-
                                profit groups trying to get started. The working coalition may also include a private firm or developer.


                           •    Although there is an overlap between Brownfields and NPS programs; Brownfields is perceived as one more part of
                                an overall community enhancement effort.  The important element for Park Service programs is that the community
                                feels that there is an important resource that they want to protect or develop.


                           •    The Rivers and Trails Program is the primary NPS program. It provides assistance in the protection, conservation
                                and re-creation of natural resources.  The focus is on trails and greenways, rail corridor transformation, waterfronts,
                                cleanup of riverfront parks, and unique national or cultural resources.  The basic procedure is to assess resources,
                                identify alternatives, get other stakeholders involved, then determine how to proceed.


                           2.9  Agency Approach to fir own fields — General Services Administration


                           •    The General Services Administration (GSA)  role in the Brownfields partnership is primarily related to the areas  of
                                community planning, assessment and  cleanup, and redevelopment support.  The agency does not do much with
                                sustainable reuse issues.


                           •    The basic GSA approach was to review other major programs and their involvement in urban  development.  Areas
                                where other development programs were already operating were identified.


                           •    The agency targeted those areas where other  actions were already taking place. The agency did not want to go into
                                an area where there was no other activity and  attempt to start from scratch.


                           •    GSA only addresses Federal properties; it is not involved with any privately held or local municipal property.


                           •    GSA identified 16 cities  for its participation in the first round and an additional 18 cities in the second round. An
                                inventory of approximately 1,000 Federally owned properties was carried out in those cities.  Meetings were held to
                                determine which Federal sites were of interest to the communities.


                           •    Federal property contributes to Brownfields in two ways: 1) underutilized sites can be transferred and put back onto
                                tax roles; and 2)  the property can become a part of nearby commercial redevelopment.


                           •    GSA takes a proactive approach by going to the municipal government and asking if they want a property.  The
                                attempt is  to  link the agency to the city.  Typically this begins  by talking to cities about abandoned properties
                                because they have the power to acquire the property.
                                                                  E-24

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APPENDIX   E
SUMMARY   OF   AGENCY   INTERVIEWS
                           2.10 Agency Approach to firownfields — Housing and Urban Development


                           •     The primary role of Housing and Urban Development (HUD) is to address housing and community development
                                issues.  In this context, environmental issues are obstacles or barriers that communities have to address.


                           •     HUD is not a regulatory agency and therefore its approach is different from the EPA's.  HUD's role is to provide
                                resources to communities - primarily money, information tools, etc. - and to set guidelines and frameworks for the
                                expenditures. Its support is primarily in the form of Special Grants (i.e., Economic Development Initiative Grants)
                                that are based on a more regional approach, and Basic Community Development Block Grants targeted to improve
                                low or moderate-income facilities in cities  with populations of 50,000 or more. Communities have flexibility as to
                                how they are going to  expend the funds,  but communities generally do not like to spend block grant money for
                                cleanup.


                           •     Brownflelds issues are addressed in the context of communities trying to revitalize. Communities are not interested
                                in Brownfields per se - they are interested in development.  Brownflelds have increasingly become an issue that has
                                to be faced as another step along the way to development.


                           •     The  concern is how to promote community  revitalization - what  can the Department do to help revitalize
                                Brownfields.


                           •     Another development  area is the Comprehensive Planning  Program.  This emphasis on area-wide  planning is
                                concerned with placing subsidized housing in the suburbs where new jobs are — making people more "portable. "  It
                                encourages "movement to  opportunity" or movement of inner city populations  to the suburbs.   This promotes
                                desegregation and moves poor or economically distressed populations to  the  suburbs where new jobs  are located.
                                Here they can take advantage of suburban amenities (i.e., schools, social, shops, etc.).


                           2.11 Brownfields  Project Organization


                           •     The Groundwork Trust represents a potential model of community non-profit control that might contribute to the
                                sustainable development of Brownfields.  The Groundwork Trust organization was originally developed in Great
                                Britain and transferred here.   Model organizations are designed to bring the  point of coordination for local
                                environmental work to the community itself.  The efforts typically focus on creating or improving greenspace (e.g.,
                                tree planting, wetlands restoration, and conservation projects).


                           2.12 Brownfields  Redevelopment Strategies


                           •     Community development values and desires  should be  determined on a  case-by-case basis.  For example in Los
                                Angeles the priorities are driven by transportation issues and needs where in Chicago, the priority is  on housing
                                issues/needs.


                           •     Rural communities need a replicable model to  follow in order to get started.


                           •     The current focus of Brownfields projects appears to be on inventory, but where can you go  from there? There is a
                                need to develop criteria to identify and select Brownfields properties that can be made financially attractive.
                                                                  E-25

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APPENDIX  E
SUMMARY  OF   AGENCY   INTERVIEWS
                           •     It's the local municipalities' responsibility to control (via effective public outreach) public information and opinions
                                 about properties in order to prevent the creation of unrealistic or divergent expectations for the parcel.


                           •     The Brownfields project requires three  elements: the right  incentives  (tax breaks, low interest loans, grants, and
                                 others); the right property; and the right use.


                           •     Waterfront sites are a hot item.  They make really good Brownfields redevelopment sites.  People are changing their
                                 idea of what a waterfront is and transforming older areas from port and warehouse uses to recreational areas.


                           •     There is a danger in replicating successful models where you can get  too much of the  same thing (i.e., everyone
                                 develops eco-parks or convention centers or stadiums and soon everyone competes against each other and can no
                                 longer  support the  development).   The question should  be:  Will  the  market  support  extensive  waterfront
                                 development in every city that has a river?


                           •     Program planning  or community based planning depends on  the requirements of the  local community and the
                                 related issues.


                           •     There is  a  need  to focus on all costs associated with redevelopment  -  acquisition, assembly,  infrastructure
                                 development, etc. - in addition to any kinds of contamination. The actual cost of cleanup and potential liability are a
                                 very small part of the development cost.


                           •     Economic analysis primarily uses profitability and cost-benefit analysis. But incremental cost analysis may be a
                                 better way of determining the pure cost. This may be the better way to characterize  Brownfields.  This approach
                                 provides a relative comparison.


                           2.13  Incentives to Stimulate Emerging Technology


                           •     One of the most profound new ideas, in terms of creating new possibilities, is the integration of natural processes
                                 into the actual infrastructure of the community.


                           •     Phy to-remediation is a low cost alternative and it also increases the property value when you are planting trees, green
                                 areas, etc.  This is probably the most important technology for Brownfields redevelopment.


                           •     There are new site  screening and characterization technologies that are fast and cost effective. These are especially
                                 important for small sites and communities that cannot afford  traditional methods.


                           2.14  Strategies to Attract Financing


                           •     The need to attract financing to the inner city is important. Chemical Bank does  not want to end up foreclosing on
                                 a Brownfield, but would much rather have a nice suburban greenfield with which to deal.


                           •     GSA has received  several calls from  banks and mutual funds trying to identify  properties for  investment.  Other
                                 investors are also looking to acquire contaminated land in large quantities.
                                                                   E-26

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APPENDIX   E
SUMMARY  OF   AGENCY   INTERVIEWS
                           •    Example:  the Pnchard, AL Pilot focused its initial efforts on agencies with money to fund grants.  A number of
                                agencies were targeted and these formed the funding basis for the project.


                           •    A potential source of funding exists through Intermodal Surface Transportation Efficiency Act (ISTEA) legislation
                                (e.g., Environmental Enhancement Loans).  This  can be a source of funding  for trails  and greenways  projects
                                through Federal highway money.


                           2.15 Strategies to Attract Business to the Urban  Gore


                           •    To attract a developer  back to the urban area, you need to emphasize what the positive characteristics  of developing
                                in this location are (e.g., taxes, access, finances, infrastructure).


                           2.16 Federal Property Transfer


                           •    All Federal Property is deeded to the United States  Government.  There are 31 agencies  designated to hold the
                                property and act as owner with custodial and accountability responsibilities.  GSA is the only source of authority for
                                the disposal of property.


                           •    Some  agencies have disposal authority for some types of property (as a  delegation of authority from GSA).  For
                                example, the military can dispose  of BRAG sites directly, but this is done under GSA authority.


                           •    Federal  agencies are required to report  assets  (properties)  that  are no  longer needed. GSA  uses  a three step,
                                systematic "waterfall" approach to disposal:


                                —    A determination  must be made if the property can be used by another Federal Agency.  This covers about 5%
                                      of all re-deployed property.  Otherwise, the property is surplus.


                                —    Property declared  surplus to the Federal government is  offered for sale to  State or municipal governments -
                                      negotiations are based on the fair market value.


                                —    If there is no State  or municipal interest, the property can go to a public sale.


                           •    For any transfer or sale outside the Federal government, GSA is required to get fair market value.  Exceptions to the
                                fair market price rule (including discounts  of up to 100%) can be made for "socioeconomic programs" such as parks
                                and recreation areas, education, health, prisons  or wildlife uses by the States or municipalities,  or to wrap into a
                                larger community development project.


                           •    Buying Federal properties is like having an insurance clause for contamination liability because the government must
                                return and cleanup the property if new contamination  is discovered.


                           •    CERCLA legislation describes requirements for the transfer of Federal property.  In 1992,  changes were added to
                                require that property  to be  re-deployed be surveyed  and that clean  parcels  be verified so  that they  can  be
                                immediately disposed.
                                                                  E-27

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APPENDIX   E
SUMMARY   OF   AGENCY   INTERVIEWS
                           •    An additional  change to  CERCLA provides authority for the early transfer of property.   This allows the
                                Government to defer remediation until after the property is transferred and also frees the Government from the
                                absolute requirement to pay for the cleanup.  The Government can discount the fair market value of the property for
                                the cost of any cleanup; the new owner pays for cleanup, the cost of which is deducted from the sale price. Early
                                transfer authority does not absolve the agency from responsibility for the clean up or any subsequent liability.


                           •    Relocation is another strategy.  The agency can also integrate or consolidate to free up property, especially in high
                                cost/property value areas.  Agencies  sitting on high dollar real estate can sometimes sell it and pay  for the
                                construction of new facilities in lower value areas.  This frees up desirable land for commercial development.


                           2.17 Risk Factors and  Indemnification


                           •    Need to consider how environmental insurance  might be used as a tool to help communities address pollution
                                problems and municipal liability.


                           •    There is a range of options  for determining cleanup levels. Cleanup levels should be risk-based.  We have to look at
                                both the human ecological  risks that are involved with the project and at the natural ecological risks - we may have
                                clean sites, but a dead environment.


                           2.18 Community Involvement


                           •    The developer  is the key. The developer tends to involve only those community participants it needs to expedite
                                the project.


                           2.19 Environmental Justice


                           •    Environmental justice is a very recent consideration in public programs; it was not a part of the process in the past.
                                Now the tendency is to move away from past practice and not to build public housing at or near Superfund sites.


                           •    Environmental justice has  helped focus a lot of Federal money on inner city areas that "also happen to have
                                contamination problems."


                           •    Aside from lead paint contamination, cities otherwise report anecdotally that contamination is not a serious problem
                                for development, and that it is not likely to become one.


                           2.20 Barriers to Brownfields Development


                           •    Small community politics can be an important impediment to the redevelopment effort.


                           •    Sometimes it is difficult to  get the consensus of the private property holders adjacent to a project. For example, a
                                recent  greenspace project met with  opposition from adjacent landowners who objected to  increased use by the
                                public.  Residents also objected to the loss of opportunity to purchase the land and expressed concern that this was
                                                                  E-28

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APPENDIX   E
SUMMARY  OF   AGENCY   INTERVIEWS
                                the beginning of a National Park or Federal area.  Local businesses became concerned over withdrawal of the land
                                from productive use.


                           •    Environmental contamination is not necessarily an impediment to development.  The cost of remediating PCBs,
                                lead contamination, new construction, local poverty issues, high crime, etc., are actually what halts development.
                                Therefore, environmental costs are just one of a number of factors to be dealt with in the process of adaptive reuse.


                           •    The biggest problem is shortsighted thinking and a lack of expanded vision, limited focus, and an over emphasis on
                                job creation. Looking at it only from a short-term, monetary gain standpoint is not beneficial.


                           •    People who can define and move the vision forward cannot always be found.


                           •    The Federal regulatory environment encourages  sprawl and impedes redevelopment.  There is a need to identify
                                which Federal regulations may actually be encouraging sprawl. The CEQ is preparing a preliminary draft document
                                on this issue.


                           •    There  is a  finding that air quality  regulations are driving cities  toward  sprawl.   Increased sprawl is a possible
                                mechanism for reaching attainment through dilution.


                           2.21 Brownfields Success Criteria


                           •    The success criteria are really specific to the individual community or city.


                           •    The best possibility  for success is in those  communities  where  there is a strong city economic development
                                department as opposed to those communities that are limited only to a planning or other similar department.  The
                                city's economic development people are  more adept at defining where  the project is going and where the funding
                                will come from, as well as the types  of development the community will support.


                           •    It is  important for the community/municipality to really identify and understand its needs.


                           •    There should be a group, or organization, that will take responsibility for the resource and process; and that will be
                                around to assure that the process will continue beyond the immediate future. Essentially, a non-profit organization
                                that will be there to assure the long-term  future of the project.


