School Siting
Guidelines
United States
Environmental Protection
Agency
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Contents
1. About the School Siting Guidelines [[[ 1
1.1. Who Should Use the Guidelines? [[[ 2
1.2. Limitations of the Guidelines [[[ 2
1.3. Public Involvement in the Development of the Guidelines [[[ 4
1.4. Principles behind the Guidelines [[[ 5
2. Overview of the School Siting Guidelines [[[ 13
2.1. Introduction [[[ 13
2.2. Overview for Considering Environmental Factors in the School Siting Process ........................... 14
3. Meaningful Public Involvement [[[ 19
3.1. Overview [[[ 19
3.2. Establishing a Public Involvement Strategy [[[ 20
3.3. School Siting Committee [[[ 20
3.4. Communications Plan [[[ 22
3.5. Consideration of Community Information Accessibility Issues [[[ 23
3.6. Technical Assistance and Training [[[ 24
3.7. Designation of Opportunities for Meaningful Public Input and Budget for
Public Involvement Activities [[[ 24
4. Environmental Siting Criteria Considerations [[[ 33
4.1. Overview [[[ 33
4.2. Before the Siting Process Begins [[[ 34
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5.10. Stage 6: Long-term Stewardship 92
6. Evaluating Impacts of Nearby Sources of Air Pollution 95
6.1. Overview 95
6.2. Location Layout and Study Area 97
6.3. Initial Assessment of Area Air Quality 97
6.4. Inventory of Air Pollutant Sources and Emissions 98
6.5. Screening Evaluation of Potential Air Quality 100
6.6. Development of an Environmental Assessment Report 102
7. Recommendations for States and Tribes 105
7.1. Overview 105
7.2. Recommendations for States 105
7.3. Recommendations for Tribes Ill
8. Quick Guide to Environmental Issues 117
8.1. Air Pollution 117
8.2. Nearby Highways and Other Transportation Facilities (Including Goods Movement) 118
8.3. Volatile Organic Compounds (VOCs) in Soil and Ground Water 120
8.4. Radon 121
8.5. Petroleum Hydrocarbons in Soil and Ground Water 121
8.6. Lead-based Paint Hazards and Lead in Soil and Drinking Water 122
8.7. Polychlorinated biphenyls (PCBs) in Fluorescent Light Ballasts,
Window Caulking and Soil Associated with Older Buildings 123
8.8. Asbestos-Containing Material Surveys 124
8.9. Mold 124
8.10. Chemicals in Schools 124
8.11. Heavy Metals in Soil and Ground Water 125
8.12. Pesticides 125
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9.4. Will EPA's School Siting Guidelines prevent pollution generating facilities
from being built near existing schools? [[[ 130
9.5. What can I do to protect my child right now from environmental hazards at
their current school? [[[ 131
9.6. Shouldn't schools be built as far away from major pollution generating sources
as possible? [[[ 132
9.7. Isn't an uncontaminated site always the best location for a new school? ..................................... 133
9.8. Can schools be safely built on sites with residual soil or ground water contamination? ....... 134
9.9. In cases where the best available location for a school relies on engineering and/or
institutional controls to prevent potential exposures, how can the community work
with the LEA and other responsible entities to ensure that those controls are effective
for the life of the school? [[[ 134
9.10. What cleanup or remediation of contamination at a school site should be
completed before the school is occupied? [[[ 134
9.11. To what cleanup standard should school sites be remediated? [[[ 135
9.12. Does EPA recommend buffer or exclusion zones (also sometimes called distance
criteria or separation distances) to make sure schools aren't built close to major
sources of pollution? [[[ 135
9.13. What is the difference between "screening perimeters," which are included in the
guidelines, and "buffer" or "exclusion" zones? [[[ 136
9.14. The School Siting Guidelines place a lot of emphasis on state and tribal involvement
in evaluating and approving siting decisions where environmental contamination is
present. At a time of shrinking state and tribal budgets, how are states and tribes to
meet the anticipated demand for more involvement? [[[ 136
9.15. Do the guidelines apply to child care centers or other facilities where children
spend time? [[[ 137
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Exhibits
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Exhibit 1: Overview of the Siting Guidelines 15
Exhibit 2: Meaningful Public Involvement Points and Opportunities 25
Exhibit 3: Example Enrollment Area that Creates a Prohibitively Long Walking/
Biking Trip for Some Students 41
Exhibit 4: Desirable Attributes of Candidate Locations 44
Exhibit 5: Factors Influencing Exposures and Potential Risks 49
Exhibit 6: Screening Potential Environmental, Public Health and Safety Hazards 53
Exhibit 7: Stages of Site Review 69
Exhibits: Stage 1: Project Scoping/Initial Screen of Candidate Site 70
Exhibit 9: Stage 2: Preliminary Environmental Assessment 72
Exhibit 10: Stage 3: Comprehensive Environmental Review 78
Exhibit 11: Stage 4: Develop Site-specific Mitigation/Remediation Measures 84
Exhibit 12: Stage 5: Implement Remedial/Mitigation Measures 89
Exhibit 13: Stage 6: Long-term Stewardship 92
I Contents
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Acronyms
ADA Americans with Disabilities Act
AHERA Asbestos Hazard Emergency Response Act
AQI Air Quality Index
ASTM American Society for Testing Materials
CDC Centers for Disease Control and Prevention
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
CHPAC Children's Health Protection Advisory Committee
CHPS Collaborative for High Performance Schools
DOD Department of Defense
DOT U.S. Department of Transportation
EISA Energy Independence and Security Act
EPA U.S. Environmental Protection Agency
ESA Environmental Site Assessment
FUDS Formerly Used Defense Sites
HAPs Hazardous air pollutants
HealthySEAT Healthy School Environments Assessment Tool
HEI Health Effects Institute
HVAC Heating, ventilating and air conditioning
IPM Integrated pest management
LEA Local education agency
LEED Leadership in Energy and Environmental Design
LTSP Long-term Stewardship Plan
NAAQS National Ambient Air Quality Standards
NATA National Air Toxic Assessment
NEI National Emission Inventory
NIOSH National Institute of Occupational Safety and Health
PCB Polychlorinated biphenyl
QA/QC Quality assurance and quality control
RCRA Resource Conservation and Recovery Act
SARA Superfund Amendments and Reauthorization Act
SSC School Siting Committee
USGBC U.S. Green Building Council
VOCs Volatile organic compounds
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1. About the School
Siting Guidelines
In December 2007, Congress enacted the Energy
Independence and Security Act (EISA).1 Among
the provisions included in the Act was a
requirement that the U.S. Environmental
Protection Agency (EPA) develop, in consultation
with the Departments of Education and Health
and Human Services, model guidelines for the
siting of school facilities that take into account:
1. The special vulnerabilities of children to
hazardous substances or pollution exposures
in any case in which the potential for
contamination at a potential school site exists;
2. The modes of transportation available to
students and staff;
3. The efficient use of energy; and
4. The potential use of a school at the site as an
emergency shelter.
In carrying out this statutory mandate, EPA has
developed voluntary School Siting Guidelines that
will encourage, inform and improve consideration
of environmental factors in local school siting
decision-making processes without infringing on
local decision-making authority. EPA's
overarching goal for the guidelines is to serve
children, staff and the broader community by:
1 Energy Independence and Security Act of 2007, Public Law 110-140,
HR6,110th Cong., (December 19, 2007). Available at:
www.govtrack.us/congress/bill.xpd?bill=hllO-6.
Supporting states, tribes, communities, local
officials and the public in understanding and
appropriately considering environmental and
public health factors when making school siting
decisions;
Encouraging meaningful, broad and inclusive
community involvement to ensure community
understanding, input and engagement in school
location selection;
• Encouraging comprehensive evaluation of
prospective locations for their potential positive
and negative impacts on the health and safety of
children and school workers and on the
environment;
Identifying opportunities to promote
environmental justice in how school siting
decisions are made;
Encouraging decision makers, where
appropriate, to examine existing schools and
the potential for renovation, upgrade,
adaptation and expansion before concluding
new school construction is warranted;
Encouraging decision makers, where
appropriate, to examine nearby environments
in low-income, minority, indigenous and other
overburdened communities;
Demonstrating how well-located schools can
allow more students, faculty and staff to walk,
bike and/or use public transit to get to and from
school;
• Identifying opportunities to serve multiple
community purposes (e.g., emergency shelters,
community centers, joint school and public
libraries, gymnasiums, playing fields, theaters
and community gardens) so that schools can
become a hub for the whole community; and
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• Encouraging decision makers to consider short-
and long-term construction, transportation and
operation and maintenance costs and benefits
in design and construction decisions.
1.1. Who Should Use the
Guidelines?
These voluntary guidelines are intended to assist
local school districts, which will be referred to
throughout these guidelines as the local education
agency (LEA) (see Section 10), and community
members in evaluating environmental factors to
make the best possible school siting decisions. The
special vulnerabilities of children and
considerations for children's health underpin the
recommendations contained in these guidelines,
consistent with EISA, Subtitle E—Healthy High-
Performance Schools, Section 502. While the
guidelines are primarily intended to be used by
LEAs in evaluating and selecting locations for K-12
schools, EPA believes that the recommendations
in the guidelines represent a set of best practices
that inform and improve evaluation and selection
decisions for a wide range of settings where
children spend time. Although there are many
differences in how locations are chosen across the
types of child-occupied facilities, the practices
recommended within the guidelines may be
applied, with appropriate adaptation, to a wide
range of school-related institutions, including:
K-12 public schools (including charter schools
and schools in leased locations);
K-12 private schools;
K-12 schools operated by the Department of
Defense or Department of the Interior's Bureau
of Indian Education;
Technical and vocational schools;
• Colleges and universities; and
Pre-K and non-home child care, after care and
early learning settings (e.g., Head Start and
Early Head Start programs).
The guidelines are intended to be used prior to:
Making a decision about whether to renovate
the existing school, build a new school on the
current site or build a new school on a new site;
• Acquisition of land for school facilities;
Use of legacy property already owned by the
LEA;
Leasing of space in new or existing structures
not owned by the LEA for use as a school;
and/or
Major repair, renovation or reuse of existing
properties and structures already owned by the
LEA for use as a school.