                           •    The presence of sufficient stakeholders (including indigenous residents)  who are appropriate to the project and who
                                can support a long-term commitment because they really care about the project is important.


                           •    Successful projects are usually tied to a strong market, however, there is no one particular model of success.


                           •    Simple  success means  that the  effort promotes  sustainable  development  or  sustainable  communities;  the
                                development makes sense - uses sustainable criteria.


                           •    A key question to determine success is: Would you want to live and work here?
                                                                  E-29

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APPENDIX   E
SUMMARY   OF   AGENCY   INTERVIEWS
                          •    The project has done something that reduces overall demand on resources, energy or transportation.


                          •    The project has avoided dong anything that will cause another Brownfields 30 years from now.


                          •    An important question is: If I build this, will people want to live here as well as work here?


                          2.22 Weaknesses in Brownfields Projects - Failure Indicators


                          •    Community development is often hampered by a ground zero start.  Typically there are no resources or networks
                               already in place.


                          •    Failure occurs more often  when plans are done by a  consultant or a group  that has no commitment  to see the
                               project through. A successful plan needs  a component of residents to become involved and make it happen.


                          •    There  is a lack of understanding and appreciation for what a sustainable community might look like.
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APPENDIX   F
SUMMARY   OF   ON-SITE   INTERVIEWS
                          1.   Brownfields  Economic  Redevelopment  Initiative  -  Dudley  St.  Neighborhood

                               Redevelopment

                               Boston, MA

                               Site visit: January 28 -January 30, 1998


                          1.1  Background


                          The  primary focus of the project  is the Dudley Street Neighborhood.  There are over 1,300 vacant lots  in the
                          neighborhood,  accounting  for 9%  of the  State's  listed  contaminated sites.   The  project's  objective is to  address
                          Brownfields as part of a multi-dimensional revitalization strategy for the Dudley Street neighborhood.  The Pilot Project
                          Grant was awarded in September of 1995.


                          The Dudley Street corridor is a major urban thoroughfare running through the Roxbury section of the city to Dorchester.
                          Roxbury and Dorchester have borne  the brunt of Brownfields creation during the past  20 years. The Boston Brownfields
                          Pilot focus is on one small  area of Roxbury around Dudley  Square.  The overall vision for this redevelopment was the
                          creation of a "Dudley Urban Village" — a self-sustainable community within the city. The Roxbury  area was recently
                          rezoned to segregate residential clusters, commercial/industrial clusters, etc. Previously, industry was located right on top
                          of the residential community.


                          The city of Boston perceived the  Brownfields effort as an environmental rather than an economic development problem
                          and placed the  Brownfields coordinator position in the Environment Department.   The  project has had significant
                          accomplishments with respect to community involvement and is supported by community residents  who have been given
                          an opportunity  to participate in the  decision making process.  However, problems with respect to the overall project
                          management and coordination, the metropolitan government and political structure, and the response of property owners
                          have impeded progress and limited the achievement of project goals.


                          The population  of the city of Boston is 574,283 (1990 census), with a minority population of about 236,000 and 18.7% of
                          the population living at or below the poverty level.


                          1.2  Project Contacts:


                          John Podgurski, Region 1 Brownfields Coordinator,
                          Carol Tucker, Brownfields Project Manager, USEPA, Region 1
                          Barbara Landau, Brownfields Coordinator, MA Dept of Environmental Protection
                          Jacqueline Ritchie, Brownfields Coordinator, City of Boston, the Environment Department
                          Russ Lopez, Director, Environmental Diversity Forum
                          William A. Shutkin, Co-Director, Alternatives for Community and Environment (ACE)
                          Frank Sapoda, Deputy Director of the Dudley Street Neighborhood Initiative
                          Dudley Street Neighborhood Initiative - Membership
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SUMMARY   OF   ON-SITE   INTERVIEWS
                           1.3   Summary of Major Themes


                                 1.3.1	Conception of Sustain ability


                           •     Although EPA is concentrating on sustainability and wants municipalities to factor in sustainability early in the Brownfields
                                 process, it has not been a high priority in the regional Pilots to date. The focus has been more on encouraging sustainable,
                                 closed loop type of industries.


                           •     At the  project-level, the goal of sustainability is not so much on the effort to  keep the program going, but to have the
                                 individual project sites ready and in position to be redeveloped once the site assessments are completed.


                           •     Sustainability can also be related to what  communities may want to do. A project is sustainable if it satisfies goals
                                 and criteria that communities may define for themselves.


                                 1.3.2	Conception of the Brownfields Process


                           •     Brownfields is not so much a process but a "tool kit" from which you select the parts you want or need. The Pilot
                                 Projects are  simply a tool for communities to leverage resources with other grant programs.


                           •     The program should be a "forum" for property owners to get answers and input on how to deal with contaminated
                                 land. But, Brownfields should not be a tool for communities to push owners into redeveloping land.


                                 1.3.3	Brownfields Project Organization


                           •     There is a feeling that the grant process  really should be three years in length for those communities that are starting
                                 from  scratch.   Large urban cities also  have  greater  internal,  administrative barriers  to  overcome and more
                                 stakeholders to  involve than do smaller cities.  Therefore, large urban areas require more time and money to
                                 accomplish the same outcomes as small urban or rural areas.


                           •     The most difficult parts of the Brownfields process relate  to  attracting developers  and marketing  contaminated
                                 properties, overcoming impediments posed by  private property rights, and  linking sociocultural and ecological
                                 desires with economic values.


                           •     Without a centrally located mechanism at City Hall to act as  a coordinator, projects appear to falter. There is a
                                 definite need to have a point person who is connected to the city administration and who can act as a conduit to
                                 other key players to broker requirements and deals.


                           •     There is no  advantage to not having the city involved in the Brownfields process. So much of the land use work for
                                 the city is Brownfields.  Municipally owned Brownfields are the most attractive for redevelopment. The city is also
                                 able to pass  bonds to finance the assessment and cleanup.
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SUMMARY  OF   ON-SITE   INTERVIEWS
                                1.3.4	Distinction Between Urban and Rural Brownfields


                                Although there  is community interest in both urban  and rural Brownfields, the people  are usually closer to the
                                project in urban areas and the community usually wants a greater degree of control.  The urban area generally has
                                more people and the facility usually has a greater direct impact on the surrounding residential community.   As a
                                result, there  is a greater need for  consensus building.   In rural areas, the  projects are  usually farther  removed
                                physically from the public and the concern is usually more for economic impact and jobs.


                                1.3.5	Elements of Successful Projects


                                A common theme is that a successful project requires  good management and a supportive local government.  The
                                project needs the leverage to make  things happen (an aura of power within the municipal political structure).  The
                                city must have strong, capable city management with a vision and commitment.


                                Current market  trends and a strong economy are contributing  to Brownfields marketability and developer interest
                                and  involvement.   There is some question  as to whether in a poor  economy,  or with poor marketability of
                                Brownfields sites, the same level of interest would exist, with or  without a Federal Brownfields program.


                                A strong emphasis was placed on the need for a single group, organization, or agency within the community that is
                                designated as the main, central authority for the project.


                                1.3.6	Impediments to Brownfields Success


                                A number of problems  were related to  the creation of false expectations on the part of the  community groups.
                                These were attributed in part to a  need for public education to develop an understanding of how private sector
                                investment works, the needs and expectations  of developers, and the mechanisms for determining marketability and
                                marketing the site. The  perception was that community groups  believed that all that was necessary was to pick a site
                                and that  something would happen.


                                Individual property owners were considered a major stumbling block to progress; non-cooperative  owners were able
                                to shut down the project at certain points. Two ownership types were identified as particular problems; those that
                                just do not care, and speculators who are merely waiting for the property value to  go back up. Some owners still
                                resist the opportunity to dispose of their contaminated property even with new liability provisions; also, some just
                                do not care about the neighborhood.


                                People in  the community did  not own most of the  Brownfields  properties  selected for  consideration by the
                                community groups. This reflected the fact that most of the properties in the community are not owned by people in
                                the community. The project had to learn how to deal with "bad actor" private landowners that don't live in the
                                community and therefore don't share community vision and values.


                                Private property issues  were considered important with  respect to  how  public funds could be used  in the
                                assessment, remediation, and restoration process.  Also considered important were the resolution of private property
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SUMMARY  OF   ON-SITE   INTERVIEWS
                                 rights, how to counteract private owner motivations/intentions that run counter to the overall community goals, and
                                 land value changes before and after the assessment.


                                 The municipal government cannot commit public funds  for a site assessment on a property that the city  does not
                                 own; it opens up too much liability for the city to assess a site before it owns it. It also sets a dangerous precedent
                                 that may limit future participation by owners.


                                 Because of the delays caused by a cumbersome and lengthy foreclosure process, an emphasis was placed on the need
                                 for a  fast track approach  to  the  foreclosure process  that  does not infringe on private property rights.  Tax
                                 foreclosure is a problem especially if the property is contaminated;  it can take up to one year.  Municipalities also
                                 don't want to assume title to highly contaminated land.


                                 There is a definite concern over the need to  remain focused and not to place too much emphasis on the process
                                 itself, at the expense of progress toward goals. A loss of "up  front focus" on the project was attributed to a myriad
                                 of later procedural details and problems.  The recommendation is that by the time the project grant is awarded, the
                                 project must already have its people organized and should know what it plans to do with the funding. Those Pilots
                                 that have moved ahead are those that have had a good idea of what they wanted to do and where they wanted to do
                                 it.


                                 The role  of city support to the success  of a project was very much emphasized.  Problems with the project were
                                 attributed to the absence of a complete "buy-in" by the city. Two key questions for project  success were as follows:
                                 1) How to gain the community's and metro government's attention  and 2) What to  say after the attention  has been
                                 obtained.


                                 The number of players involved in the  redevelopment  was  considered to have enormous potential for creating
                                 opportunities for misconception, miscommumcation, and misapprehension about the project.


                                 In the process of addressing future site uses, there  is a  major dilemma  involved in deciding between  three basic
                                 alternatives:  1) waiting for  the  perfect business to become interested in the development; 2) settling for a less-
                                 preferred business that is immediately available; or 3) leaving  the property abandoned and deferring any permanent
                                 decision on future site uses to a  later time.


                                 1.3.7	Community Involvement


                                 Community outreach early in the project cycle is considered critical to establishing the project vision, standards and
                                 the public credibility of the effort. A less formal "project structure" is needed over time as banks, developers,
                                 administrators, etc., become more accustomed to the process.  The assumption is that the  more development that
                                 occurs  in the community, the less control the municipality will have over the end product as other stakeholders
                                 become more sophisticated about the process.


                                 A concern expressed by residents of the community is that for most development projects, they get to go to the
                                 public meetings and  are heard  by  project and city officials, but when it comes time  to make decisions, they are
                                 excluded.
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SUMMARY  OF   ON-SITE   INTERVIEWS
                                 1.3.8	Environmental Justice


                                 Environmental justice was conceived as being really a question of who has power in the community, how that power
                                 is being used to affect change, and who benefits from the exercise of the power.


                                 1.3.9	The Financial Institution Perspective


                                 There is a real benefit to banks that support the Brownfields process; the  alternative could be  to foreclose on
                                 property of poor collateral and little value. Lenders are now more wary of the possibility of foreclosures.  They are
                                 interested in the repayment of the loan, not in acquiring the property.


                                 1.3.10    The Developer's Perspective


                                 The development process generally involves  identifying marketable properties for development, lining up potential
                                 companies to move into  the neighborhood,  checking with the city on barriers and regulatory issues/requirements
                                 affecting  the  site,  offering a  development proposal  to  the city and/or property owners, and establishing a
                                 development team to address critical components such as community interest, site contamination and remediation,
                                 permits, financing, etc., in addition to addressing adjacent landowners concerns.
                                The physical properties of the site are the key to development, especially parking.  The parcel must be large enough
                                to accommodate both buildings and parking.  In the past, urban developers, because of high land cost, have tended
                                to maximize coverage of land with buildings and ignore the parking requirement. The parcel also needs good feeder
                                road access with expansion capability.


                                Developers usually want to turn a property over for a quick cleanup and sale. They usually have an  idea of what they
                                want, what neighborhood they want, how big the  site needs to be, what infrastructure is required  (such as highway
                                improvements) and what they want to do with a parcel.


                                Developers are interested in conducting (and in some  cases absorbing the cost of) site assessment and cleanup if
                                reliable cost estimates  are available that will enable them to analyze these costs as a part of the overall project cost
                                figures.


                                1.3.11      State Level Involvement


                                The State of Massachusetts has a supportive role in the Brownfields Process, but  the projects are  traditionally very
                                local, community based efforts, and often are not aware of the State's role. Most local projects do not need to deal
                                with the State since  they are typically dealing with low-tier threats. The State uses licensed, private environmental
                                consultants to oversee the clean up and certify that pre-established cleanup levels and standards have been achieved.
                                The State then conducts an audit of the project to verify that established criteria have been employed and achieved.


                                The State tries to focus its resources on the high tier sites that really need attention.  Determination of these sites is
                                based on a priority list developed under the State Superfund program. The sites are ranked according to their level
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APPENDIX   F
SUMMARY  OF   ON-SITE   INTERVIEWS
                                of contamination. The State provides technical and planning assistance to communities where needed or requested
                                to put the plans together.


                           •    The State also works with private developers and the local communities to get the development process started. The
                                finding is that the Brownfields process works best when it is implemented as part of a larger development project in
                                the community.


                           •    Based on their frequency of contact with the State to request assistance, the most likely initiators of a project are:
                                city planners, town managers, State Representatives, or potential site developers. The community itself occasionally
                                initiates projects.


                           •    The State is currently drafting legislation to  cover the Brownfields redevelopment process.   The most important
                                continuing issue for this  legislation is  the  need to determine a balance between helping the developers and
                                protecting the environment.


                           •    Under Massachusetts  State law, private owners have no  pollution liability until they do a site assessment that
                                documents a  problem - therefore they have no incentive  to identify  contamination and  declare a  property  a
                                Brownfields site.


                           •    Massachusetts has the provision for activity  and use limitations on redeveloped property;  for example, cleanup to
                                industrial use standards would be acceptable  if institutional controls were in place.  These  institutional controls go
                                on  the deed and remain with property.  This  policy requires continual government oversight and audit capability to
                                insure compliance with institutional controls.


                                1.3.12     Suggestions for EPA


                           •    EPA should be less restrictive on the city and community's role in the project. The city should be allowed to shape
                                and streamline the project.


                           •    Control  of the process should  be  focused on one key  organizational component as opposed to a decentralized
                                community decision-making process.


                           •    EPA should shift the Federal focus to "preparing or enabling property to be marketed."


                                1.3.13     Program Recommendations or Lessons  Learned


                           •    A fundamental requirement is to establish a big education effort and to provide the community with the technical
                                tools necessary to understand how development happens.  Community groups need to understand the  constraints
                                and the economic forces at work on the project.


                           •    The community should be informed about how to identify hazardous waste and the process for cleaning it up.  This
                                includes  the mechanics and the decision-making processes of site assessment and cleanup.
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APPENDIX  F
SUMMARY  OF   ON-SITE   INTERVIEWS
                           •    The jobs versus environment question is always an issue and it needs to be evaluated on a project-by-project basis.
                                Typically the worst development proposals also have almost no jobs (e.g., parking lots).  There is also a concern that
                                proposals need to be examined carefully to assure that the removal process does not cost more jobs than are created
                                by the new development.


                           1.4  Project Summary


                           •    The Boston Project emerged out of a previous  effort to address an  abandoned incinerator site located in the
                                Neighborhood.  This experience was leveraged to form the basis for the current project.


                           •    Although the project has made some progress, the definition of progress is often a function of perspective.  A
                                number of  stakeholder groups within the  community expressed dissatisfaction with the project.  The project has
                                been criticized  for  taking too  long to get started,  spending too much time in the learning process,  and not
                                establishing an effective organization.  The neighborhood residents, however, feel that the project was  a success
                                because they were empowered to  make decisions  about changes.  They express some frustration over a perceived
                                lack of local government support in terms of providing information and guidance.


                           •    The project site selection process was very specific. The community groups tended to stay within the target areas in
                                identifying the sites because  the community residents did  not want to dilute their resources.  They believed it was
                                important to employ a "small wins" approach to establish  credibility, mutual understanding, and motivation before
                                addressing larger and more difficult projects.


                           •    The community's concerns included the type and number of jobs created, the associated  pay scale,  the potential
                                impact to traffic patterns and congestion, the hours of public operation, and good building construction to match
                                the long-term vision of the communit/s desired appearance.  Other concerns included the  aesthetic appearance  of
                                the neighborhood, and a desire for clean businesses (not re-polluting)


                           •    The community's goals were focused on identifying and attracting green businesses to the community and assisting
                                local residents to establish green businesses.


                           •    The lack of success in meeting project goals was attributed to the following: 1) the absence of appropriate emphasis
                                on the project by the municipal government;  2) a failure to understand  the program as an  economic  development
                                program and to place the program coordinator position correctly within the municipal  structure, (both in terms  of
                                the department to which the  position was assigned and the level of the position itself within  the department); and 3)
                                the absence of any staff support to the Brownfields project by the city. It was also noted that the coordinator salary
                                with benefits for 2 years took up a large  portion of  the grant and that the coordinator had no real economic
                                development experience, nor established reputation and credibility within the city infrastructure.


                           •    Other problems  noted  were the absence of a coherent and coordinated operation on  the  part of the city, a poor
                                community vision,  the inability to sell the  Brownfields  value and community needs to the  city  administration, and
                                confusion as to whether the project was environmental or economic development in nature.


                           •    Recommendations  for those program activities that could have been done  differently include: 1) centralizing the
                                program under a non-profit  agency or group; 2) making the grant recipients themselves the main decision makers;
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APPENDIX   F
SUMMARY   OF   ON-SITE   INTERVIEWS
                               and 3) designating the Brownfields lead position at a director level within the municipal structure rather than at its
                               current level, as a coordinator.


                          2.   Port of Cape Charles Sustainable Technologies Park

                               Cape Charles/Northampton County, VA

                               Site visit: January 5  -January 8, 1998


                          2.1  General Background


                          The Pilot Project Site  is  the Port of Cape Charles Sustainable Technologies Industrial Park (STIP) which is proposed for
                          the town of Cape Charles, VA as a means of creating sustainable economic development for the surrounding community
                          and the county of Northampton as a whole. The Brownfields Pilot Project Grant was awarded in September of 1995. This
                          project has also been selected by the President's Council on Sustainable Development as a demonstration project.


                          The master plan for the development includes operating standards for the STIP that have been embodied in a set of
                          covenants and recently approved by the town council. The Town of Cape Charles has acquired part of the land designated
                          for development, a portion of which  is leased to  the Industrial Development Authority for  use in the first phase of the
                          project. The first tenant has been identified and has already moved into a temporary facility in the county, anticipating the
                          opening of the main facility.


                          On completion, the park will become part of a larger development project that includes the eco-industrial park  itself, a
                          restored  wetlands  area and nature trail, an environmental education facility, and a tertiary  sewage  treatment  facility.
                          Additional  development of a recreation  area including the  potential construction of golf  courses and a residential
                          condominium  is  planned for an adjacent  site  along the  waterfront.  A companion development along a strip  of
                          underutilized retail and commercial buildings on the main street of the city is also anticipated.


                          2.2  Project Contacts


                          Timothy Hayes,  Executive  Director, Joint  Industrial Development  Authority of Northampton County  and  Its
                          Incorporated Towns; County Director of Sustainable Development.
                          Thomas Harris, County Administrator - Northampton County
                          Richard Hubbard, Chairman, Joint Industrial Development Authority of Northampton County and Its Incorporated
                          Towns
                          Donald Clark, Town Manager, Town of Cape Charles


                          2.3.  Summary of Major Themes


                               2.3.1	Conception of Sustain ability


                          •    Sustainable development here is viewed as a process rather than as an outcome. In this conception, what is  done is
                               less important than the manner in which it  is done. The objective is to achieve a consistent development process
                               that benefits everyone. The process should  be community driven, based on the community's vision and values, and
                               supported by community leadership.
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SUMMARY  OF   ON-SITE   INTERVIEWS
                           •    A sustainable development project must be marketed to the host community in its own context and language in
                                order to obtain acceptance and support.  It is  necessary to translate non-traditional development into traditional
                                terms.  The community needs to understand what is being done and why the project is in the best interest of each
                                individual.


                           •    In addition to the  support of the community at  large, it is also necessary to develop leadership from within  the
                                existing political structure.  This requires that the process be explained to the political leadership in a way that they
                                can grasp and understand.  Project requirements  and benefits must be translated into numbers that local political
                                leaders  can use.


                           •    Sustamability does not always mean high tech; this is not always the key to success.  A low-tech labor force is often
                                the preferred option.  The goal is to develop a diversified economy, matched to the workforce, with challenging
                                career opportunities to promote workforce growth (i.e., both in numbers and knowledge levels).


                           •    In the three circles of the  sustamability model (e.g., economy, society,  ecology), it does not matter which of the three
                                takes the lead or has  the focus, as long as all three of the parameters  are  moved together  toward the center -
                                sustamability.


                           •    Although no  single  definition of sustamability can be applied to all  scenarios, sustamability can be seen as a goal
                                oriented process to bring  together all three elements; society, economy, and ecology.  It is based on the values of the
                                community and driven by a vision, a plan, and the people of the community.


                           •    Sustamability is  a mechanism by which the concerns of the community for environmental integrity can be translated
                                into economic opportunity and social improvement (e.g., jobs and development).


                                2.3.2	Conception  of the Brownfields Process


                           •    The Brownfields redevelopment process is seen not as a one-sided risk, but  as a "shared responsibility to address
                                problems."  A key factor  is to avoid categorizing issues, problems, tasks, etc., according to different elements, (i.e.,
                                environmental,  economic, etc.)  and instead, to consider them as  part of  a  holistic approach.  This  reduces  the
                                number of individual perspectives and counter productive objectives, and places emphasis on "what makes the most
                                sense overall."


                           •    The conception of the Brownfields redevelopment process  should be as just  one element  of a  larger overall
                                community improvement or development strategy.


                                2.3.3	Distinction between Urban and  Rural Brownfields


                           •    The definition of community needs and values  drives the initial focus of the development process and the choice
                                between redevelopment of the built environment or the creation of greenspace areas.  Rural areas  already have
                                greenspace so the goal becomes a drive toward  economic  development.  Whereas urban areas already have  the
                                economic infrastructure, so the goal here is to drive toward greenspace.
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SUMMARY  OF   ON-SITE   INTERVIEWS
                                 2.3.4	Brownfields Redevelopment Strategies
                                 The initial funding for the project comes from Federal Grants.  Federal grants or other funds help to provide the
                                 resources  necessary to  initiate and  accelerate the process.   However, the process  should not be  a long-term
                                 development effort based solely on external resources. The project cannot spend all of its effort chasing grants.
                                 First, it is necessary to  identify where the  project is going and then go out and find grants to  support what the
                                 community wants to do. It is too easy to let grant availability set the direction of the project instead of the other
                                 way around.


                                 One key element is cooperation between  jurisdictions.  The focus  should be on how to  help make  something
                                 succeed rather than whether or not it is part of a particular jurisdiction's effort.  If another  entity is working on a
                                 project, evaluate it to see if it fits into the overall plan and if it does, do not try to stop it or compete with it, figure
                                 out how to help it succeed.


                                 The successful integration of the Brownfields redevelopment effort into the overall master plan of the city, county
                                 or region allows both the project and the host jurisdiction to be working together.


                                 A model strategic plan can be considered that defines  development as a public process. The focus is on defining
                                 who the development is directed to assist, where they are located, and the assets and liabilities of the  community
                                 that are involved. All three elements, social, economic, and ecological are considered together, with an emphasis on
                                 equity.


                                 Six general elements form  the basis of the model: 1)  community values;  2) housing; 3) education; 4) health and
                                 human services;  5) reinventing government; and 6) sustainable community development.  From this overall model,
                                 an action strategy is developed to focus on those specific areas that relate to the experience of the local community
                                 and have a potential for development.


                                 2.3.5	Model for Community Involvement


                                 The important question is  framed as how to get  out  into the community and begin teambuilding efforts to get
                                 everyone on the same  path.  It is often true that  the  least affected individuals will also be  the least interested in
                                 supporting new efforts.


                                 As you identify  the needs  of the community, its values  and  priorities also emerge.  Development should  not be
                                 driven  entirely  by economics.   There is  also  a  need to consider other community  values  as  well - such as
                                 lifestyle/character of the community.


                                 A dual  perspective on growth can become one of the biggest issues.  The poor and disenfranchised will want to see
                                 the community change as a way of increasing economic opportunity. The  successful  and the old guard will have a
                                 tendency to resist change.   They have their own lifestyle and status definitions  and do not  understand the
                                 development to  be  in  their best interest.  Thus, lifestyle and social position  are key factors in determining the
                                 participation and support for the project.
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SUMMARY  OF   ON-SITE   INTERVIEWS
                                 2.3.6	Elements of Successful Projects
                                 One key to success in a smaller community is the ability to attract small, entrepreneurial companies who want to
                                 reside in a locale with character, that enhances or matches the company image or values.


                                 In smaller communities, the preference may be for multiple small and diverse companies with smaller workforces,
                                 rather than one or two large firms of 200 to 500 people.  The belief is that smaller firms have a better possibility of
                                 providing continuing employment, even if one or two close down, the impact is not as great as if a single large firm
                                 closes.


                                 Land use decisions should  contribute to the economic needs of the community.  Land use decisions should also
                                 recognize the natural limitations of the area.


                                 It is considered important to insure that a point of contact exists  for maintaining continuity of project responsibility.
                                 Once  decisions are made by whatever body, it is necessary to be  specific  about designating the persons to  be
                                 responsible for carrying out the decision and the associated action (i.e., the people who are going to be responsible
                                 for getting things done).