1.1.1. Evaluation of Hazards
Throughout these guidelines, references are made
to chemical hazards, contaminants, toxic
substances and other terms that identify
chemicals and compounds that may pose risks to
students, staff, parents and others. The use of any
of these terms is not intended to be limited to a
statutory or regulatory definition. The intent of
these voluntary guidelines is to provide a process
for the assessment of chemicals, compounds or
other materials that pose a threat to anyone that
spends time in the school environment at
candidate locations for schools.
1.2. Limitations of the
Guidelines
Decisions on school siting are complicated and in
many instances will involve issues where there
are scientific and technical uncertainties.
Generally, state, tribal and local governments
decide where to locate schools. With few
exceptions (e.g., a school located on a Department
of Defense base or funded and/or operated by the
Bureau of Indian Education), the federal
government does not have authority over school
siting decisions.
While EPA does not have the statutory authority
to control school siting decisions directly, it
About the School Siting Guidelines
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administers federal environmental laws that may
apply to or be relevant to location evaluation,
including site assessment and cleanup. In many
cases, states have similar authorities to address
site cleanup, and some states and tribes also have
additional authorities (e.g., certain land use
authorities) that may be relevant to school
location decisions. No single set of national
guidelines can reflect the widely divergent
situations and institutional relationships that exist
throughout the education system in the United
States. Because each state, tribe and community
has or will develop their own location evaluation
and selection procedures, the recommendations
contained in EPA's School Siting Guidelines are
designed to provide a general guide that should be
adapted to local situations.
The guidelines are designed to support state,
tribal and community decision makers in
evaluating their existing school processes and
policies to address environmental factors in
school siting and construction decisions,
especially when the presence of contamination
may pose a threat to a safe learning environment.
These guidelines do not impose legally binding
requirements on EPA, states, tribes, local
governments, LEAs or the regulated community,
and may not apply to a particular situation based
upon the circumstances. These guidelines do not
pre-empt, supersede or serve as a substitute
for state, tribal or local school site or location
selection policies or requirements.
Economic, racial and ethnic segregation is a
continuing challenge across the country. More
diverse schools can provide educational as well as
life attainment benefits to all school age children.2
While community centered schools can be part of
improved educational, economic, community and
public health outcomes for children, families and
2 Gary Orfield and Chungmei Lee, "Historic Reversals, Accelerating
Resegregation, and the Need for New Integration Strategies," The
Civil Rights Project, University of California Los Angeles, August 29,
2007. Available at: http://civilrightsproject.ucla.edu/research/k-12-
education/integration-and-diversity/historic-reversals-accelerating-
resegregation-and-the-need-for-new-integration-strategies-
1/orfield-historic-reve rsals-accelerating.pdf.
neighborhoods, LEAs should balance these issues
with meeting the goal of diverse school
populations. Techniques are available to help
achieve the multiple goals of diverse student
populations and schools located within the
communities they serve. The Resources page of
the guidelines website (www.epa.gov/schools/
siting/resources.html#Links_Technical_Assistance)
contains information about techniques that have
been identified to support these goals. While these
issues are beyond the scope of these guidelines,
the Resources page of the guidelines website also
contains links to select studies on school
segregation trends and causes.
(www.epa.gov/schools/siting/resources.htmlttLI
NKS_Segregation)
It is beyond the scope of these guidelines to
discuss the requirements of federal civil rights
laws that apply to public school districts and may
be relevant to school siting decisions. These civil
rights laws include Title VI of the Civil Rights Act
of 1964 (www.justice.gov/crt/cor/coord/
titlevi.php), which prohibits discrimination on the
basis of race, color or national origin in federally
assisted programs or activities. EPA's regulations
implementing Title VI prohibit both intentional
discrimination and facially neutral policies and
practices that result in discriminatory effects,
including siting decisions.3
3 EPA's Office of Civil Rights and the Department of Education's Office
for Civil Rights are available to provide technical assistance to districts
concerning applicable civil rights laws. See agency regulations
implementing Title VI, for example, EPA's Title VI regulations, 40 C.F.R.
Part 7, and the U.S. Department of Education's Title VI regulations, 34
C.F.R. Part 100. The Title VI regulations prohibit, among other things,
race, color or national origin discrimination in siting decisions. In
addition to prohibiting discrimination in siting decisions, among other
things, the civil rights laws establish other requirements relevant to
the decision-making process, such as requirements pertaining to
effective communication with limited English proficient persons and
individuals with ties and requirements pertaining to access by
individuals with disabilities. See U.S. Department of Justice regulations
implementing Title II, 28 C.F.R. Part 35, and Title III, 28 C.F.R. Part 36,
of the Americans with Disabilities Act, and U.S Department of
Education's regulations implementing Section 504 of the
Rehabilitation Act of 1973, 34 C.F.R. Part 104.
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IMPORTANT: The School Siting Guidelines are
NOT designed for retroactive application to
previous school siting decisions. They are
designed to inform and improve the consideration
of environmental factors in the school siting
decision-making process going forward. In
developing these guidelines, EPA seeks to
strengthen information exchange and cooperation
between LEAs, state and tribal education agencies
and their environmental counterparts to better
serve school children, parents, staff and their
communities in providing safe school
environments. Many schools across the country
may be located in proximity to one or more of the
potential hazards discussed within the guidelines.
Due to many factors that affect exposure to
environmental hazards (such as those included in
Exhibit 5) and based on the regulations and
protective measures that can be applied,
proximity of a school to nearby sources of
environmental contaminants may not pose
unacceptable risks. EPA recommends that districts
periodically inspect existing schools for potential
environmental health and safety risks using tools
designed for that purpose such as EPA's Healthy
School Environments Assessment Tool
(HealthySEAT; www.epa.gov/schools/
healthyseat/) or the National Institute for
Occupational Safety and Health (NIOSH) Safety
Checklist Program for Schools, (www.cdc.gov/
niosh/docs/2004-101/) Where deficiencies are
found, EPA recommends steps to reduce student
and staff exposure to potential hazards be
identified and implemented (see Section 9.13).
Keeping children safe from environmental
exposures at school does not end with site
selection, or even materials selection during
construction; the health of students and staff in
schools is supported by an ongoing attention to
commitment to healthy school environments. EPA
has a considerable body of guidance and
regulations that are specifically geared toward
existing schools, which is available at
www.epa.gov/schools.
1.3. Public Involvement in the
Development of the Guidelines
In July 2009, EPA convened a special School Siting
Task Group (Task Group) under the existing
Children's Health Protection Advisory Committee
(CHPAC) to provide early input to EPA on the
content of the siting guidelines. (http://yosemite.
epa.gov/ochp/ochpweb.nsf/content/whatwe_advi
sory.htm) The Task Group was composed of
representatives from a wide range of national,
state, tribal and local organizations. The Task
Group was provided with an initial draft and
provided comments (http://yosemite.epa.gov/
ochp/ochpweb.nsf/content/CHPAC_Comments.ht
m#14) in April 2010 to EPA in the form of a letter
from the CHPAC to Administrator Lisa Jackson
(April 7, 2010) (http://yosemite.epa.gov/ochp/
ochpweb.nsf/content/CHPAC_School_Siting_Letter
_web.htm) and a report from the School Siting
Task Group, (http://yosemite.epa.gov/ochp/
ochpweb.nsf/content/CHPAC_SSTG_Report2.htm/
$File/CHPAC_SSTG_Report2.pdf) EPA appreciates
the work of the Task Group and the contributions
made by all of its members. EPA incorporated
many of the recommendations from the CHPAC
letter and School Siting Task Group report into the
guidelines.
In November 2010, EPA released the draft School
Siting Guidelines for public comment. The
comment period was open until February 2011.
EPA considered these comments in revising the
guidelines. A summary of the issues raised by the
public commenters and EPA's responses can be
found on the Public Involvement in the
Development of the guidelines page.
(www.epa.gov/schools/siting/development)
In addition, the guidelines have drawn from, and
the Resources page of the guidelines website
includes links to, numerous resources that have
already been developed by state and local
jurisdictions and other organizations. (See:
www.epa.gov/schools/siting/resources)
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1.4. Principles behind the
Guidelines
1.4.1. Principle 1. Safe and healthy school
environments are integral components of the
education process
The overriding purpose of a school building is to
provide a safe, healthy and supportive
environment in which children can learn. Children
spend nearly a third of their typical day in the
school environment, where they may be exposed
to a range of contaminants both indoors and out.
Such exposures can impact health and learning
and negatively impact school attendance. Student
exposure to environmental hazards at school can
arise from multiple pathways, which may differ
between locations. Each location may have
different underlying causes of potential exposure,
such as site contamination, neighborhood
emission sources or indoor air quality problems.
(http://yosemite.epa.gov/ochp/ochpweb.nsf/frm
chemicals)
Poor indoor air quality can contribute to illness
resulting in absence from school and acute health
symptoms that decrease performance while at
school.4 Poor indoor air quality may also directly
reduce a person's ability to perform specific
mental tasks requiring concentration, calculation
or memory. Although children spend most of their
school day inside the school building, they also
spend time outdoors, such as during recess,
physical education class, physical activity outside
of class time and getting to and from school.
Examples of contaminants that can be found in
outdoor school environments include air pollution
from motor vehicles, pesticides and industrial
pollutants. Some of these pollutants also
4 U.S. Environmental Protection Agency, "Indoor Air Quality and
Student Performance," U.S. Environmental Protection Agency,
Washington, DC, EPA402-F-00-009, August 2000.
contribute to exposures within the indoor
environment in schools.5
Children are more vulnerable to environmental
exposures because their responses to toxic
substances, both in severity and in the nature of
the adverse effect, can differ markedly from those
of adults.6
Children breathe more air, drink more water
and eat more food per kilogram of body weight
than adults;
Children's behaviors (e.g., hand to mouth
contact) also make them more susceptible to
environmental hazards, especially hazards in
soil and dust;7
• Children experience periods of growth and
development which can be adversely affected
by exposures to toxic substances. The rapid
development of a child's organ systems during
embryonic, fetal and early newborn periods
makes children vulnerable when exposed to
environmental toxicants. The particular
vulnerabilities of infants, preschool and young
children may be of particular importance to
consider where child care centers are
integrated with or adjacent to elementary or
other schools;
Children with chronic illnesses such as asthma
may experience increased vulnerability to
5 U.S. Environmental Protection Agency, "An Introduction to Indoor
Air Quality (IAQ)," U.S. Environmental Protection Agency, Washington,
DC. Last modified November 29, 2010. Available at:
www.epa.gov/iaq/ia-intro.html.