                                 An important element to the success of the project is the creation of a non-political body to lead the effort.  This
                                 body must be mission driven (for example, in Cape Charles, a joint Industrial Development Authority (IDA) is
                                 chartered under State  authority.  A set of bylaws clarify who is  involved  (county and its  incorporated cities), how
                                 they are represented on the  authority (i.e., number of seats for each), and how the involvement takes place.


                                 The project should make maximum use or advantage of existing resources and features (i.e., use existing facilities
                                 through modification or expansion as opposed to building everything new).


                                 An important contribution  to the success of the project with respect to public acceptance and the support of public
                                 officials is to have the  necessary background information and facts established before the pubic debate begins.


                                 There is a need to be  more active in public education and awareness efforts regarding the democratic process and
                                 particularly the requirements placed on the public in that process.


                                 Projects that  are driven by a community of individuals  as opposed to those that are a partnership of individual
                                 stakeholders have a better chance to succeed.  The important thing is to  avoid using the stakeholder concept and
                                 consider everyone simply as project participants.  The key is to achieve a fully integrated community - integrated into
                                 the project goals.


                                 It is important to make an obvious tie-in between local "sustainable development" and the global UN Agenda 21 so
                                 that the community can show the relevance of its plan on a global scale.  This  helps build credibility and increases
                                 local citizen's awareness of how they fit in. This also  helps contribute to a  national recognition of the importance of
                                 the local role.


                                 The national recognition of the early efforts and strategy conferred by the award of the EPA Pilot Project Grant and
                                 other grants was of great assistance in marketing the project both inside and outside of the community. It helped to
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                                solidify the support of the community and increased the dedication and momentum  for project.  It also added
                                credibility to the efforts of local officials.


                                2.3.7	Barriers to Development


                           •    The presence of multiple local government structures (town-county-state) can impede the decision making process;
                                as does the presence of overlapping authorities.


                           •    Internal competition with other government or community entities for the same funding is a key point.  Clarifying
                                how funds will be used will alleviate internal competition and improve the overall pnoritization and coordination of
                                all grant applications in the community.  It is important to coordinate the development project with State, regional
                                and county agencies so that they are not all chasing the same funding resources.


                           •    Surrounding property holders don't want  to become involved for fear that an assessment will find something.  The
                                Brownfields process does not really address the issue of who will clean up if something is found.


                           •    Small communities  must rely on outside firms for expertise (legal, environmental, tax, design and architecture). They
                                usually do not have the capability in-house.  But these services are  also expensive and may be beyond the resources
                                of the  community to acquire.


                           2.4  Project Summary


                                2.4.1	Impetus for the Redevelopment Process


                           •    The initial redevelopment process began with an Enterprise Community effort focused on economic development -
                                not Brownfields  redevelopment.   The city created an Enterprise Community Strategic Plan  that  included  an
                                emphasis on sustainable economic development.  The Brownfields component was added after the development
                                process was  already started.  Environmental consciousness and sustamability concepts were a part of the original
                                development mentality and reflected a general sensitivity to the fragility of the environment on the peninsula.


                           •    The impetus for the development appears to  have been a recognition  of the poor economic situation and a
                                perceived threat to  the position of the old guard, the "landed gentry," that had previously perceived the situation as
                                tolerable because their lifestyle was unaffected.  There was a perceived critical need to create  jobs that challenge,
                                motivate, and would retain  the youth of the county.


                           •    The community itself represents a blend of new residents with new ideas and older residents who remained after the
                                economic decline, creating internal tensions and providing for both an impetus to change. Many of the most active
                                participants in the project are long-term residents who could not afford to move out during the decline, when most
                                others did.


                                2.4.2	Project Coordination


                           •    The sources  of authority for  the project are based on the county political organization and a State chartered agency.
                                In line with its  strategic plan, the county established a Sustainable Development Department under the direction of
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                                the county manager.  This department represents a unification of environment and development functions under a
                                single structure.


                           •    An independent Industrial Development Authority (IDA) was formed by State Charter to oversee the project and
                                help cut through county/town politics. The IDA is composed of key community leaders from the county and the
                                town boards, as well as others with vested interests (e.g., local  banker). Both the County Administrator and the
                                Town Manager are ex officio members of the IDA Board.  They have no vote.


                           •    Historically there  has  been a poor relationship between town and county.  The  formation of the  IDA and the
                                County Sustainable Development Department has improved the relationship  and  increased the points of contact
                                between the two.


                                2.4.3	Sustainable Development Action Strategy


                           •    The early planning was not based on  criteria of sustainability, but rather the question of "does  it make  sense for
                                people, ecology, etc."  The plan was based on a local vision and a public will to make it happen; also  support from
                                the local politicians. The plan was not really trying to meet an abstract definition of sustainability but was trying to
                                incorporate sustainability into the planning process itself.


                           •    The basic strategy was put together in early 1993 when the Sustainable Development Task Force was created.  Six
                                key local industries were targeted for  development as a part of  the action  strategy: 1) agriculture; 2)  seafood and
                                aquaculture;  3) heritage and tourism;  4) arts,  crafts, and local products; 5)  research and education; and 6) new
                                industry (i.e., the sustainable technology park and Brownfields redevelopment).


                           •    The marketing effort was directed to private developers and companies that would share  a vision in common with
                                the  community (i.e.,  those  that  were willing to make a  commitment  to  pollution standards  and equivalent
                                wages/benefits; and are therefore willing to do and pay more than the minimum necessary to get into the park).


                           •    The project used  the architectural design of the STIP facility as a focus for  teambuilding among IDA members.
                                Since the County Administrator  and Town Manager  were present and involved,  and knew their own governing
                                bodies' preferences, they were  able to integrate them into the planning process. This shortened the  debate  of the
                                respective councils/boards and speeded acceptance of the development goals.


                           •    Community input was important at the earliest stages of the plan.  It was considered important to develop a "dream"
                                image  of what the community wanted.  An open  town meeting  format was used with a  TQM type facilitated
                                approach.  This was followed by an IDA Retreat conducted by a  University of Virginia  facilitator.  The retreat used
                                an abstract town as its  study object, rather than the actual community itself, to facilitate a group design conference.


                           •    The implementation process began by putting all of the players together in a room and then deciding what each
                                could do to contribute to the success  of the overall plan.  Agencies (Federal) and community groups  were able to
                                find money or programs that could support one or more particular aspects of the overall plan.
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                           •    The town bought the property from an owner who was interested in eliminating a non-performing asset that was
                                created when the original development for the site was not implemented.  The entire park is about 320 acres, of
                                which the Brownfields portion is about 155 acres.


                           •    Covenants  have been established  for the  operation  of  the  park and include  incentives  based on covenant
                                requirements (i.e., hire locally and reduce energy and water consumption).


                           •    The objectives or criteria for new development included: the creation of new jobs for the currently unemployed (at a
                                "family wage");  attracting  environmentally  friendly  firms  with a strong potential for a  long term presence;
                                establishing green building standards; recording covenants and  codes  to control development;  and obtaining the
                                involvement of community groups.  The general approach is that the area does not need a stratified economy - what
                                it needs is a diversified economy.


                                2.4.4	Project Success Factors


                           •    The support of the local population  for its public officials was a key element of the project's success.


                           •    The new  County Administrator (appointed in 1993) was a visionary and represented a strong leadership force at the
                                top. He and the Executive Officer of the Industrial Development Authority (IDA)  are the catalysts for the current
                                activity.


                                2.4.5	Barriers to Development


                           •    Opposition from local groups to any new proposed development was a  serious consideration.  These groups tend to
                                be  strong and well  organized.  The area has  a history of wanting some growth and  some  jobs  but  each  time a
                                development is planned, they find that it is "not quite what I had in mind."  This results in a loss  of opportunity for
                                the community.


                           •    There  is a problem associated with the  existing small town elite.  They represent a "landed gentry" that has resisted
                                change and is in a  polarized conflict with newer and  lower income  residents, who are interested in improving
                                employment and lifestyle opportunities.


                           •    The overly  restrictive covenants will keep many  companies out.   The area  can  expect to attract only five to seven
                                percent of the potential market.


                           •    Tax incentives to attract business to  the local area are not possible. The  area does not have a strong existing tax base
                                from which to start. Current taxes  are high  (especially personal  property) and tend to penalize development.  The
                                agricultural  tax rate  (equipment tax) discriminates against small farms (they need the same basic equipment as big
                                farms).


                           •    Impediments at the  State level include:  the narrow interpretation of the scope of State programs by State officials; a
                                tendency  to misunderstand local priorities; overly restrictive and narrow criteria for grants/loans; and unrealistic
                                criteria for  State  initiatives  (i.e., based on a  "standard county  profile" rather than addressing variations  across
                                individual counties).
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                           •    Wetlands restrictions are a bigger problem than perceived contamination; most of the land is wetland.  Suspected
                                contaminants are believed to be a less serious problem.


                           •    The town wants to include surrounding properties in the site assessment and address ecological issues across the
                                entire area.   But there is no incentive to property owners to become involved now,  only a disincentive.  Federal
                                grants are available for the site assessment, but if anything is found, the owner would be responsible for the cleanup
                                and they would still have to have the property checked out again at the time of any sale.


                                2.4.6	Lessons Learned


                           •    Do not limit the project to pie in  the sky type development, when literally anything is needed. The local economy
                                needs as much free expertise as it can get.


                           •    Staff resources are limited and there is no time or extra funding at the local level.


                           •    There is a serious concern for what happens when the grants end - there is no other way for a small county to bridge
                                the gap between the grants and private funding.


                           •    There is a need to consider tax reform options seriously (i.e., reforms and incentives) as an impetus to development.


                           •    There is some difficulty inherent  in identifying traditional values versus new values.   The newcomers' beliefs and
                                issues  are different.  Outspoken  newcomers and part-time  residents  do  not have  a voting share in municipal
                                government.


                           •    The EPA grant is useful to survey  the site, but if something is found, then the real problems begin.


                           •    Getting new development users to pay for all of the infrastructure upgrades is difficult.


                           •    The project will definitely change the town and its government. The problem is how to achieve development while
                                preserving the character of the town.


                           •    One problem area was that the project did not provide enough lead-time  to government agencies and governing
                                bodies to allow  for deliberation before a decision  deadline was reached.  They should have given the town council
                                and county board time to read the  materials and consider their meaning before having to vote.
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                          3.   Sustainable Redevelopment of the Urban Core of a Mid-Sized City -

                               Chattanooga, TN


                               Site Visit:  February 16 - February 18, 1998


                          3.1   Background


                          The current development project dates back to a 1982 initiative to redevelop the downtown and riverfront areas of the
                          city. The initial concern was  a growing problem with poor air  quality in the region and a deteriorating downtown core.
                          The original development initiative was combined  with a 1986 initiative aimed at the elimination of all  substandard
                          housing in the city within ten years.


                          The first redevelopment effort was concentrated along the riverfront of the city and is part of a larger 22-mile riverfront
                          greenway plan. With substantial progress on the waterfront development already completed, a second  focus is currently
                          being directed to an older industrial (foundry) region on the south side of the city. Brownfields redevelopment is a part of
                          these development initiatives.


                          Although the City of Chattanooga has made previous applications for a Brownfields Grant, it has never been awarded a
                          Pilot Project by EPA.


                          The city of Chattanooga has  a population of 152,466  (1990 Census), 36% of this population is of African-Am eric an
                          descent, with 18.2% living at or below the poverty level.


                          3.2  Project Contacts:


                          John K Clark, Director, River Valley Partners, Inc.
                          Robert C. Taylor, Urban Design and Project Development, River Valley Partners, Inc.
                          Ken Hayes, Chief of Staff, Mayor's Office - City of Chattanooga
                          William P. Sudderth, President, The Chattanooga Land Company
                          Joe Fergussen, AVS, Electric Shuttle Bus Designer
                          William Wilkerson, Derthick Henley and Wilkerson, Architects
                          Sid Saunders, VP  - Government Operations, Site Manager, The Volunteer Site
                          T. R. Andrake, Marketing Manager, The Volunteer Site
                          Bev Blair, Marketing Coordinator, The Volunteer Site


                          3.3  Summary of Major Themes


                               3.3.1	Sustainable Development


                          •    Purists are  not really sustainable.  The question  that should be addressed is: Are you making sense for future
                               generations? The present efforts at sustainability could benefit from studying what has happened in the past. We
                               should try to duplicate past successes.
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                           •     One element of sustamability is to take care of what is already here (i.e. use or reuse what is already available). A
                                 second component of this is to build new buildings with some sense of permanence. Buildings should be reusable.
                                 It is important to design and build for permanence and with the potential for other uses in the future in mind.


                           •     An important component of sustamability is shared resources. Nothing is permanent or sustainable if it involves
                                 just one resource - and the waste of that resource.  The linkage and sharing of resources creates a closed loop.  For
                                 example, linking properties and uses together allows parking in the central city to be shared (i.e., daytime for offices,
                                 evening for recreation), and the total land area that must be devoted to parking can be reduced, opening  space for
                                 other land uses.


                           •     Part of sustamability is that the initial  success of one project becomes the selling point for future projects, thereby
                                 helping to promote or sustain redevelopment for the future of the  community.