6 "Developmental Toxicity: Special Considerations Based on Age and
Developmental State," in Pediatric Environmental Health, 2nd Edition,
ed. Ruth A. Etzel and Sophie J. Balk, American Academy of Pediatrics
Committee on Environmental Health (2003) 9-36.
7 U.S. Environmental Protection Agency, "Child-Specific Exposure
Factors Handbook (Final Report)," U.S. Environmental Protection
Agency, National Center for Environmental Assessment, Office of
Research and Development, Washington, DC, EPA/600/R-06/096F,
September 2008. Available at: http://cfpub.epa.gov/ncea/risk/
recordisplay.cfm?deid=199243#Download.
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environmental toxicants.8 Asthma continues to
be a significant problem among school age
children; and
There is potential for children who are actively
engaged in structured and unstructured
outdoor physical activity, including sports
activities, to be disproportionately affected by
outdoor air pollution because intake of air
increases during periods of increased physical
activity. Also, when mouth breathing occurs, the
process of deposition in the upper respiratory
tract is bypassed with direct deposition in the
lungs of any environmental contaminants
present in the air.
Research has confirmed that the quality of a
school facility has an impact on students'
experiences and ultimately on their educational
achievement. Research on school building
conditions and student outcomes finds a
consistent relationship between poor facilities and
poor performance: higher student achievement is
associated with school facilities that are clean, in
good repair and designed to support high
academic standards, independent of student
socioeconomic status.9 (www.epa.gov/
schools/siting/resources)
1.4.2. Principle 2. The environmental review
process should be rigorous, thorough and
well-documented, and include substantive
and ongoing meaningful public involvement
Selecting sites where environmental reviews have
recently been conducted and documented (within
the past six months) or performing an
environmental review on candidate locations is
the only means of determining if there are any
8 World Health Organization, "The Physical School Environment: An
Essential Component of a Health-Promoting School," The World
Health Organization's Information Series on School Health Document
No. 2 (2004). Available at:
http://www.who.int/school_youth_health/media/en/physical_sch_envir
onment_v2.pdf.
9 M.J. Mendell and G.A. Heath, "Do indoor pollutants and thermal
conditions in schools influence student performance? A critical review
of the literature," Indoor Air (2005) 15:1. 27-52. Available at:
http://onlinelibrary.wiley.eom/doi/10.llll/j.1600-
0668.2004.00320.x/full.
onsite or offsite environmental hazards that may
pose a health risk to students and staff. If there are
potential hazards associated with the preferred
location, in addition to identifying the potential
hazards, the LEA and the school siting committee
(SSC) (see Section 3.3) with meaningful public
involvement (see Section 3) can use the
environmental review process (see Section 5) to
determine what cleanup, mitigation and long-term
stewardship should be implemented to ensure the
safety and health of all school occupants.
A thorough and transparent environmental
review process will help reduce the likelihood that
natural hazards (e.g., flooding) or environmental
hazards (e.g., site contamination) will be
discovered after the school is located and
operating, thus reducing potential adverse
environmental and public health effects on
children, legal and financial liability and/or public
backlash. The rationale for choosing one location
over another should be clearly articulated based
on a robust review of candidate locations,
especially if the environmental review is a
deciding factor. Moreover, all engineering and
scientific reporting must comply with applicable
federal, state, tribal and local regulations.
Stakeholder groups such as parents, teachers and
other school personnel, and nearby residents are
most directly impacted by school siting decisions
and should be fully engaged in the review and
decision-making process. These guidelines
provide important information and links
throughout, especially in the Quick Guide to
Environmental Issues (see Section 8) and on the
Resources page of the guidelines website, to
address the need for technical assistance and
training to enable meaningful participation by
parents and nearby residents, including minority
and low-income populations.
(www.epa.gov/schools/siting/resources)
State and tribal environmental regulatory
agencies may play a central role in oversight and
approval of the environmental review where
contaminated sites are being considered (see
Section 7). Their involvement is critical in any site
About the School Siting Guidelines
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remediation and site management plans as well as
ensuring the integrity of long-term stewardship
plans (see Section 5.10), including any
institutional and engineering controls (see Section
8.15) in place to prevent exposures, so they can be
relied upon over the long term.
1.4.3. Principle 3. Schools should be located
in environments that contribute to the
livability, sustainability and public health of
neighborhoods and communities
Investments in educational facilities represent one
of the largest capital outlays that many states,
tribes and local governments make. Decisions
about the construction and renovation of schools
will have important implications for communities
beyond educational outcomes. Communities may
choose to use these investments to meet multiple
goals—education, health, environmental,
economic, social and fiscal. Both the location and
design of a school and its accessibility to residents
outside of class hours, including residents with
disabilities, play a major role in determining what
benefits it provides to the community. Many
communities that are re-evaluating their growth
patterns and infrastructure investments are also
assessing how and where they spend their
education dollars. Integrating school planning
with broader community plans, visions and goals
can produce neighborhood-centered schools that
offer high-quality educational programs while
benefiting the environment, health and well-being
in many ways.
National trends in school siting and size have
largely followed the model of building new
schools at the edges of communities on large,
undeveloped parcels of land away from the
neighborhoods and towns they serve. Average
school size (in terms of student population per
school) has steadily grown. According to the
National Center for Education Statistics, the
number of schools in the United States decreased
from 262,000 in 1930 to 95,000 in 2004.10
(http://nces.ed.gov/) Student population over the
same period rose from 28 million to 54.5 million.
This approach of constructing large schools on
undeveloped locations often leads to
underinvestment in the community core and
existing facilities and increases public
expenditures, vehicular travel, traffic congestion,
pollution and loss of open space. Accordingly,
many residents in older neighborhoods have
lower access to public infrastructure and
recreational locations, such as school playgrounds
and athletic fields. Instead, schools should be a
hub for the whole community, by providing public
spaces for recreation and learning, extended
hours before and after school and during the
weekends and summer, and space for academic
and non-academic services such as social services
and activities that engage parents and the entire
community. The National Trust for Historic
Preservation's 2009 report "Helping Johnny Walk
to School" outlines the benefits of retaining
community centered schools.11 It can be found
here: www.preservationnation.org/
issues/historic-schools/.
Encouraging physical activity
The location of a school and the school
environment can influence levels of physical
activity. Further, the American Academy of
Pediatrics Committee on the Environment wrote
in 2009, "The most universal opportunity for
incidental physical activity among children is
getting to and from school."12 Many studies show
that the distance between home and school is the
10 U.S. Department of Education Institute of Educational Sciences,
"National Center for Educational Statistics Fast Facts." (Accessed on
September 16, 2011) Available at: http://nces.ed.gov/fastfacts/
display.asp?id=84.
11 Renee Kuhlman, "Helping Johnny Walk to School: Policy
Recommendations for Removing Barriers to Community-Centered
Schools," National Trust for Historic Preservation (2010). Available at:
www.preservationnation.org/issues/historic-schools/helping-johnny-
walk-to-school/helping-johnny-walk-to-school.pdf.
12 American Academy of Pediatrics Committee on Environmental
Health, "The Built Environment: Designing Communities to Promote
Physical Activity in Children." Pediatrics (June 2009) 123:6. 1593.
Online article available at: http://aappolicy.aappublications.org/
cgi/content/full/pediatrics;123/6/1591.
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strongest predictor of whether students walk or
bike to school.13 The U.S. Department of
Transportation reports that the number of
students ages 5 to 18 who walk or bike to school
has declined dramatically over the past few
decades, from 41 percent in 1969 to only
13 per cent in 2001.14 This has coincided with a
sharp increase in obesity rates among children.
According to the Centers for Disease Control and
Prevention (CDC), the prevalence of obesity
among children ages 6 to 11 nearly tripled in the
past three decades, increasing from 6.5 percent in
1976 - 1980 to 19.6 percent in 2007 - 2008. The
rate among adolescents ages 12 to 19 more than
tripled, increasing from 6.5 percent to
18.1 percent over the same period.15
Obesity rates and associated chronic disease rates
are substantially higher in minority populations.
Yet, these communities often lack access to
opportunities for physical activity and to
affordable and nutritious food.16 Well-sited
schools within these neighborhoods combined
with Safe Routes to Schools17 (see Section 4.3.4)
efforts and reinvestment in infrastructure that
increases pedestrian and bike safely can increase
the opportunity for incidental physical activity
and may help address this environmental inequity
13 Safe Routes to School National Partnership, "The Influence of the
Built Environment on Travel Behaviors." (Accessed on September 16,
2011) Available at: www.saferoutespartnership.org/mediacenter/
research/231317.
14U.S. Department of Health and Human Services at Centers for
Disease Control and Prevention, "Kids Walk-to-School: Then and
Now—Barriers and Solutions," Last modified February 25, 2008.
Available at: www.cdc.gov/nccdphp/dnpa/kidswalk/
then_and_now.htm.
15 Cynthia Ogden and Margaret Carroll, "Prevalence of Obesity Among
Children and Adolescents: United States, Trends 1963-1965 Through
2007-2008," National Center for Health Statistics Health E-Stat
Centers for Disease Control and Prevention. Last modified June 4,
2010. Available at: www.cdc.gov/nchs/data/
hestat/obesity_child_07_08/obesity_child_07_08.htm.
16 Centers for Disease Control and Prevention, "CDC Health Disparities
and Inequalities Report—United States, 2011," Morbidity and Mortality
Weekly Report (January 14, 2011) 60 (Suppl). Available at:
www.cdc.gov/mmwr/pdf/other/su6001.pdf.
17 Safe Routes to School National Partnership, "Impact of Physical
Activity on Obesity and Health." (Accessed on September 16, 2011)
Available at: www.saferoutespartnership.org/mediacenter/
research/230339.
and health disparity. Numerous studies have
shown that when schools are within an easy
walking or biking distance of residential areas and
the routes to school are safe, students increase
their participation in physical activity.18
(www.epa.gov/schools/siting/resources) In a
study of adolescents, 100 percent of students who
walked both to and from school met the
recommended levels of 60 or more minutes of
moderate to vigorous physical activity on
weekdays.19 Community centered schools that
encourage daily physical activity lead to better
health for children, for example better
cardiovascular fitness, and healthier communities
and may reduce risk of obesity and chronic
disease.20
School siting that supports walking or biking to
school can also contribute to academic
achievement. The 2010 CDC report, "The
Association between School-based Physical
Activity, including Physical Education, and
Academic Performance" (www.cdc.gov/
healthyyouth/health_and_academics/pdf/pape_ex
ecutive_summary.pdf), synthesized the scientific
literature examining indicators of cognitive skills
and attitudes, academic behaviors and academic
achievement. The report found substantial
evidence that physical activity can help improve
academic achievement, including grades and
standardized test scores. The review suggests that
physical activity can have an impact on cognitive
skills and attitudes and academic behavior, all of
which are important components of improved
academic performance. These include enhanced
18 Active Living Research, "Walking and Biking to School, Physical
Activity and Health Outcomes," Research Brief (May 2009). Available
at: www.activelivingresearch.org/files/ALR_Brief_ActiveTransport.pdf.
19 Leslie M. Alexander, Jo Inchley, Joanna Todd, Dorothy Currie, Ashley
R. Cooper and Candace Currie, "The broader impact of walking to
school among adolescents: seven day accelerometry based study,"
British MedicalJournal (2005) 331:7524. 1061-1062. Available at:
www.ncbi.nlm.nih.gov/pmc/articles/PMC1283187/
20American Academy of Pediatrics Committee on Environmental
Health, "The Built Environment: Designing Communities to Promote
Physical Activity in Children," Pediatrics (June 2009) 123:6. 1591-1598.
Online article available at: http://aappolicy.aappublications.org/
cgi/content/full/pediatrics;123/6/1591.
I About the School Siting Guidelines
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concentration and attention as well as improved
classroom behavior.21
Reducing environmental impacts on air,
water and land
The location of a school affects the environment in
complex ways. Locating schools in the
neighborhoods they serve, reusing infrastructure
and renovating buildings conserve energy and
resources. Integrating schools into neighborhoods
instead of building them on undeveloped land on
the fringe of the community preserves the natural
environment, including farmland, fields and
wildlife habitat. By using existing buildings, roads,
parking lots and other infrastructure,
communities can avoid building more impervious
paved surfaces, which in turn reduces
contaminated water runoff into nearby lakes,
rivers and streams. Appropriate consideration of a
school's potential environmental impact can help
to preserve and nourish the natural and human
resources of a community.
As noted earlier, the percentage of children that
walk or bike to school dropped from 41 percent in
1969 to about 13 percent in 2001. Bus ridership
has remained relatively stable during the same
period, with about 55 percent of students riding a
school bus in 2004.22 This means that the
proportion of children arriving at school in
privately owned vehicles has increased—a change
that has implications for overall traffic and
emissions. Increases in traffic can raise emissions
of numerous pollutants, including criteria air
pollutants, air toxics and greenhouse gases. In
addition, traffic congestion around schools
decreases child safety. Data from the 2001
National Household Transportation Survey show
that the distance a child lives from school
21 Centers for Disease Control and Prevention, "The Association
Between School-Based Physical Activity, Including Physical Education,
and Academic Performance," U.S. Department of Health and Human
Services (April 2010). Available at: www.cdc.gov/healthyyouth/
health_and_academics/pdf/pape_execu tive_summary.pdf.
22 Safe Routes to School National Partnership, "National Statistics on
School Transportation, Safe Routes to School: Creative and Safe
Solutions to School Bus Cuts." (Accessed on September 16, 2011)
Available at: www.saferoutespartnership.org/media/
file/school_bus_cu ts_national_stats_FINAL.pdf.
influences the choice of whether to walk, bike, ride
a bus or get a ride in a car. For trips of less than %
of a mile, walking or biking is the dominant mode.
For trips of % to % a mile, private automobiles
account for about half the trips to and from school.
At a distance of 1 mile and beyond, the majority of
the trips are by private automobile.23
Additionally, schools that apply integrated site
and building design practices incorporating green
principles and standards (See: www.epa.gov/
schools/siting/resources)—such as those from
the Collaborative for High Performance Schools
(CHPS) (www.chps.net/dev/Drupal/node) and
the EPA's ENERGY STAR program
(www.energystar.gov/k-12)—improve
educational opportunities through use of the
building and practices as teaching tools; improve
energy, material and resource efficiency; improve
indoor environmental quality; and help create
models of sustainable neighborhoods.
1.4.4. Principle 4. The school siting process
should consider the environmental health
and safety of the entire community, including
disadvantaged and underserved populations
A growing body of research suggests that minority
and low-income children are more likely to attend
schools that are in poor condition or have
received inadequate maintenance due to lack of
resources.24 Studies also highlight the
disproportionate percentage of minority and low-
income children that are exposed to multiple
environmental hazards in close proximity to the
schools they attend.25 These environmental
23 U.S. Department of Transportation Federal Highway Administration,
"National Household Travel Survey," NHTS Brief (January 2008).
Available at: www.saferoutespartnership.org/media/file
/T ravel_To_School.pdf.
24 Daria E. Neal, "Healthy Schools: A Major Front in the Fight for
Environmental Justice." Lewis & Clark Law School's Environmental Law
Online (n.d.) 38:2 (Accessed on September 16, 2011) Available at:
www.elawreview.org/elaw/382/healthy_schools_a_major_front.html.
25 David Salvesen, Peter Zambito, and Dylan McDonnell, "Safe
Schools: Identifying Potential Threats to the Health and Safety of
Schoolchildren in North Carolina," Center for Sustainable Community
Design Institute for the Environment, University of North Carolina at
Chapel Hill, Chapel Hill, North Carolina (November 2010). Available at:
www.ie.unc.edu/cscd/pdf/Safe_Schools_Final_Report.pdf.
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hazards range from exposures to outdoor air
toxics to various exposures that originate within
the school boundaries. Minority and low-income
children may be even more at risk from these
environmental hazards given the presence of
other factors, such as poor nutrition, lack of access
to health care and pre-existing health conditions.
The adverse health effects from these exposures
may result in both short-term effects, such as poor
school performance due to increased absenteeism,
and possible long-term effects, such as the
development of a serious learning disability,
respiratory illness or other disease.
Policies that encourage the renovation of existing
schools, with appropriate mitigation of
environmental hazards if necessary and the siting
of new facilities within existing neighborhoods
can contribute to solving multiple challenges in
older communities. Conversely, policies that
discourage renovating existing schools or siting
schools within the community can lead to a
disinvestment in the community that may
contribute to physical, social and economic
decline in the community. Siting schools in the
communities they serve—particularly in urban
areas where disinvestment in neighborhoods has
led to chronic environmental, economic and public
health disparities—can be part of a revitalization
strategy aimed at a wide range of improved
community outcomes. School grounds can provide
important play and recreational space for
children.26 Research shows that in inner-city
neighborhoods, children are more likely to be
physically active when there is a safe, easily
accessible play space such as a schoolyard than
when their neighborhood does not have a similar
26Ad-Hoc Coalition for Healthy School Siting, "Revising CDE School
Siting Policy Documents: How California's School Siting Policies Can
Support a World-Class Educational System," Submitted to the
California Department of Education by the Ad-Hoc Coalition for
Healthy School Siting (January 31, 2008). Available at:
http://citiesandschools.berkeley.edu/reports/School_Siting_Policy_Brie
f_013108.pdf.
space.27 Because these facilities are located within
walking distance, families and children are more
likely to use them.28 School locations that are
accessible by walking or biking make it easier for
families without cars to be part of their children's
school community and helps to reduce
transportation expenses. Rates of auto ownership
are lower among low-income and minority
populations and being closer to the school makes
it easier for parents to be involved in the school
community.29 The benefits of locating schools in
the communities they serve should be considered,
especially in cases where the school will be
serving disadvantaged or underserved
populations.
When renovation or new construction of school
facilities in existing communities is paired with a
joint-use program—using the location for K-12
education as well as an adult vocational training
center in the evenings, for instance—communities
benefit. Joint use schools can also include public
libraries, amenities such as swimming pools and
gyms, public health centers, and counseling clinics.
Co-locating these uses leverages public and
private dollars more efficiently, reuses existing
infrastructure and contributes to the vibrancy of
existing communities. Joint use agreements can be
used to address LEA or community concerns
about costs, vandalism, security, maintenance and
liability in the event of injury. For more on joint
use and joint use agreements see the Center for
Cities and Schools (http://citiesandschools.
berkeley.edu/) and the National Policy and Legal
Analysis Network to Prevent Childhood Obesity
(www.nplanonline.org/nplan/joint-use) websites.
27Thomas A. Farley et al., "Safe Play Spaces To Promote Physical
Activity in Inner-City Children: Results from a Pilot Study of an
Environmental Intervention," American Journal of Public Health
(September 2007) 97:9.1625-1631. Available at:
www.njafter3.org/edu/docs/Reports_Safe-Places-to-Play-Report.pdf.
28 National Policy and Legal Analysis Network to Prevent Childhood
Obesity, "Healthy School Siting." (Accessed on September 16, 2011)
Available at: www.nplanonline.org/nplan/healthy-school-siting.
29Adam Carasso and Signe-Mary McKernan, The Urban Institute, "The
Balance Sheets of Low-Income Households: What We Know about
Their Assets and Liabilities," Prepared for U.S. Department of Health
and Human Services Office of the Assistant Secretary for Planning and
Evaluation (November 2007). Available at:
http://aspe.hhs.gov/hsp/07/PoorFinances/balance/index.shtml.