                           •     Sustamability means that industries are forced to make a better deal (i.e., eliminates  the continuing cycle of
                                 Brownfields).  Without the linkage to other industries in the region, new industries will stay only as long as market,
                                 technology, and costs  are favorable.   But with the sustamability loop, they  have  an incentive  to remain in the
                                 community near the other industries to which they are linked.   This means a greater stability in the community (e.g.,
                                 jobs, residents, etc.) which further enhances the sustamability of the community.


                           •     The issue  is as simple  as it is  complex in that the Department of Transportation never makes any transportation
                                 decisions  that do not  have something to do  with automobiles.  It  never looks  at more sustainable  forms of
                                 transportation like pedestrian, light rail, etc.


                           •     Agricultural sustamability is another factor that must be considered in the sustainable development model.


                           •     There may be a need for regulatory reform.  For example, the EPA Regulations for groundwater clean up - are they
                                 contrary to sustamability by being overly protective?


                                 3.3.2	Brownfields Program Issues


                           •     The initial $200,000  EPA Brownfields  grant is not a lot of money.  What can a community do with $200,000 but get
                                 itself educated about the process.


                           •     We need to figure out the Brownfields problem as societal issue.   There is a need to invest the time and money to
                                 get people educated on the issue of Brownfields.


                           •     If Brownfields redevelopment is to succeed, the private sector has  to be in the driver's seat.


                           •     There is an established fear of public taking.  There needs to be a way of addressing the Brownfields issue without
                                 scaring the owners.


                           •     Brownfields are not just an environmental problem.  The abandoned  sites are actually bringing  down the  entire
                                 neighborhood both economically and socially.
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                                 Federal agencies must be a part of the local process to help instruct, understand, and observe.


                                 An important problem is that there is no clear-cut set of definitions for the  Brownfields redevelopment process.
                                 There needs to be a glossary of terms. Brownfields should have a Global Environmental Exchange of information.


                                 EPA needs to define several issues for the benefit of the  program including: what the proposed incentives should
                                 be; what is  considered a successful project; and what role  EPA will have  (e.g., defer to the State, Federal oversight,
                                 regulatory lines of authority and responsibility)?


                                 There is a definite need to deal with the mechanisms that are used to fund projects.  Communities are not finding
                                 money for what they need - but lots of money for what they don't need.


                                 3.3.3	Brownfields Development Issues


                                 Brownfields cannot be viewed from a single-issue standpoint.  A larger perspective is needed.  For example, in the
                                 past, competition for development was primarily with other regions of the country or offshore.  Now, competition
                                 for manufacturing jobs is between the city and the local surrounding communities.  Every place around the city is
                                 encouraging industrial development.  There are many more rings of growth around  the metropolitan areas.  Small
                                 communities around the larger cities have now been able to replicate every metro area service available in every other
                                 community.


                                 The key question for attracting industrial development into the Brownfields areas is: What is it that they can not get
                                 elsewhere?"


                                 It is necessary to look at the entire picture.  You cannot departmentalize the decisions related to development. The
                                 need is to focus on the dynamics of the process.  Until you look at the problem from the perspective of all the
                                 districts  and until you get a multi-purpose plan for downtown, the downtown becomes just an office center.  This
                                 kind of single purpose development soon dies.


                                 A Brownfields project simply cannot compete with a greenfields project.  The pendulum  of change has not swung
                                 far enough  that greenfields are not still cheaper to develop. Brownfields development is not a viable project for the
                                 private sector; individual parcels are too small to generate the revenues needed for remediation.  It is necessary to
                                 leverage government funds (i.e., grants, loans, and loan guarantees) to help defray the costs  of remediating the site.


                                 Despite  the extent of sprawl development in the surrounding fringe  of most urban areas, the downtown district is
                                 the most central and still the most convenient access for most of the residents of the area.


                                 The timing of  development is another critical factor.  Suburban mall usage is down, so  this is  a good time to
                                 transition back to the downtown multi-attraction mall.  Downtown becomes the preferred site;  it is strategically
                                 located for  the convenience of the public.


                                 In order to  be successful, there must be somebody in the government sector that is committed to getting the project
                                 done.
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                                We  have  never had  infrastructure  in  the right location, in  the  right  capacity for  downtown  development.
                                Infrastructure is readily available for development in  the  suburbs (and is often subsidized by State and county
                                funds). But meeting new infrastructure requirements for downtown is expensive and often must be paid for by the
                                developer.


                                It is  rare to find a sponsor who wants to be a candidate for a Brownfields development; 95% of them want
                                greenfields with no contamination.


                                The key  to  development success is  that the community has committed people  -  people who care about  the
                                community.  There is also a need to have good municipal leadership.


                                As a result of a  catalyst project, the entire community redevelopment project emerges. A key (or anchor) project is
                                required.  There must be a public (stakeholder) buy in.  Then, small developments spring up throughout the region.
                                Local business and residents begin to invest in their own property once they see what is going to happen to  the
                                general area.


                                Predicting risk going forward is easier and it is easier to quantify the risk, rather than attempting to go back and
                                reconstruct the risk from past activity.


                                3.3.4	Landowner Issues


                                Liability issues remain a key component and a major hurdle for the redevelopment effort. People are still afraid of
                                the liability issues and it becomes a very legitimate consideration at sale.  People feel that the law changed once and
                                it will change again.  Despite whatever comfort letters or other indemnifications that may be presented, they may
                                become liable again for the contamination.  Non-profits are supposedly not liable -  but who really knows?  The
                                longer the period of voluntary compliance continues, the more comfortable people will become with the process.
                                The State voluntary cleanup program is a good idea, but it is worthless if the EPA  and the DOJ don't formally
                                recognize it with an MOU.


                                Absentee landlords that are holding land on speculation for future sale or development tend to keep a low profile
                                and are difficult to identify and track down.


                                In dealing with  the problem of owner intransigence, you need to have the money in one hand and a hammer in the
                                other (either a State agency or the EPA).


                                3.3.5	The Community  Perspective


                                The confidence level of the community  is important.  There is a "let's see what you can do" kind of attitude.  The
                                public's goals may also begin  getting higher as individual projects  are  completed successfully and expectations
                                increase.


                                In order to be successful, the development plan requires a "buy-in" on the part of the public at large.   You cannot
                                just eliminate the "nay-sayers."  A directed approach that focuses on certain groups is one successful approach to
                                gaining public consent.
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                           •    The key  orientation for the city government  is all  about jobs.   Any  industry is welcome but it  must be
                                environmentally state-of-the-art.


                           •    Planning and design using the charrette process and involving everybody  in the community is important to the
                                success of the project.  The belief is that everybody should have a seat at the table - and as many seats as they want.


                           •    It is difficult to get a buy-in on the entire plan; however, it is easier if you take one aspect at a time. The public has a
                                better understanding of individual pieces than it may have of the entire plan if presented all at once.


                           3.4  Project Summaries


                                3.4.1	Riverfront Development


                           •    Brownfields  is one  of a number of problems  that have been addressed as a part of the downtown redevelopment
                                project for Chattanooga.


                           •    The local community had both an image and a self-confidence  problem.  The area was once  declared the most
                                polluted city in the country.  By focusing on  the construction of the waterfront project and the aquarium, the overall
                                confidence of the community in the possible success of its plans was increased.


                           •    One impetus to begin the redevelopment process is based on a sense of urgency with respect to future development.
                                The city of Chattanooga  has assets that include extensive scenic beauty,  but precious little land for development.
                                The city is already losing some of the scenic  beauty to development pressure. There is  a perceived need to preserve
                                the scenic beauty of the area; the area is losing greenfields at a rate that is causing concern.


                           •    In 1982, a concerted effort was made to do something about the city.  A local foundation shifted its orientation to a
                                focus on the community  and moved other local foundations with it.  The waterfront became the most obvious place
                                to start a redevelopment plan.


                           •    The foundation set up a  company to formulate the plan  and  implement  downtown development.  The company,
                                established  as  a 501c(3)  company - not  for  profit, was  endowed by $10 million in private foundation money.
                                Although the effort was privately  funded, there was  also  representation from  multiple community  groups.


                           •    An emphasis was placed on the intangibles or subtleties of a project that  help it to succeed.  The question is what
                                makes it possible for a  mid-size community like  Chattanooga  to tackle major redevelopment.  There is  some
                                advantage due to the high degree of communication and coordination in the city.  Also having the same people
                                involved  in  Brownfields as  in  other  community development projects  is  an  advantage.    Small  to  mid-size
                                communities do find it a little easier to tackle problems and gain public confidence than do larger urban areas.


                           •    The planning exercise itself was development oriented.  The process matched two simultaneously  formed grass roots
                                efforts - one as part of a downtown redevelopment effort and the other with a goal of eliminating unfit housing in
                                the city within ten years.  The process became a National Model for Community Consensus Building.  People felt
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                                that they were a part of the effort. The public involvement served as a base for establishing the credibility of the
                                project and obtaining public support for future plans and proposals.


                                The project began with a two-year design process.  Using the available private resources, a plan was prepared and
                                presented to the public for review. The intent was to go where the private sector was normally not prepared to go.


                                A conference room is maintained in the offices of the Development Corporation that serves as a central meeting
                                room and conference facility for the downtown district.  Several displays show a before (or current) picture of a site
                                and a completed picture or artists conception of what the completed project will look like.  The primary purpose of
                                this facility is  to be a central place for any and all issues, meetings, etc., related to downtown and its development.
                                This includes public meetings and issue groups not directly related to the design process.


                                The public meetings focused on what "fixes" the residents would like to see implemented.  The emphasis was placed
                                on four  areas, people, places, government, and work.   (Examples: People - quality of life, human rights; Places -
                                parks, attractions, housing tracks).  The meetings received a genuine community response and genuine input to the
                                plan.  They provided an opportunity to review proposals and prioritize them.  From  the results  of the public
                                meetings a work plan was  developed.


                                The redevelopment plan  is part of a  20-mile waterfront project defined as Moccasin  Bend.  The  project, which
                                covers multiple eco-systems, was developed through the Lyndhurst Foundation.  The key issue was  that the public
                                would be allowed access back to the river. Existing structures along the waterfront had privatized the shoreline and
                                cut off public  access to the river. The total project cost was estimated at $750 million in '85 dollars.


                                The emphasis of the proposed plan was on a mixed-use development with the proposed new aquarium project as the
                                anchor.  An effort was made to keep national  franchises out of the  aquarium district in order to maintain  local
                                character and increase  opportunity for local entrepreneurship.  The  city put detailed  design  and development
                                restrictions on the  land.  This included  a requirement for a design review and a review of economic impact and
                                employment figures for any new development.


                                Chattanooga initially could not find developers willing to do anything.  They found they had  to try to do  it by
                                themselves and formed their own company.


                                One important question was that of what would attract people to downtown. The county has developed all of the
                                industrial sites in  the area, and 80-90% of county projects  are composed of people who have  relocated  from
                                downtown.


                                One important aspect of the plan is  the Architecture Review Committee.  The residents can  demand that new
                                entities in their own neighborhood conform to certain standards.


                                The Riverfront Development effort contributed to the overall city development, but it was not intended to compete
                                with the development of the downtown district.  Since  the planned growth in the city was primarily internal (not
                                dependent on outside business moving in) there was concern that spec building on the riverfront might attract
                                tenants from  the downtown core  where the existing office  and commercial centers are.  This would have the
                                potential to create new abandoned or underutilized properties downtown.  Through zoning changes, the city was
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SUMMARY   OF   ON-SITE  INTERVIEWS
                                able to  enforce  recreational  uses for the  waterfront  area, thus  not detracting  from office and  commercial
                                development in the downtown core.


                                The proposed riverfront plan emphasized the Aquarium as the  keystone  of the project.  It currently attracts an
                                additional revenue of $6,000 a day to the downtown area, as compared with  the initial cost of $45 million to build it.
                                In terms of the overall economic impact of the aquarium project, it is estimated that the completion of the aquarium
                                stimulated another $280 million in additional investment in the downtown area.


                                The city has seen a huge growth in sales and property tax revenues and feels that the money spent on redevelopment
                                since 1982 was well worthwhile.


                                3.4.2	Southside Development


                                Having accomplished the waterfront project, the new focus is on redevelopment of a 640-acre  tract on the south
                                side of the city.  The intention is to turn this area into an urban redevelopment zone. But, the planners want to
                                avoid the "condemn and bulldoze" variety of development.  The intention is to develop the area in line with a
                                mixed-use plan that emphasizes  reuse of existing structures wherever possible.  Another important concept is that
                                there will be no taking of owner occupied housing.  The plan is to work with residents to encourage them to stay in
                                the neighborhood.


                                The project is conducting an  environmental assessment (Phase  I)  on the  entire  640 acres at one time. The end
                                product is intended to produce a CD containing baseline environmental and land use data for the area - Sanborn
                                Maps.  The results of the survey will be incorporated into the city's GIS database.  Although most of the land in the
                                designated area is in private ownership, the Phase  I study will be conducted as a qua si-government agency effort
                                without asking any permission of the owners.


                                Some innovative solutions have been identified: ISTEA  funds were available for some projects;  highway right-of-
                                ways have been used for greenways (e.g., tree farming, agri-tech studies, etc.); the city has also been able to exchange
                                indemnification for contaminated land in some cases.