About the School Siting Guidelines
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The renovation of an existing school or the siting
of a new school facility on a previously developed
site can reduce or eliminate expenses that might
have otherwise been incurred—for new
infrastructure like roads and sewers, separate
locations for the different uses, and the costs of
transporting children out of their neighborhood to
the new facility.30 It can also mean that a facility or
site that was once seen as a blight or blemish on a
community or neighborhood has been
transformed into a community asset.31 When
prospective locations for schools are taken out of
the discussion solely because they were
previously used or are in disrepair, or when
recent trends towards larger, dispersed, and auto-
or bus-access only schools are followed,
communities in most need of reinvestment can
miss out on significant opportunities for catalytic
investments.32'33 Links to more information on
disparities and environmental justice are
provided in the Resources page of the guidelines
website, (www.epa.gov/schools/siting/resources)
30 National Trust for Historic Preservation, "Older and Historic Schools:
Restoration vs. Replacement and the Role of a Feasibility Study," Last
updated January 2010. Available at:
www.preservationnation.org/issues/historic-schools/additional-
resources//school_feasibility_study.pdf.
31 Ariel H. Bierbaum, Jeffrey M. Vincent and Erika Tate, "Building
Schools and Community," Race, Poverty and the Environment (Spring
2008) 15:1. Available at: http://urbanhabitat.org/files/
15.Bierbaum.et_.al_.pdf.
32 Renee Kuhlman, "Helping Johnny Walk to School: Policy
Recommendations for Removing Barriers to Community-Centered
Schools," National Trust for Historic Preservation (2010). Available at:
www.preservationnation.org/issues/historic-schools/helping-johnny-
walk-to-school/helping-johnny-walk-to-school.pdf.
33Constance E. Beaumont and Elizabeth G. Pianca, "Why Johnny Can't
Walk to School: Historic Neighborhood Schools in the Age of Sprawl,"
2nd ed. National Trust for Historic Preservation (October 2002).
Available at: www.preservationnation.org/issues/historic-
schools/additional-resources/schools_whyjohnny_l.pdf.
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| About the School Siting Guidelines
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2. Overview
of the School Siting
Guidelines
2.1. Introduction
School buildings are fundamental components of
the educational process, and children spend more
time in school than in any other environment
except their home. A well-located, thoughtfully
designed, soundly built and efficiently operated
school enhances the educational process by
providing a safe and healthy environment for
children, teachers and other staff and provides
many opportunities to meet multiple community
goals. These voluntary guidelines are intended to
assist local school districts, which will be referred
to throughout these guidelines as the local
education agency (LEA) (see Section 10), and
community members in evaluating environmental
factors to make the best possible school siting
decisions.
The guidelines are intended to be used prior to:
Making a decision about whether to renovate
the existing school, build a new school on the
current site or build a new school on a new site;
Acquisition of land for school facilities;
Use of legacy property already owned by the
LEA;
Leasing of space in new or existing structures
not owned by the LEA for use as a school;
and/or
Major repair, renovation or reuse of existing
properties and structures already owned by the
LEA for use as a school.
In developing the guidelines, the Environmental
Protection Agency (EPA) focused on four
underlying principles for addressing
environmental factors in school siting decisions
(described in detail in About the School Siting
Guidelines):
1. Safe and healthy school environments are
integral components of the education process
(see Section 1.4.1);
2. The environmental review process should be
rigorous, thorough and well-documented and
include substantive and ongoing meaningful
public involvement (see Section 1.4.2);
3. Schools should be located in environments
that contribute to the livability, sustainability
and public health of neighborhoods and
communities (see Section 1.4.3); and
4. The school siting process should consider the
environmental health and safety of the entire
community, including disadvantaged and
underserved populations (see Section 1.4.4).
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2.2. Overview for Considering
Environmental Factors in the
School Siting Process
The decision about where to locate a school is
fundamentally local in nature, although state,
tribal and federal laws and programs often
influence the decision-making process in both
direct and indirect ways. For example, the
presence of environmental contamination and
threat of exposure of children and/or staff to
unsafe levels of contaminants on school property
may trigger the need for state and possibly federal
involvement.
These guidelines present recommendations on
evaluating the environmental and public health
risks and benefits of potential locations as part of
the school siting process. Examples of potential
environmental and public health risks include
onsite contamination, such as radon, volatile
organic compounds or petroleum hydrocarbons in
soil and ground water, or impacts from nearby
sources of pollution, such as industrial facilities
and transportation facilities (see Exhibit 6:
Screening Potential Environmental, Public Health
and Safety). Some examples of environmental and
public health benefits include the location's
proximity to residences where future students live
(so students would be able to walk or bike to
school) and the availability of public
transportation to and from the site (see Exhibit 4:
Desirable Environmental Attributes of Candidate
Sites).
The siting process is complex and involves many
considerations that extend beyond the scope of
these guidelines, for example:
Educational and extracurricular programs and
services;
Anticipated size and demographics of the
student body;
Needs of individuals with disabilities;
Location size (acreage and facility space);
Community partnerships and planned or
potential commercial development in the
community;
Cost of land and location preparation;
Availability of infrastructure (e.g., roads and
utilities);
• Requirements that must be met to receive local,
state and tribal funding assistance; and
Economic impact to the community.
While these issues are beyond the scope of the
guidelines, some resources related to these other
considerations have been provided on the
guidelines website, (www.epa.gov/schools/
siting/resources)
Many LEAs develop long-range school facilities
plans to help determine future facilities needs.
These long-range plans provide the context within
which the school siting decisions are made. To
make informed decisions, the LEA should consider
consulting with municipal officials on the
community's plans for future land use and capital
expenditures (often outlined in a comprehensive
plan or similar document) (see Section 4.2.1).
Although the actual process to consider
environmental factors in school siting decisions
varies from community to community, Exhibit 1
gives a general picture of the issues that are
addressed in the guidelines.
Overview of the School Siting Guidelines
-------
Exhibit 1: Overview of the Siting Guidelines
nW
Meaningful Public Involvement*
Before the
Siting Process
Begins
/"~
Environmental Siting <
Identify
Desirable School
Location Attributes
^^^^^^^j
Criteria Consideratio
Consider
Environmental
Hazards
J
ns
)
• Develop a Long-
range School
Facilities Plan
• Consider Whether a
New School Is
Needed
• Consider Whether a
New School Will Be
a High Performance/
Green School
Potential Onsite Hazards
Potential Nearby Hazards
Screening Locations for
Potential Environmental
Hazards
Select Locations that Do
Not Increase
Environmental Health or
Safety Risks
Locate Schools Near
Populations and
Infrastructure
Consider Implications of
the School Location on
Transportation Options
Plan For and Develop
Safe Routes to Schools
Programs that can
Support Alternative
Modes of Transportation
Consider the Potential
Use of the School as an
Emergency Shelter
* Meaningfutpublic involvement is critical throughout the school siting decision-making
process. The public involvement section includes a table nith examples of points in the
process where meaningful public engagement should be considered, as well as strategies
for engagement and the types of information that may be presented to, or requested
from, thepublic.
Environmental Review Process
Recommended
Environmental
Review Process
Evaluating Impacts
of Nearby Sources
of Air Pollution
Stage 1: Project Scoping/ • Initial Assessment of Area
Initial Screen of
Candidate Sites
• Stage 2: Preliminary
Environmental
Assessment
If potential concerns are
identified in Stage 2,
additional assessment may
be warranted
• Stage 3: Comprehensive
Environmental Review
• Stage 4: Develop Site-
specific Mitigation/
Remediation Measures
• Stage 5: Implement
Remedial/Mitigation
Measures
• Stage 6: Long-term
Stewardship
Air Quality
Inventory of Air Pollutant
Sources and Emissions
Screening Evaluation of
Potential Air Quality
Development of an
Environmental
Assessment Report
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At the beginning and throughout the process of
considering environmental factors in the school
siting process it is essential for the LEA to involve
the public by reaching out to stakeholders in the
community, especially those most impacted by the
decision to build a new school or renovate an
existing school. Stakeholders can include parents,
teachers, school personnel, school health council
or team members, community and business
leaders, and nearby residents. It is important to
develop a communications plan (see Section 3.4)
and to identify opportunities for meaningful
public involvement (see Section 3) to ensure the
public is engaged throughout the entire school
siting process. It is also important to enhance the
capacity of disadvantaged and other community
members to participate in the process through
facilitating access to technical information and
assistance and providing access to information for
individuals with disabilities and limited English
proficiency. To ensure public involvement in
consideration of environmental factors in school
siting decisions, EPA recommends that the LEA
establish a school siting committee (SSC) (see
Section 3.3). This committee should generally
consist of representatives of the LEA and its
governing body, local government or tribal staff,
and representatives from stakeholder groups that
can help the LEA identify and evaluate potential
school locations (both new and existing).
Before beginning the siting process, an initial
decision should be made on whether a new school
facility is needed. If the LEA, advised by the SSC,
determines that a new facility is needed, the
location will play an important role in determining
whether the LEA's goals for the facility will be met
(see Section 4.2.1).
It is critical for the LEA and the SSC with the
community's input to identify environmental
factors related to desirable school location
attributes that can be used to prioritize potential
new sites (see Section 4.3). Questions that can be
asked to determine these characteristics include,
but are not limited to:
What environmental and public health criteria
should be used to evaluate each potential
location (see Section 4.4)?
• How can locations be avoided that are either on
or in close proximity to land uses that may not
be compatible with schools because of onsite
and/or offsite pollution and/or safety hazards?
How can prospective locations complement and
leverage local and regional growth and
development plans and strategies?
What are the desirable cultural or historic
preservation attributes that should be
considered?
• What environmental justice considerations
should be included in the desirable location
attributes? (www.epa.gov/environmental
justice)
How will staff, students and community
members get to the school?
What are the potential impacts that the school
might have on the environment?
• What attributes will allow the school to serve as
an emergency shelter for the community?
Once potential locations have been identified
(see Section 5.5) by the LEA and the SSC with the
community's input, the LEA and the SSC should
determine which potential locations best meet the
stated desired environmental attributes.