                                3.4.3	The Foundry Site


                                The Foundry Site redevelopment project  is one part of the overall Southside development effort.  The  site had a
                                100-year history of foundry activity, mainly cast iron, and was characterized  by a lot of waste and by-products of the
                                foundry operations. The sites original owner had no ability to do  anything with the site. The site was placed on the
                                CERCLIS list.


                                The State advised a cap on the site to prevent any water penetration, but the site was  designated for recreational uses
                                and the  city wanted a  green site with reuse of the existing buildings.  The site was to be developed as  a football
                                stadium. Development of the  site required extensive planning to incorporate green areas into the design.


                                For the parking areas,  a pervious concrete paving technology was adopted  to drain  water away from the site.  The
                                design concept was to develop an environment that allows for green growth, but  still controls  water infiltration.
                                There was some  risk in the original design, but the State remained open-minded about use of the new technology.
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                                The result was a unique design that  incorporated impervious pavement, semi-pervious capture areas, and water
                                storage in sub-soil storage cisterns where it could be retained for use during the dry seasons - a sustamability factor.


                                The project was unique in that it required extensive planing and cooperation between Federal, State, city, and county
                                officials, with the private sector putting up at least half of the money.


                                The architect had to do a lot of selling.  There was a need to convince the community at each point along the way.
                                What got the community moving was tying the project to an overall community effort that had a region-wide focus.


                                Essentially, the project tried to  include all stakeholders  and focus on the overall regional approach rather than on
                                just the site itself.  The end  result was that the originally conceived project,  which was to be about 20 to  80 acres,
                                was expanded and a plan for the redevelopment of the entire 680-acre Southside area was created.


                                3.4.4	The  Electric Bus System


                                The electric shuttle bus  system,  developed for use  in downtown Chattanooga, was a speculative  enterprise  in
                                conjunction with the city transit association. The system uses three parking lots - paid parking - to funnel traffic into
                                the  system.  Revenue from  the parking is  used to  subsidize free  ndership  on  the system.    The  system, initially
                                conceived  as  a downtown transit solution, has also become a social phenomenon in the city.  It has become  a
                                mechanism for social gatherings and  information exchange.  Downtown business people  use it to travel to the
                                riverfront for lunch - this helps build restaurants there that would otherwise have a lunch business only if they were
                                located in the office sector.


                                3.4.5.     The  Cavalier Development Project


                                The Cavalier site was formerly the largest industrial site (multi-parcel) in Chattanooga.  The site has had some long-
                                term environmental issues - specifically regarding groundwater.  The property contains 230,000-sq. ft. with 18 of 21
                                buildings on the site  already demolished. The initial estimate was  that  $4.6 million would  be required to get the
                                property into modern operational condition; some of this is cleanup cost.


                                The Cavalier  Site project used uncontammated portions of the site as collateral  for a bank loan.   The project
                                depended on  the unique quality of the banks  and the owner's financial stability to  leverage  additional funding.  It
                                was important to have a community based bank to make this kind of project work; no outside bank would have been
                                as knowledgeable or comfortable with the process.


                                The approach employed was to enter a voluntary compliance track with respect to the site by  encouraging owners to
                                come forth and  work jointly to address  cleanup.  The solution was to  put  the  land into public ownership with a
                                leaseback provision.  Public ownership  solved a lot of existing problems, and allows access to Federal and  State
                                funding to help remediate the site.
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                                 3.4.6      The Volunteer site fBRAQ
                                 The general approach is to treat these facilities as national assets - rather than liabilities.  The need is to market these
                                 sites to the local communities. The premise is that these sites should be recognized as an asset where they are now
                                 perceived as liabilities.


                                 Owners are beginning to realize that no matter what they do,  they have a permanent liability under the current
                                 regulations (i.e., whether they continue to own, sell, or do something else).  But if the orientation is changed, there
                                 are assets  here that can be developed into revenue that could be used to pay for the cleanup.


                                 The proper management of liabilities turns them into assets, assets can be turned into value, and value can be turned
                                 into work for local residents.


                                 In the revised  approach, you do  not remediate and you don't  ever sell the property.  Investment goes into the
                                 construction of new capital (buildings and equipment). What was a liability, now becomes an asset as the facility is
                                 leased back to a new operation.  The leaseback becomes an asset instead of the liability that remediation presented.


                                 An example is found in existing Federal sites. The government cannot sell them and it has no money to operate or
                                 remediate the sites.   If they call  in an  environmental company to remediate the site, they are still left with the
                                 liability. The better approach is to lease the  site and not remediate - spend all the money on  buildings. If there is a
                                 real threat, such as a moving plume, then address it; otherwise, if there is no emergency then leave the contamination
                                 where it is.  Essentially the lease continues while the asset value of the  land grows.  Over time, it equals the liability
                                 of remediation.


                                 The idea is never to spend money on cleanup while still retaining liability. The idea is to improve the value of the
                                 site until it equals the liability.


                                 One solution is that corporations  set up a land  trade.  They give the State title to one parcel  as a swap for the  lease
                                 on  another. The  State gets revenue for the lease and the company gets out from under the liability. In  another
                                 variation,  it is not necessary for the corporation to give up its assets  to the State.  Using the leaseback provision, the
                                 corporation can give the land to the State, but keep the capital equipment and leaseback the land on which  it  sits.


                                 The focus should be  on reusing  facilities  as assets rather than holding them as liabilities.  The Volunteer site
                                 remodeled several old Army buildings and leased them to the Hamilton County School Board.  In another example,
                                 it was possible to pay for the cost of having  an old building torn down with the revenue generated from the salvage
                                 metal inside - this actually generated income  and now has eliminated an eyesore.  Recycling can actually be a  form of
                                 financing  for the remediation and restoration requirements;  a sort of "Bootstrap financing."
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SUMMARY   OF   ON-SITE  INTERVIEWS
                          4.   Creation and Maintenance of a Brownfields Site Inventory

                               New Orleans, LA


                               Site Visit:   February 5 - February 8, 1998


                          4.1  Background


                          The  primary  focus of this project is the identification and categorization of Brownfields sites within the city of New
                          Orleans.  This effort is intended as part of a larger effort to improve the environmental quality of socioeconomically
                          disadvantaged communities in the city. The Brownfields Pilot Project Grant was awarded in September 1995.


                          The  project was proposed as a means of developing an inventory of Brownfields sites to be used in reclaiming land for
                          industrial or business use. The effort includes the development of criteria for ranking the sites in terms of their economic
                          development potential. A community outreach plan has  been developed and implemented for the purpose of obtaining
                          neighborhood input to the process of site identification and ranking.


                          According  to the 1990 Census, the population of  the city of New  Orleans  is 496,938.  Approximately 65% of the
                          population are  of African-American  descent, with  30% of the population at  or below poverty level  (based on an
                          approximate calculation).


                          4.2  Project Contacts:


                          Audrey Browder, Holy Ghost Community Resident
                          Allison Price, Office of Councilman Oliver Thomas
                          Eric Schneider, Special Projects Developer, Habitat for Humanity
                          Selim Berkon, Project Manager, Historic Restorations, Inc.
                          Gwen  Owens, Director, Mayor's Office of Urban Development
                          Timothy Jay Carney, Project Manager, Mayor's Office of Urban Development
                          Arnold Baker, Deputy Assistant to the Mayor for Business Development
                          GaryJ. McNamara, Assistant Vice President, Real Estate Finance, First NBC
                          Sandra Gunner, Gunner and Associates, New Orleans Brownfields Facilitator
                          Edward Jackson, New Orleans Brownfields Consortium member
                          Michelle V. Ennght, Deputy Director, Mayor's Office of Environmental Affairs
                          Abe  Tahir, Jr., AARP SEE Program


                          4.3  Summary of Major Themes


                               4.3.1	Brownfields Program Issues


                          •    A set of standard Brownfields models should be developed that are categorical so that a community could identify
                               itself according to different sets of criteria and then select a model that fits the profile. Categories could be based
                               on such things as the type of site, associated hazards, type of community, scale  of the project, etc.  The models
                               should  show how to  integrate  Brownfields into  an overall regional development model based on  economic,
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SUMMARY  OF   ON-SITE   INTERVIEWS
                                 transportation, and infrastructure  development.  Models can  help  the  community understand the development
                                 process and their own needs.


                           •     There is a need to  develop base criteria for the selection and operation of Brownfields grants or loans that provide
                                 guidance, yet still allow considerable flexibility in application. These could be similar to those found in HUD Section
                                 108.


                           •     Assistance is needed in the areas of assessing ecological, economic, and sociocultural resources; linking Brownfields
                                 redevelopment  into a comprehensive city plan;  and  in developing strategic  business plans  to  sell Brownfields
                                 redevelopment.


                           •     The current economic climate and project timing are critical factors to the success of a redevelopment effort.


                           •     Academic representation and  resources  are both helpful and  economical for the development of a project and
                                 involve both youth and advanced technology in the process.  Universities are usually a  couple of steps ahead of the
                                 city in urban planning and GIS technology.


                           •     There is a need for state-level Brownfields funding legislation and flexibility in how communities can apply funds to
                                 the redevelopment effort.


                           •     Information from  the initial  Pilot programs should be made  available; there  is a need  for  feedback from  EPA
                                 regarding process improvements in the Brownfields project.


                           •     More Brownfields  conferences should be conducted, but on a regional level to highlight issues and alternatives that
                                 are more regionally or locally feasible,  and to enable greater attendance.


                           •     A list of developers who are interested in developing Brownfields sites could be created and placed  on a WEB site
                                 in much the same  way that available properties are now being listed.  This would assist communities in identifying
                                 potential developers for their properties  who  are qualified and interested in becoming involved.  City agencies or
                                 owners could survey a list of developers before selecting one to develop a site.


                                 4.3.2	Community Involvement


                           •     The challenge is in getting the community to take responsibility for the appearance, vitality, and marketability of the
                                 community as a whole. It is important to overcome the "let someone else do it" mentality and make changes locally.
                                 Brownfields are often magnets for crime.  There is also a need for crime prevention and litter prevention programs.


                           •     The first meeting in a community is critical to  establishing trust and credibility;  trust must be earned as the process
                                 develops.


                           •     The general public  does not always  understand the risk; the health implications must be  translated into plain English.


                           •     It is not certain that all of the  community involvement in the program is essentially beneficial. At some point you
                                 have to limit the community's role  and listen to the developers.  With respect to the determination of cleanup levels
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SUMMARY  OF   ON-SITE   INTERVIEWS
                                it may be important to de-emphasize public participation and approach it more as a negotiating process with the
                                respective developer.


                           •    The problem of community involvement is that you wind up  dealing with the segments of the community that are
                                the most vocal. This does not always provide a true picture of the community's wishes. Developers may sometimes
                                have a better idea of how the project will move forward than does the community.


                           •    Training community residents  to  assist  in site screening, assessment and cleanup, is  a bottom-up or grass roots
                                approach to the problem.  It makes use  of the  community's existing knowledge of the problems and also increases
                                community awareness of what it takes to  resolve them — creates an inherent prevention mentality.


                                4.3.3	Environmental Justice


                           •    Environmental justice communities are  usually overburdened with some kind of environmental  problem.  This
                                becomes a serious issue depending on what kind of cleanup is contemplated.  There is really not a lot of room for
                                error on this issue.  It is necessary to deal with the issues as they come up, even if it slows down a project.


                           •    Environmental justice  is really a question  of how you respond to the cleanup problem and what or how cleanup
                                levels are established.


                           •    Risk concerns  are  primarily health related.  The relationship between good jobs and increased risk  does  not
                                necessarily hold up. Residents need to see the connection between good jobs and a healthy, safe community.


                                4.3.4	Benefits of the Planning Process


                           •    The focus  on the planning process itself  (as opposed to the plan output) is one key to a project's sustainability
                                because it is in the process that  the inhabitants of a  community become  involved.  The plan evolves as the
                                community needs change, thus enhancing its sustainability.


                           •    A comprehensive plan serves as technical assistance to potential developers by  setting consistent standards and
                                guiding them in understanding what the community wants.


                                4.3.5	Developer Participation and Commitment


                           •    Inherent in the process of inner city development is a developer that will work with or adjust to the city plan and is
                                willing to use alternative technologies.   The city should have a mechanism in place to assure that developers are
                                selected on the basis of qualifications.


                           •    The advantage  to developers is that they can get some pretty valuable real estate. The position here is positive and
                                differs somewhat from other projects.  Here the perspective is that the community has valuable real estate available
                                and has something that developers and investors should want rather than something that must be sold or marketed.


                           4.4  Project Summary
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SUMMARY  OF   ON-SITE   INTERVIEWS
                                4.4.1      Overview
                                The New Orleans Brownfields initiative is among the first major projects begun after the formation of the Mayor's
                                Office of Environmental Affairs, within the Department of Economic Development.  The Office of Environmental
                                Affairs was established at the urging of the Mayor and has a strong commitment from the city government.


                                The Mayor's  Office of Economic Development wants  the Brownfields  project  to  be a part of the  overall
                                redevelopment of the city. The first priority is to sustain the viability of the city as the  core of a regional economy
                                and society. The Brownfields program serves as an incentive to refocus development back into the city.