Questions that can be used to further evaluate
potential locations include, but are not limited to:
Which locations present the least risk of
exposure to pollutants originating either onsite
or offsite?
Which locations have opportunities for shared
or joint use of school facilities (such as a library,
classrooms, physical activity facilities or a
health clinic) or community facilities (such as
an athletic center or park)?
Which locations best fit with local, tribal,
regional and state development plans?
Which locations would give the most students
additional physical activity opportunities by
being able to walk or bike to school?
Overview of the School Siting Guidelines
-------
Which locations would result in the lowest
potential for negative impacts on the
environment?
After deciding which locations best meet the
desired positive environmental attributes, LEAs
should conduct a preliminary environmental
assessment (see Section 5.6) on these locations,
which is the first stage in the environmental
review process (see Section 5.3). EPA
recommends consulting with state and tribal (see
Section 7) environmental and education agencies
during the environmental review process to
ensure compliance with requirements and policies
and to obtain technical assistance. Examples of
topics the LEA, the SSC and the community can
consider during the environmental review process
include, but are not limited to:
The environmental history of each location,
which can include soliciting public input about
the past use of each location;
• Assessments of potential onsite
environmental hazards from contaminated
soil and water at the site;
• Assessments of potential offsite
environmental hazards from nearby sources;
The technical feasibility and the costs
associated with preventing or reducing
environmental exposures, if present, from a
short- and long-term perspective;
The environmental impact of building or
renovating a school on the site (e.g., loss to
habitat or green space); and
• Other physical characteristics such as overall
safety and proximity to noise and traffic.
Once the preliminary assessment has been
conducted and the assessment reports have been
reviewed by the public and the SSC, if no
environmental concerns exist, a decision can be
made to move forward with the preferred school
location.
If potential environmental concerns are found in
the preliminary assessment, EPA recommends
Cost Considerations for School Siting
During the siting process, the LEA will
need to consider costs related to
comparing desirable attributes of
candidate sites, performing the
assessments recommended in these
guidelines and acquiring the site or
structure. Some of these cost
considerations include:
• Cost of land and location preparation;
• Short- and long-term construction or
renovation costs;
• Transportation costs for students and
staff; and
• Cost estimates for mitigating or
reducing environmental risks and long-
term stewardship of remediation
measures.
performing a more comprehensive environmental
review for the location found to have potential
concerns (see Section 5.7). The comprehensive
environmental review should determine if
hazardous materials are present or if there is
potential for a release of or exposures to a
hazardous material or substance that could pose a
health threat to children, staff or community
members. This review could also assess the need
for cleanup based on levels of contamination
found and identify the cleanup standards that will
be used. Once the comprehensive environmental
review is completed and the public has been given
the opportunity to comment, the LEA, the SSC and
the community should have the information
related to the school environment needed to make
a final decision about where to locate the school. If
there are onsite and/or offsite environmental
hazards, site-specific remediation/mitigation
measures and a long-term stewardship plan
should be developed, reviewed by the public and
implemented, (www.epa.gov/schools/
siting/resources)
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3. Meaningful
Public Involvement
3.1. Overview
A meaningful public involvement process requires
those administering the process to be familiar
with and use good public involvement and risk
communication practices.
Public involvement promotes civic engagement
and builds public trust in school siting decisions.
In 2003, the Environmental Protection Agency
(EPA) updated the 1981 Public Participation
Policy and issued its Public Involvement Policy.
(www.epa.gov/publicinvolvement/policy2003/in
dex) Its foundation is the seven basic steps to
support effective public involvement:
1. Plan and budget;
2. Identify those to involve;
3. Consider providing assistance;
4. Provide information;
5. Conduct involvement;
6. Review and use input and provide feedback to
the public; and
7. Evaluate involvement.
To help implement the steps, EPA developed a
series of How-To brochures for effective public
involvement (www.epa.gov/publicinvolvement/
brochures/index) as resources on how to budget
for, plan and evaluate public involvement,
including 'The Risk Communication Workbook."
(www.epa.gov/nrmrl/pubs/625r05003/625r050
03.pdf)
Seven Cardinal Rules for Risk
Communication34
There are seven cardinal rules for risk
communication that may be helpful when
planning public involvement strategies:
1. Accept and involve the public as a
legitimate partner;
2. Plan carefully and evaluate your efforts;
3. Listen to the public's specific concerns;
4. Be honest, frank and open;
5. Coordinate and collaborate with other
credible sources;
6. Meet the needs of the media; and
7. Speak clearly and with compassion.
U.S. Environmental Protection Agency,
"Seven Cardinal Rules of Risk Communication," U.S. Environmental
Protection Agency, Washington, DC, OPA-87-020, April 1988.
(Accessed on September 16, 2011) Available at:
www.epa.gov/care/libra ry77_cardinal_rules.pdf.
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3.2. Establishing a Public
Involvement Strategy
Providing meaningful public involvement
throughout the school siting process is of critical
importance and should be formalized prior to
initiating school site selection. Stakeholder groups
such as parents, representatives of students,
teachers and other school personnel, and nearby
residents are most directly impacted by school
siting decisions. The community should be fully
engaged throughout the siting process and fully
informed of the presence of contaminants at or
near school sites, of any remedial measures
employed to eliminate exposure to such
contaminants, and of testing results evaluating
such measures over the long term. These groups
also play a critical role in the initial site selection
process. Documentation of contaminated sites can
be housed in many different locations (e.g.,
federal, tribal or state environmental regulatory
agency, local health or planning department,
private property owner). This can make it difficult
to find a complete record of the contamination
history at the site. Efforts are underway to
consolidate these different information sources
through geospatial and Internet accessible
methods. Currently members of the public can use
EPA's MyEnvironment search application
(www.epa.gov/myenvironment) to find a cross
section of environmental information based on
location. Additionally, members of the public can
contribute to the information collection effort
through their own recollections as neighbors or
employees. The public should be engaged to help
establish historical uses of potential school sites
and adjacent sites and to assess the likelihood and
possible presence of contamination. Because these
groups may also have frequent contact with the
site, they can significantly contribute to efforts to
ensure compliance with site use restrictions as
part of long-term site management plans. Finally,
transparency and meaningful public involvement
are essential to understanding decisions about
risk tradeoffs and to building trust in the safety of
specific school sites and the siting process in
general.
A public involvement strategy includes proactive
and meaningful approaches to encouraging
informed public participation. The role of the
public in facility planning and site selection should
be established early in the school siting process to
ensure effective collaboration and public
participation. Key components for implementing a
meaningful public participation strategy include:
• School siting committee (see Section 3.3);
• Communications plan (see Section 3.4);
• Consideration of community information
accessibility issues (see Section 3.5);
• Technical assistance and training
(see Section 3.6);
• Designation of opportunities for public input
(see Section 3.7); and
• Budget for public involvement activities
(see Section 3.7).
3.3. School Siting
Committee
If not already in place, EPA recommends that local
education agencies (LEAs) (see Section 10)
establish a school siting committee (SSC) whose
responsibilities include making recommendations
to the LEA's governing body on sites for
renovating existing buildings for educational
purposes, building new schools and/or leasing
space for new schools. SSC responsibilities would
also include participating in the environmental
review of potential sites and structures for
existing and new use conversions. EPA
recommends that the formation of the SSC be a
publicly transparent process and that the SSC
include:
Representatives of the LEA and its governing
body (such as elected school board members,
facility, health and safety staff);
Local government or tribal staff (such as city
planners, government environmental health
specialists, county auditors, parks and
recreation department staff); and
Meaningful Public Involvement
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Representatives from stakeholder groups that
reflect the demographics of the community,
such as:
- Parents of children likely to attend the
school;
- Teachers and school staff;
- Public health organizations;
- Community members and neighborhood
groups;
- Environmental advocacy and
environmental justice groups;
- Community planning organizations;
- Locally based nonprofits;
- Age-appropriate students;
- Local businesses and trade/building
associations;
- Emergency planners and responders; and
- Preservation organizations and agencies.
Long-range School Facilities Plan
School siting decisions should be
integrated with broader community
planning efforts, including transportation,
health care, libraries, parks and historic
districts, to name a few. A long-range
school facilities plan functions as a way
for LEAs to identify important projections
of long-term school and community
needs such as student enrollment,
operational costs and infrastructure to
use in making school siting
decisions. The LEA's long-range plan
should be reviewed and commented on
by the public, including other local public
entities (e.g., municipalities, planning
departments). More information on the
long-range school facilities plan can be
found in the Environmental Siting Criteria
Considerations section (see Section 4).
LEAs should seek to avoid conflicts of interest in
selecting committee members and should manage
any conflicts transparently, as needed. It is
recommended that the local school board, or a
similar governing body, formalize the process of
convening the SSC and develop language that
clearly articulates the SSC's charge. EPA
recommends that a neutral party help organize,
administer and/or facilitate the work of the
committee.
The SSC can play an integral role in making
decisions about the most environmentally sound
school location. One of the first responsibilities for
an SSC can be contributing to the development of
a plan for meaningful public engagement in the
decision-making process, including ample time
(e.g., 30-90 days) for public comment by
members of the affected community. The SSC can
also assist with other key steps in identification of
environmentally desirable potential school
locations, including:
Establishing desirable location criteria;
• Identifying initial candidate locations,
including the existing schools;
Weighing the pros and cons of a community's
experience with the existing location;
Working with environmental professionals to
review the suitability of candidate locations
(see Section 10);
• Reviewing recommendations and reports
from the environmental review process;
Considering the suitability of potential school
sites in light of the locations;
Giving recommendations to the decision-
making authority based on data and public
input;
Making formal presentations and providing
reports to the LEA and general public;
Providing the public with all of the
appropriate data, a forum to express their
opinion and/or to make a recommendation on
the available options; and
• Facilitating public access to relevant technical
and legal information through technical
assistance and other measures.
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SSC members should collaborate with LEAs and
other local government agencies and stakeholders
to ensure school siting decisions account for fiscal
constraints and fit with the objectives of larger
community and regional development plans.
Community involvement in school facility
assessment, planning, design and construction
provides the community an opportunity to
improve local schools, increase their suitability for
community use and build and strengthen
connections among community members. The
Smart Growth Schools Report Card
(www.smartgrowthschools.org/
abouthtml), For Generations to Come: The
Leadership Guide to Renewing Public Buildings
(www.21csf.org/csf-home/Documents/
Organizing_Manual.pdf) as well as other resources
identified in the Resource page of the guidelines
website (www.epa.gov/schools/siting/resources)
can serve as useful tools to support collaboration
and community involvement.
The SSC should be mindful of its members'
knowledge and expertise to effectively
participate in decision-making. The SSC should
also ensure that its members effectively reach out
to environmental justice and low-income
communities, as well as other stakeholders, with
technical assistance and/or training support to
ensure that they have the necessary skills and
knowledge to address relevant issues, (see links to
Community Involvement and Training resources
atwww.epa.gov/schools/siting/resources)
Engineering and institutional controls, such as
lead encapsulation systems, can be used to
prevent exposure to contamination and typically
require specialized expertise. The SSC should
carefully evaluate if there is sufficient capacity at
the LEA to safely operate engineering and
institutional control systems or to undertake long-
term stewardship tasks to prevent environmental
exposures at schools. If the LEA staff do not have
the expertise, EPA recommends that LEAs obtain
training or support from a government
environmental department and/or additional
contracted technical services to effectively
manage institutional and engineering controls.
3.4. Communications Plan
LEAs should develop a communications plan to
ensure meaningful public involvement in school
siting. The plan should include a schedule and
methods of delivery of information to the public
and identify ways for the public to participate
throughout the school siting decision-making
process. It is essential that the public receives
timely notice about the LEA's plans for school
facilities and critical decision points in the
process. To ensure that key stakeholders receive
such notice, LEAs should publicize the release of
plans and reports, the commencement of public
comment periods, and the dates of public hearings
through written notices that are:
• Composed in lay-accessible language to
communicate effectively with all stakeholders
in the community, including non-English-
speaking stakeholders and individuals with
disabilities;
Published in newspapers of general
circulation within the LEA's jurisdiction
(including foreign language newspapers for
any non-English-speaking population);
Placed conspicuously in schools within the
LEA;
Delivered to each parent-teacher
organization and each labor union covered
by a collective bargaining agreement within
the LEA;
Delivered to businesses and residents
located within 1,000 feet of potential school
locations;
• Delivered to places of worship and
community centers within the LEA's
jurisdiction;
Delivered to organizations representing
neighborhoods within potential catchment
areas;
Provided to elected representatives in
jurisdiction areas; and
Disseminated on the Internet through
websites and social media (e.g., Facebook,
Twitter, blogs).
Meaningful Public Involvement
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Public comments received on plans and reports
should be made available on all non-final actions,
and the LEA, SSC and other governing bodies
should be encouraged to provide responses to
these comments.
LEAs and/or state or tribal environmental
agencies should also establish and make public
key contact persons, including local planning,
public works, parks and recreation, and library
directors, and create central information
repositories (e.g., a project website and other
centralized sources such as community libraries)
for key documents and notices related to school
siting and monitoring. For each ongoing school
siting process, these repositories, including the
website, should provide:
Documents that are or have been subject to
review and comments received on such
documents;
Relevant correspondence between LEAs and
the state or tribal oversight agency, including
any supplemental information provided as a
result thereof;
• A timeline for the review process that
specifically notes opportunities for public
comment and public hearings;
• Copies of any public notices;
Key school siting resources, including laws,
regulations, guidance documents and
appropriate agency contacts;
• For any schools where environmental
remediation measures (see Section 5.8) are
put in place and/or long-term stewardship
plans (see Section 5.10) are implemented,
copies of such measures or plans and the
results of any monitoring results or reports
generated under those measures or plans; and
How the project supports the community's
long-range plans.
3.5. Consideration of
Community Information
Accessibility Issues
A number of factors can impede effective
communication in community settings, including a
lack of trust between stakeholders and
community members, a lack of easily accessible
information related to decisions in languages
spoken by local residents, socio-cultural
differences, lack of access to electronic
communication resources, limited access to
scientific information and legal resources, and a
lack of available time for meetings and review of
documents.
These factors can be especially prominent in
populations disproportionately burdened by
environmental hazards as well as those vulnerable
subgroups that are at particular risk to threats to
human health and the environment. These include
minorities, low-income and indigenous
populations, children and people with disabilities.
Although these factors can frequently be
overcome, the LEA may need to enhance
information delivery and communication methods
and consider providing assistance to communities
that are affected by a combination of any or all of
these factors to ensure their meaningful and
informed participation in the process.
Every effort should be made to provide
information that will be accessible to the
community. Some activities that should help make
information more accessible include:
Seeking out community leaders to obtain
their views on how to best communicate and
follow their advice;
Holding public meetings that are convened
at times and locations available and accessible
to community members (provide the services
of an interpreter for those who need it);
Publicizing meetings and the availability of
information;
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• Posting information on the Internet and
making it available in multiple languages, if
needed, to reach all members of the
community;
Meeting Internet accessibility standards
for making information on the Internet
accessible to users with disabilities (e.g., for
the federal government this would be 508
compliance); and
Organizing a community tour of existing
sites and/or potential and proposed locations.
Addressing accessibility issues is important to
ensure effective communication and
community support for projects. In the end,
community support will be critical to help
gain support for school funding and siting
decisions.
3.6. Technical Assistance
and Training
A broad representation of stakeholder groups is
important for meaningful public involvement.
However, it should not be assumed all members of
the SSC have the necessary skills and knowledge
to fully participate on the SSC. Similarly,
community members, particularly those affected
by environmental injustice (e.g., minority and low-
income populations, and tribes), may lack the
resources to effectively address the scientific,
technical and legal information presented during
the school siting process. For these reasons, it is
critical that all members of the SSC and the
community have the opportunity to access
technical assistance that provides a basis for
common knowledge and understanding on factors
that are critical in the school location decision,
including public health, transportation options,
environmental review, site review issues, site-
specific mitigation/remediation strategies and
legal considerations. Many federal agencies and
non-profit organizations offer training at little to
no cost and also have programs with funding
available for various technical assistance
resources. Examples of these programs and
training opportunities can be found on the
Resources page of the guidelines website under
Technical Assistance and Capacity Building.
(www.epa.gov/schools/siting/resources)
Communities may also consider reaching out to
local colleges and universities, state, tribal and
local governments, or professional organizations
for assistance and training on specific scientific or
technical topics.
3.7. Designation of
Opportunities for
Meaningful Public Input and
Budget for Public
Involvement Activities
It is critical to budget time and resources for
meaningful public involvement during the earliest
stages of planning. The table below presents
examples of points in the process where public
engagement should be considered, as well as
strategies for engagement and the types of
information that may be presented to or
requested from the public. SSCs should also
consider including a public comment period and
public hearings, when appropriate, to allow the
public to seek clarification and provide input.
Before finalizing its action, EPA encourages the
LEA to respond to comments in writing.
EPA recommends that all properties or structures
proposed for use as a school be carefully
evaluated for potential environmental
contaminants and potential exposures of children,
staff and visitors before making final decisions to
use a site or structure for a school. The site
evaluation process should identify and evaluate all
potential safety hazards and sources of
environmental contamination that may be present
at the site or which may migrate to the site from
nearby sources.
Meaningful Public Involvement
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Exhibit 2: Meaningful Public Involvement Points and Opportunities
Before the Siting Process Begins
LEA Activity
Description of Activity
Opportunities for Meaningful Public
Involvement
Develop Long-
range School
Facilities Plan
(see Section 4.2.1)
A long-range school facilities plan
functions as a way for local education
agencies (LEAs) to identify important
projections of long-term school and
community needs such as student
enrollment, operational costs and
infrastructure to use in making school
siting decisions.
Review and comment on the
long-range facilities plan
Establish School
Siting Committee
(see Section 3.3)
If not already in place, EPA recommends
that LEAs establish a SSC whose
responsibilities include making
recommendations to the LEA's governing
body on locations for building new
schools, leasing space for new schools,
and/or renovating or expanding existing
schools, and considering environmental,
public health and sustainable
communities objectives (see Section 3.3).
Provide nominations for
stakeholder/community
representatives on the SSC
Request a community meet-and-
greet with SSC representatives,
once selected
Develop
Communications
Plan
(see Section 3.4)
LEAs should develop a communications
plan to ensure meaningful public
involvement in school siting. The plan
should include dates and methods of
delivery of information to the public, and
identify ways for the public to participate
in school siting decisions. The plan should
also ensure sufficient funds are allocated
for meaningful public involvement
activities in the school siting budget.
Voice expectations for informed
and meaningful involvement
while addressing potential
communications barriers and
considerations for
underrepresented community
members, including translation
services
Provide recommendations for the
location of an information
repository and information
delivery needs, and ensure that
the communications plan and
public involvement budget will
meet these needs
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Before the Siting Process Begins
LEA Activity
Description of Activity
Opportunities for Meaningful Public
Involvement
Provide
Opportunities for
Training and
Technical
Assistance
(see links to
resources at
www.epa.gov/
schools/siting/
resources)
A broad representation of stakeholder
groups is important for meaningful public
involvement. However, it should not be
assumed all members of the SSC have the
necessary skills and knowledge to fully
participate on the SSC. For these reasons,
it is critical that all members of the SSC
and the community have the opportunity
to access technical assistance and/or
training resources that provide a basis for
common knowledge and understanding
of factors that are critical in the school
location decision, including public health,
transportation options, environmental
review, site review issues, site-specific
mitigation/remediation strategies and
legal considerations.
Ensure that all community
members (including the SSC) have
the ability to access and utilize
available independent technical
assistance options and training
resources
This may be accomplished by
inquiring about grant funding for
technical assistance and/or the
availability of low-cost or free
online training resources
Consider reaching out to local
colleges and universities, state,
tribal and local governments, or
professional organizations for
assistance and training on specific
scientific or technical topics
Determine if a New
School Facility is
Needed
(see Section 4.2.2)
LEAs should consider renovation, repair
and/or expansion options before deciding
to build a new school facility. "Old" and
"obsolete" are not synonymous. Many
existing schools can be retrofitted with
new technologies to expand their useful
life, possibly at a lower cost and lower
environmental impact than new
construction.