                                The Brownfields process  was initiated in the summer of 1996 by a push  from the Mayor's Office.   Initially they
                                wanted to identify 10 sites as demonstration Pilot Projects.  A key element of the project was to correct a lot of past
                                wrongs and to get the right people involved in the future.


                                The formation of the  New Orleans Brownfields Inventory Consortium was the initial  step in getting the  project
                                started. The primary objective was that the Brownfields effort should be a comprehensive process.


                                 The authority for the Consortium is a charter by the Mayor's Office through the Office of Environment.  The
                                Consortium is the city authority for Brownfields. They are charged with formulating a marketing plan, describing
                                their view of what the  community should look like.  They have the freedom to act as they see fit, independently of
                                the city government.


                                New Orleans is a  unique city because  of  the tightly  structured neighborhood communities  and the  strong
                                identification of its citizens with local neighborhoods.


                                Each neighborhood elected a representative to serve on the Brownfields consortium.  Ground rules  were developed
                                for how the Consortium would operate, including the weighting criteria applied to different stakeholders, and the
                                selection of delegates with voting privileges.


                                The primary basis of the effort is the neighborhood town meeting.  The proposed identification of Brownfields sites
                                is  through  input  from these  neighborhood groups.   Neighborhoods  essentially drove  the process.   Each
                                neighborhood brings its own unique characteristics  to the Brownfields process.   The project also  relied  on the
                                historical memory of residents for the description of previous site activities.


                                A priority of the city's Environmental Development Office is greenspaces.  The  office is cooperating with other
                                groups to establish "pocket parks" and gardens, and to try to set aside money for city maintenance. Several places
                                exist in the city that are amenable to pocket parks. Safe greenspaces are important to the city, but public safety and
                                maintenance costs are the biggest impediments to public parks.


                                New Orleans  as  a green city; there are pristine  areas within ten miles of the city that offer a potential for eco-
                                tounsm.  The department of the Environment is proposing a green map of the city to help get out the word. The
                                greening process  is definitely dependent on education and valued experience.


                                4.4.2	City of New Orleans Plan Development
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SUMMARY  OF   ON-SITE   INTERVIEWS
                                The city is currently working on the development of a new strategic plan to cover 25 neighborhoods.  The plan
                                involves a neighborhood audit (walk through) and a  grass roots planning  effort as  the  key components.  The
                                neighborhoods  will determine what the issues are  and decide what elements they want to  address.  Potential
                                developers must show evidence that their plan  for a  site has been  taken  to  the  community for review.  The
                                community can reject a developer's proposal following review.


                                The project developed Comprehensive Strategic Community Plans with Brownfields as a key central point. The use
                                of formal neighborhood meetings  was effective in developing the  needs assessment and components of the
                                Comprehensive Strategic Plan.


                                4.4.3	The Urban Development Initiative


                                The focus of the city's economic development effort is job creation. An active outreach effort takes meetings and
                                programs out into community to develop a broad  working base within community.  The  city has reactivated its
                                Industrial Development Board and created a Developers Forum that will include a Brownfields session, GIS maps
                                of the city with Brownfields pieces shown, and a presentation of current and future redevelopment opportunities.


                                The city is gathering information for the creation of new databases  from the GIS system.  It is identifying city
                                owned or city-leased buildings, Brownfields, and Federally owned properties.  A map is being prepared to identify
                                these properties, community-wide.


                                The city is finding many groups that are looking for investment opportunities;  there is  also a need to provide
                                assistance to existing resident businesses on how to diversify and remain competitive. The city created the Office of
                                Small Emerging Business Development to identify investors in the local community.


                                One incentive to development is the Restoration Tax Abatement Program.  This  allows the city to put a hold on
                                taxes for up to ten years.  Rates are held at pre-construction levels for 5 years  in the case of residential development
                                and an additional 5 years  for  commercial  development.   This  program  has  encouraged major development
                                downtown. The total abatement versus the total reinvestment in the city turns out to be a plus for the city.


                                4.4.4	The Developer's Perspective


                                Developers are currently making money by bringing people back into the city.  The philosophy is that if the city dies,
                                eventually so does everything else surrounding the city.  The developer's interest in a site is because it is potentially a
                                profitable development site, not necessarily because it is a Brownfields  site.


                                The issue of displacement is less important when dealing with abandoned industrial properties. Renovation of these
                                properties contributes to  the strengthening of the original community by providing a new residential component
                                (i.e., a higher income population like artists/academics attracted to unique redeveloped areas).


                                The Consortium  needs to provide assistance to contractors in understanding what Brownfields means  to the
                                development of the site.  The question is what does the  Brownfields initiative bring to  the table that is more than
                                what was  there before.
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SUMMARY  OF   ON-SITE   INTERVIEWS
                                4.4.5	The Financial Institution Perspective


                                An important element was to define for the Consortium what the financial community could and could not do -
                                essentially to get expectations in line with reality. The bank provided guidance on how to look at the site from the
                                standpoint of the investor/developer - what is financially possible and what is not? The bank helped to define what
                                would be realistic to finance; and defined what a "bankable situation" is for given locations. The bank also assisted
                                with the development of realistic  rules or  RFP guidelines, and guidelines about how project money could best be
                                utilized.


                                The bank informed the project on what made sense from the banker's perspective, but did not get involved with the
                                day-to-day activities and politics of the Consortium.  It also offered criteria pertaining to real estate principles  to
                                help the site selection process, but left the Consortium alone to work through the selection process.


                                The community itself is usually more comfortable working with local banking institutions  that have a good track
                                record in a community.


                                Money is a finite resource; the bank is looking for the best return on its investment, both in terms of a capital return
                                and in terms of the community's attitude toward the bank.


                                From the perspective of the  commercial real estate investor, each site has many different potential uses/directions
                                for redevelopment.   It  is important  to consider  the viability of investment in all  the possible redevelopment
                                strategies, including the environmental remediation process itself.  From experience, the bank has learned that it is
                                not just the property, it's also the surrounding land area that makes the difference in a loan.


                                The repayment of the loan is the major issue for the bank.  It is important to understand the process that the bank
                                has to go through to get a loan paid — identification of the risks, loan-underwriting criteria, the loan process itself,
                                and how the repayment will be made. There must be a sound basis for repayment including sufficient cash flow and
                                some long-term equity component something that creates an equity value (i.e., can be reused or will retain value).
                                The bank will also look at any included grants and loan guarantees.


                                The perceived level of contamination has scared off many investors haphazardly. Banks especially have always been
                                the deep pockets at the end of the tunnel.  They  need some  "safe harbors"  from environmental liability.  Now,
                                banks are excused if the acquisition is involuntary (e.g., foreclosure).


                                To satisfy the requirements of the loan, the  investor is looking for the adequacy and competency of the cleanup.
                                There  must be full cleanup to expected land use requirements.   On a limited use project, Phase I and Phase  II
                                assessments are essential.  A limited cleanup to risk-based, re-use development levels  is possible but this poses an
                                additional capital expense — risk varies on a case by case basis.


                                4.4.6	Environmental Justice


                                The city Open Access Program was  created  in response  to  the need to include  women and minorities  in the
                                business/entrepreneurial activity associated with redevelopment.   Created by an Executive  Order of the Mayor, it
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APPENDIX   F
SUMMARY  OF   ON-SITE   INTERVIEWS
                                includes Worn an/Minority Equity Investor Goals as well as Employment Goals.  It is part of an active effort to
                                avoid  gentnfication  in  city  programs and increase the  opportunities  for home  buying  in lower  income
                                neighborhoods, as well as to aid the development of local entrepreneurial efforts.


                           •    There  is concern  for minimizing or avoiding displacement of residents.  A "first right of refusal" principle and
                                savings/loan incentives are being used by the city to help long term residents resettle in redeveloped properties.


                                4.4.7	Potential Impediments to Brownfields


                           •    A major impediment was not having enough information; specifically information about the Brownfields program
                                itself.  The  Consortium  felt that it understood much more after the National Brownfields Conference  in Kansas
                                City.  There is a general opinion that the Consortium needs more information on the relationship of Brownfields to
                                Empowerment Zones, tax incentives, development process, etc.


                           •    The Consortium  is understaffed  and depends on support from its parent government agency, the Environmental
                                Office. The Consortium needs the resources to develop its own staff.


                           •    Liability is still a key issue. There is no clear picture  of how the owners will fare  in the process.


                           •    Most people are very territorial; the neighborhoods are especially sensitive.  Participation in the community network
                                helped overcome these sensitivities and established the program's credibility in the individual neighborhoods.


                           •    It is not possible to address just one problem in an area. There is a need to address the area as a whole; to  work with
                                neighborhoods to do a comprehensive needs assessment.  In order to succeed, it is also important to watch other
                                community groups that are active in the area to see what they are doing.


                                4.4.8	Development Strategies


                           •    New Orleans is basically asking developers to put all their chips on the table (i.e., show all aspects of their proposed
                                plan) and get involved in the community process.


                           •    The city has created a Brownfields Day to  help advertise the program and show the potential for development and
                                support in New Orleans.  They are planning 16 booths for environmental professionals and developers  to discuss
                                issues  with  participants as well as representation by government agencies and universities with related  programs.
                                Workshops  will demonstrate how the Federal program works.


                           •    One strategy being considered is to look at more incentives for the non-profit sector as a source  of development.
                                For example, Habitat  for Humanity has  already constructed 27 units throughout the city in  the years since  its
                                inception.  The  type of site  that is normally identified as a Brownfields site  is amenable to the construction of
                                multiple houses simultaneously (what Habitat calls "Blitz Building"), increasing the efficiency of the volunteer labor
                                that such organizations may have available.


                                 4.4.9     Prevention  of Future Brownfields
                                                                   F-31

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APPENDIX  F
SUMMARY   OF   ON-SITE   INTERVIEWS
                          •    A key element is the effort to increase  public  awareness  of the problem  and the solutions  that are being
                               implemented.  For example, Brownfields Day which is proposed as a mechanism for getting out the word on the
                               problem.


                          •    One mechanism that  has been explored is the setting aside of specific lands for preservation and future green-
                               development.


                          •    The creation of an environmental code for the city will help  in reducing the number of abandoned sites.  One
                               example of this technique is found in New Jersey where some  controls  have been placed on industries leaving the
                               state. There is an attempt to set up the same conditions in Louisiana.


                          •    The development of a Strategic  Enforcement Program to  control the  environmental quality of Brownfields
                               properties after cleanup and redevelopment is being implemented. The  effort is to clean up sites to prevent future
                               abuses (trash tends to attract trash).


                          5.   Site Inventory, Characterization, and Development Potential for Communities in the

                               Woonasquatucket and Blackstone Watersheds

                               State of Rhode Island


                               Site Visit:  January 30, 1998


                          5.1  Background


                          The objective of this project is to return under-used, contaminated properties  to productive use with particular emphasis
                          on the reuse or recycling of the multiple abandoned mill sites and structures that are found along the Woonasquatucket
                          and Blackstone Rivers. The subject area is part of a proposed plan to create a greenway along the Woonasquatucket River.
                          The Brownfields Pilot Grant was awarded in June 1996.


                          The goal of the Pilot Project is to create a model plan to identify and characterize sites  for contamination and market
                          potential.  The strategy developed will allow for accurate determination of present levels of contamination and accurate
                          estimates of the associated  clean up costs.  When completed, the  strategy will  represent a transferable model for site
                          characterization and remediation that could be used by other Brownfields Communities.  The project is also attempting to
                          leverage additional resources and  support to continue to address Brownfields redevelopment in the affected communities
                          of the watershed areas of the two rivers.


                          The population of the State of Rhode Island is 1,003,464 according to the 1990  Census. Approximately 8.6% of the State's
                          population are minority, with approximately 9.2% living at or below the poverty level.


                          5.2  Project Contacts:


                          Timothy Reagan, Principal Engineer, State  of Rhode Island, Department of Environmental Management, Office of Waste
                          Management
                          Jane B. Sherman, Project Director, Woonasquatucket River Greenway Project
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APPENDIX   F
SUMMARY   OF   ON-SITE   INTERVIEWS
                           5.3  Summary of Major Themes
                                5.3.1	Lessons Learned from the Pilot Project experience


                           •    One mechanism for the initialization of a project is  to  start by building a connection to the urban community.
                                Identifying central  issue groups that  already  have  connections to the community can be  useful  in  terms of
                                developing an identity and establishing the proposed project's  credibility with the community.  The Brownfields
                                agenda can be integrated into  the  larger plan/agenda of these other local groups.   The project  focus  can be
                                addressed to these groups to make use of group  meetings and networks that are  already established.


                           •    The planning departments in most cities are overworked and are probably not in a position to be very helpful to the
                                project. It is important to connect with the city  economic development people.


                           •    If a new Brownfields organization cannot be created, use other people's organizations to get started.


                          •     An ecosystem-based approach, focused on water resources, may not always work successfully with urban sites.


                          •     It is important to keep  the focus of the project concentrated on abandoned properties.


                          •     EPA's concern  about recovering  Federal cleanup  costs  from owners or  responsible  parties  complicates the
                                Brownfields effort.


                           •    The worst part of the Brownfields process is getting to the cleanup stage.


                           •    The role of the city government is critical in obtaining commitment to acquire properties, overcoming difficulty and
                                delays in getting to the  right person for decisions/guidance, and in funding remedial design plans.


                           •    The ideal Brownfields site has no owner, and is ready to be taken over by the city.


                                5.3.2	Environmental Justice


                           •    Environmental justice continues to be a significant problem.  Local community groups often do not want to discuss
                                economics. Although the neighborhood needs jobs, it also needs greenspaces.




                           5.4   Project Summary


                                5.4.1	Overview


                           •    A decision was made to employ an ecosystem-based approach to redevelopment planning because most Brownfields
                                sites under consideration are old mills  adjacent to rivers.  Most  of the mills that were still structurally viable have
                                already been re-utilized, so  the project  had to focus  on those sites  that  had  some sort  of problem, either
                                contamination, structure, or accountability.
                                                                   F-33

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APPENDIX  F
SUMMARY  OF   ON-SITE   INTERVIEWS
                           •    The old mill sites offered significant architectural and other features that made them attractive for redevelopment.
                                The mill sites were mostly woolen mills that have good public accessibility and are therefore also a direct threat of
                                human exposure to contaminants.


                           •    The Brownfields project included the nomination of candidate sites by the five  municipalities  (one from  each
                                county) that were included  in the project partnership.  Using previously established Brownfields criteria; the initial
                                list of 120 nominated sites  was reduced to 50 sites that represented viable Brownfields type problems.  A  further
                                reduction of the site list was made on the basis of the condition of existing facilities, socioeconomic factors and
                                infrastructure considerations.


                           •    Two target sites have been identified; one is a typical inner city neighborhood site, with known contamination
                                problems, that the city intends to purchase in cooperation with  a third party community group; and the other is a
                                fairly isolated site located near a public park and some tough public housing.  Both sites are located in a flood  plain
                                along the river.   Currently,  these sites have little to no marketability due to location, the estimated cost of cleanup,
                                the lack of greenspace, and  thew unattractive  appearance of the neighborhood.  The surrounding residential area is
                                very built up but with a number of old dwellings many of which are abandoned.


                           •    Areas of significant concern during the project included: housing problems, site accessibility, a waterfront location -
                                but also located in a floodplain, potential transportation impacts, and the need for greenspace.


                                5.4.2	The Providence Plan


                           •    The Providence Plan was identified as a pre-existing community group that was already working in  the affected
                                neighborhoods.  The plan addresses issues of the inner city urban development process. The goal is to establish new
                                directions for housing and urban development.  The organization is also  investigating welfare to  work issues -
                                matching skills and jobs.


                           •    A cooperative  project  with the  Brownfields Pilot  Project  was  established.   The  Providence Plan provided
                                socioeconomic  expertise; the Department of Environmental  Management  provided the environmental/technical
                                expertise.


                           •    The project keyed on the river as an asset that, if used properly, could be a catalyst for redevelopment of the target
                                neighborhood.  The vision was a  Waterfront Park in downtown Providence


                           •    The larger goal was to convert the subject neighborhood into a place where people would again want to live.


                                5.4.3	External Support


                           •    Local university students  supported  the  site redevelopment-planning project.  Working  in conjunction  with a
                                graduate supervisor, they participated in the site identification and screening process.
                                                                    F-34

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APPENDIX  F
SUMMARY  OF   ON-SITE   INTERVIEWS
                           •     Operating primarily on grants, the project is  required to juggle a number of variables  including the differing
                                 time frames of grants, the overall activity, and the involvement of other community organizations that are dependant
                                 on grants.


                           •     The project is interested in tying into additional sustainable development grant money that may be available such as
                                 EPA's Urban Environmental Initiative.


                                 5.4.4	State Department of Environmental Management (RIDEM)


                           •     The State remediation  regulations  have been amended  to  include  enforcement and  cleanup  standards.   The
                                 Department has also published a road map on how to comply with these regulations.


                           •     State  regulations require that a Remedial  Evaluation Report  be prepared for any site;  the  owners  or  a State
                                 representative can prepare the report.


                           •     Cleanup levels are authorized to either restricted industrial or unrestricted residential use. The finding is that a lot of
                                 owners/developers will dig a little more for an unrestricted use permit.


                                 5.4.5	Recommended Pilot Site Expansion


                           •     Several important areas need to be addressed including testing the theory on other ecosystems, site ownership and
                                 recouping costs  from the owners.


                           •     The plan is to expand by acquisition of three to four sites with mills that are still standing,  in order to broaden the
                                 project's experience with different sites.


                           •     The project is also looking for more information on how to locate a business in a big mill building.
                                                                   F-35

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APPENDIX  F
SUMMARY OF
                   ON-SITE  INTERVIEWS
                                                F-36

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APPENDIX   G
LOCAL  CONTACTS   FOR  BROWNFIELDS  PROJECTS
                         This appendix presents selected contacts for the Brownfields Projects that have been referenced in this report. They

                         represent the most recent addresses available at the time this report was printed.  In addition, information may also be

                         obtained from the EPA Regional Brownfields Coordinators and EPA National Headquarters contacts listed below.
BeownSdds PrqectCcraads
                         BALTIMORE, MARYLAND

                         Brownfields Project Director
                         Baltimore City Department of Planning
                         417 East Fayette Street, 8th Floor
                         Baltimore, MD 21202-3433                     Telephone:  (410)396-4367
                         BOSTON, MASSACHUSETTS

                         Brownfields Coordinator
                         City of Boston, Office of Environmental Services
                         Boston City Hall, Room 603
                         Boston, MA  02201                            Telephone:  (617)635-3425

                         The Dudley Street Neighborhood Initiative
                         513 Dudley Street
                         Roxbury, MA 02119                           Telephone:  (617)442-9620
                         BRIDGEPORT, CONNECTICUT

                         City of Bridgeport, Office of Planning and Economic Development,
                         c/o BERC
                         10 Middle Street, 1st Floor
                         Bridgeport, CT 06604                          Telephone:  (203)335-1462
                         BUFFALO, NEW YORK

                         Office for the Environment
                         920 City Hall, Room 907
                         Buffalo, NY 14202                            Telephone:  (716) 854-5633
                         BURLINGTON, VERMONT

                         Community and Economic Development Office
                         City Hall, Room 32
                         Burlington, VT 05401                          Telephone:  (802)865-7144
                         CAPE CHARLES - NORTHAMPTON COUNTY, VIRGINIA

                         County Administrator, County of Northampton
                         16404 Courthouse Rd., P.O. Box 66
                         Eastville, VA 23347                            Telephone:  (757)678-0440

                         Executive Director,
                         Joint Industrial Development Authority of Northampton County and Its Incorporated Towns
                                                               G-1

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APPENDIX   G
LOCAL  CONTACTS   FOR  BROWNFIELDS   PROJECTS
                         16404 Courthouse Rd, P.O. Box 538
                         Eastville, VA 23347
Telephone:  (757) 678-0477
                         Director, Northampton County Department of Sustainable Economic Development
                         23 Park Row
                         Cape Charles, VA 23310                        Telephone:  (757)331-1998
                         CHARLOTTE, NORTH CAROLINA
                         City of Charlotte, Economic Development Division
                         600 East Trade Street
                         Charlotte, NC 28202
Telephone:  (704) 336-3955
                         CHATTANOOGA, TENNESSEE
                         Chief of Staff, City of Chattanooga
                         Suite 100, City Hall
                         Chattanooga, TN 37402

                         RiverValley Partners, Inc.
                         One Central Plaza, Suite 800
                         835 Georgia Avenue
                         Chattanooga, TN 37402
Telephone:  (423) 757-5152
Telephone:  (423) 265-3700
                         CLEVELAND, OHIO

                         Director of Economic Development,
                         City of Cleveland, Department of Economic Development
                         601 Lakeside Avenue,  Room 210
                         Cleveland, OH 44114                          Telephone:  (216)664-2406
                         GREENFIELD, MASSACHUSETTS

                         Town of Greenfield, Office of Planning and Community Development
                         277 Mam Street, 4th Floor
                         Greenfield, MA 01301                          Telephone:  (413) 772-1548
                         NAVAJO NATION, ARIZONA

                         Executive Director, Navajo National Environmental Protection Agency
                         Window Rock Boulevard
                         Window Rock, AZ 86515                        Telephone:  (520) 871-7692
                         NEW ORLEANS, LOUISIANA
                         Director, Mayor's Office of Environmental Affairs
                         1300 Perdido Street, Suite 8E06
                         New Orleans, LA 70112
                         Director, Mayor's Office of Urban Development
                         1515 Poydras Street, Suite 1200
                         New Orleans, LA 70112
Telephone:  (504) 565-8115
Telephone:  (504) 565-6940
                         OREGON MILL SITES, OREGON

                         Project Manager, RDI Millsite Conversion
                         1047 West Lookmgglass Road #3
                         Roseburg, OR 97470
Telephone:  (541) 677-9648
                         RHODE ISLAND BROWNFIELDS PILOT
                                                               G-2

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APPENDIX   G
LOCAL  CONTACTS   FOR   BROWNFIELDS   PROJECTS
                         Project Director
                         Woonasquatucket River Greenway Project
                         56 Pine Street, Suite 3B
                         Providence, RI 02903                           Telephone: (401)455-8
                         STATE OF RHODE ISLAND

                         State of Rhode Island, Department of Environmental Management
                         Office of Waste Management
                         235 Promenade Street
                         Providence, RI 02908-5767                      Telephone: (401)277-2797
                         TRENTON, NEW JERSEY

                         City of Trenton, Department of Housing and Development
                         319 East State Street
                         Trenton, NJ 08608                              Telephone:  (609) 989-3509
                         WEST CENTRAL MUNICIPAL CONFERENCE, ILLINOIS

                         West Central Municipal Conference
                         1127 South Mannheim Road,  Suite 102
                          Westchester, IL 60154                          Telephone:  (708) 450-0100
EPAR^cnalBtownSdds Gxttfoafats
                         REGION 1: Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont

                         EPA Regional Brownfields Team
                         U.S. Environmental Protection Agency Region 1
                         John F. Kennedy Federal Building
                         One Congress St.
                         Boston, MA 02203                              Telephone:  (617) 573-9681


                         REGION 2: New Jersey, New York, and the territories of Puerto Rico and the U.S. Virgin Islands

                         EPA Regional Brownfields Team
                         U.S. Environmental Protection Agency Region 2
                         290 Broadway, 18th Floor
                         New York, NY 10007                           Telephone:  (212) 637-4360


                         REGION 3: Delaware, Maryland, Pennsylvania, Virginia, West Virginia, and the District of Columbia

                         EPA Regional Brownfields Team
                         U.S. Environmental Protection Agency, Region 3
                         841 Chestnut Building
                         Philadelphia, PA 19107                          Telephone:  (215) 566-3001


                         REGION 4: Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, and Tennessee

                         EPA Regional Brownfields Team
                         U.S. Environmental Protection Agency, Region 4
                         61 Forsyth Street
                         Atlanta, GA 30303                              Telephone:  (404) 562-8661


                         REGION 5: Illinois, Indiana, Michigan, Minnesota, Ohio, and Wisconsin
                                                                G-3

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APPENDIX  G
LOCAL   CONTACTS   FOR   BROWNFIELDS  PROJECTS
                          EPA Regional Brownfields Team
                          U.S. Environmental Protection Agency, Region 5
                          Brownfields and Early Action Section
                          77 West Jackson Boulevard
                          Chicago, IL 60604                              Telephone: (312) 353-3161
                          REGION 6: Arkansas, Louisiana, New Mexico, Oklahoma, and Texas

                          EPA Regional Brownfields Team
                          U.S. Environmental Protection Agency, Region 6
                          1445 Ross Avenue,  Suite 1200
                          Dallas, TK 75202                     Telephone: (214) 665-6660
                          REGION 7:  Iowa, Kansas, Missouri, and Nebraska

                          EPA Regional Brownfields Team
                          U.S. Environmental Protection Agency, Region 7
                          726 Minnesota Avenue
                          Superfund Division
                          Kansas City, KS 66101                          Telephone: (913) 551-7603
                          REGION 8: Colorado, Montana, North Dakota, South Dakota, Utah, and Wyoming

                          EPA Regional Brownfields Team
                          U.S. Environmental Protection Agency, Region 8
                          999 18th Street
                          Suite 500
                          Denver, CO 80202                              Telephone: (303)312-6931
                          REGION 9: Arizona, California, Hawaii, Nevada, and the territories of Guam and American Samoa

                          EPA Regional Brownfields Team
                          U.S. Environmental Protection Agency, Region 9
                          75 Hawthorne Street
                          San Francisco, CA 94105                        Telephone: (415) 744-2237
                          REGION 10:  Alaska, Idaho, Oregon, and Washington

                          EPA Regional Brownfields Team
                          U.S. Environmental Protection Agency, Region 10
                          1200 Sixth Avenue
                          Seattle, WA 98101                              Telephone: (206) 553-6523
EPANationalHeadquarters
                          U.S. Environmental Protection Agency
                          Office of Solid Waste and Emergency Response
                          Outreach and Special Projects Office (5101)
                          401 M Street SW
                          Washington, DC 20460                          Telephone:  (800) 424-9346
                                                                                    (Superfund Hotline)
                                                                 G-4

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