Engage in discussions with the
LEA and SSC regarding the pros
and cons of using an existing
school building versus building a
new school facility. These
discussions may include getting
community input on the influence
of the existing school on the well-
being of the overall community,
including disadvantaged/
underserved, minority and low-
income populations
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Environmental Siting Criteria Considerations
LEA Activity
Description of Activity
Opportunities for Meaningful Public
Involvement
Evaluate Desirable
Environmental
Attributes of
Candidate
Locations and
Appropriate
Environmental
Criteria
(see Section 4)
The LEA, in concert with the SSC and with
meaningful public involvement, should
identify the criteria that will be used to
evaluate both the present characteristics
and the possible future characteristics of
all locations being considered for use as a
school. In addition, the SSC should weigh
those location characteristics that may
adversely affect the decision, including
exposure to onsite contamination and
offsite pollution.
Discuss the characteristics of the
community's preferred school site,
including location (both proximity
to students and other community
buildings) and compatibility
(space and accessibility) with
student and staff activities
Help to identify environmental or
public health siting considerations
(with a basis for common
knowledge and understanding on
factors that are critical in the
school location decision),
including public health,
community health environmental
review, site review issues and site-
specific mitigation/remediation
strategies, legal considerations as
well as green building techniques
that are important to the
community
Provide insight into key
community characteristics that
could influence the siting decision
(e.g., demographics, income)
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Environmental Review Process
LEA Activity
Description of Activity
Opportunities for Meaningful Public
Involvement
Project
Scoping/Initial
Screening of
Candidate Site
Locations
(see Section 5.5)
This portion of the environmental review
process begins when the LEA decides to
proceed with a school facility project
(ideally identified in a long-range school
facility plan). This decision includes such
considerations as the project size (number
of students to be served), scope (type of
school to be built) and target date for
completion. At this point, the SSC should
be tasked with identifying candidate sites
for the school project and should plan to
give the public an opportunity to
comment on the preferred site that is
selected.
Review/comment on the
screening criteria proposed by the
LEA, as well as the top three sites
proposed for preliminary
environmental review
Recommend additional sites for
consideration that the community
deems as candidates for
preliminary environmental review
Offer community knowledge
regarding historic land use on
candidate sites (e.g., the site was
used for agricultural or industrial
purposes in the past)
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Preliminary
Environmental
Review
(see Section 5.6)
The LEA should engage environmental
professionals or professional firms to
conduct the necessary environmental
reviews for the project.
The LEA should solicit public comment on
the preliminary environmental assessment
and proposed next steps based on review
findings. A public comment period is
recommended and may be required by
the tribal or state regulatory agency,
particularly if the preliminary review
indicates that no further environmental
review is necessary and no other methods
of securing public comment are likely.
Review/comment on each
preliminary environmental review
report as they become available
and request LEA response to
comments received
Identify community needs for
technical assistance to explain the
technical/scientific information in
the reports
Request tours of candidate sites
for community
members/representatives, if
possible
Notify the LEA of the community's
perspectives on the preferred
site(s) and request a response to
community recommendations
Request changes to the public
involvement plan (e.g., to extend
the public comment period), if
necessary
Meaningful Public Involvement
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Environmental Review Process
LEA Activity
Description of Activity
Opportunities for Meaningful Public
Involvement
Comprehensive
Environmental
Review/Site
Selection
(see Section 5.7)
The purpose of the comprehensive
environmental review is to gather and
analyze data on environmental and public
health hazards and impacts identified in
the preliminary environmental review, and
evaluate the risks posed to children's
health, public health, and the environment
based on the contamination or impacts
found. The comprehensive environmental
review also includes developing
preliminary plans and cost estimates for
mitigating or reducing risks.
The environmental professional should
prepare draft reports of onsite
contamination, investigation results,
offsite hazards and project environmental
impacts. The LEA should release those
drafts for public comment. The
environmental professional should then
prepare final drafts that take into account
public comments. The final drafts should
be subject to review and approval by the
SSC and LEA.
Review and comment on the draft
versions of the comprehensive
environmental review report
Request a response to public
comments from the LEA and
review the resulting final draft of
the comprehensive environmental
review report
Request and attend any
scheduled public meetings to
discuss project impacts
If the final comprehensive
environmental review report
includes proposals for mitigation
measures (e.g., additional
sidewalks, enhanced filtration in
the heating, ventilating and air
conditioning system, institutional
controls), review preliminary cost
estimates and schedules of
implementation for any
remediation of onsite
contamination and provide input
on implications of the suitability
of that site for a school
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Environmental Review Process
LEA Activity
Description of Activity
Opportunities for Meaningful Public
Involvement
Develop Site-
specific Mitigation/
Remediation
(Cleanup)
Measures
(see Section 5.8)
If the LEA decides to proceed with a site
where contamination will be cleaned up, a
remedial action workplan should be
developed and submitted to the state or
tribal regulatory agency for approval,
typically with the help of an
environmental professional.
The remedial action workplan should
identify and recommend methods for
cleaning up the site to contaminant levels
that meet the applicable safety standards
and should clearly describe the
responsibilities and long-term
environmental stewardship obligations of
the LEA (or other responsible parties) for
inspection, maintenance and reporting
associated with any engineering or
institutional control implemented as part
of the cleanup. The remedial action
workplan should also include a
preliminary long-term stewardship plan
(LTSP).
Participate in the public hearing
on the draft remedial action
workplan, which the LEA should
conduct in the neighborhood or
jurisdiction where the candidate
site is located, at a time and
location convenient for
community residents, with
interpretation services provided as
needed
Review and comment on the draft
remedial action workplan during
the public comment period and
request a response to comments
from the LEA
Community input is important on
remedial action workplan issues
such as:
Sufficiency of remedial
response
Timeline for remedial work
Cost estimates for remedial
work
Effects of remedial actions on
the community and daily life
(traffic, noise, etc.)
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Meaningful Public Involvement
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Environmental Review Process
LEA Activity
Description of Activity
Opportunities for Meaningful Public
Involvement
Implement
Remedial/
Mitigation
Measures
(see Section 5.8)
Prior to the onset of any school
construction on the candidate site, EPA
recommends that the remediation of the
site, as defined in the remedial action
workplan, be completed. If engineering or
institutional controls are required as part
of remediation, construction of those
controls may begin following approval by
the state or tribal environmental
regulatory agency.
Review and comment on
documentation regarding the
implementation of the plan and
all final sampling results
Any modifications to the remedial
action workplan should also go
through the appropriate public
review processes
Review and comment on the
revised LTSP, which should detail
specific engineering and
institutional controls, if applicable
(see Section 8.14)
Suggest adding a public
accountability/oversight plan to
the LTSP to ensure long-term
public and institutional memory
of the LTSP through activities
designed to promote awareness
by students, staff and the
community, including signage at
the site and reporting measures
Long-term
Maintenance and
Monitoring
(see Section 5.10)
LEAs should incorporate key components
of the long-term stewardship plan into
other facilities and operational plans and
training materials for principals, facilities
staff, groundskeepers and
contractors. This plan describes in detail
the specific manner in which institutional
and engineering controls will be
employed in the future, and by whom.
Consider forming a public
oversight committee to ensure
that periodic reviews are
conducted on the effectiveness of
remedial measures and any
engineering and institutional
controls that are used at the site
Provide the LEA and tribe or state
with a list of community contacts
to be notified if a problem arises.
Ensure there is a contact person
for the community to go to with
concerns related to facility
maintenance or monitoring
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4. Environmental
Siting Criteria
Considerations
4.1. Overview
School location plays an integral role in creating
healthy, safe schools that support high quality
education and promote sustainable and healthy
communities. In order to reach these goals, the
local education agency (LEA) (see Section 10), in
concert with the school siting committee (SSC)
(see Section 3.3) and with meaningful public
involvement (see Section 3), should identify
criteria that will be used to evaluate both the
present characteristics and possible future
characteristics of all locations being considered
for the school. Characteristics of surrounding
properties and current and planned zoning and
land uses near the location should be evaluated.
Careful assessment takes time, but the importance
of school siting decisions justifies the attention
and the need for sustained public involvement to
ensure that the location meets the needs of the
community and has community support.
This section includes information on the following
general areas of consideration for deciding where
to locate a school:
• Whether a new school is needed
(see Section 4.2.2);
* Whether the new school will be a high
performance/green school (see Section 4.2.3);
• Whether some candidate locations increase
environmental health or safety risks
(see Section 4.3.1);
• Implications of the school location for
transportation options (see Section 4.3.3);
• Options for developing Safe Routes to School
Programs that can support alternative modes
of transportation (see Section 4.3.4); and
• The potential use of the school as an
emergency shelter (see Section 4.3.5).
Balancing the many criteria and potentially
conflicting characteristics of candidate locations
can be very complex. For example, in most urban
areas, potential school locations that are
accessible to the community may have been
previously used for other purposes that may
present environmental hazards. Further, they may
be located in proximity to sources of potential
environmental health and safety concerns, such as
highways, rail yards, a wide range of light and
heavy industries and other facilities that, under
ideal circumstances, would not be located near a
school or other facilities used for children's care.
Sites that have not previously been developed—
often called greenfields (see Section 10)—are
often not ideally located in terms of
environmental impact and transportation options.
Integrating community centered schools into
existing residential neighborhoods often allows
for better environmental, community, economic,
educational and public health outcomes. These
community centered schools allow children,
faculty and staff to walk or bike to and from the
school and use public transportation options,
when available. These schools also often take
advantage of previous investments in
infrastructure and add to the vibrancy and vitality
of a community.
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Some candidate school locations may have real or
perceived environmental challenges. While the
prior uses and potential for onsite contamination
and impacts from nearby sources for some
candidate locations may be known, in other cases,
determining these issues at candidate sites
requires investigation. The challenges of potential
environmental hazards associated with sites can
be overcome in many, although not all instances.
Technical assistance and oversight from state,
tribal and local environmental, public health and
planning agencies can help communities evaluate
potential environmental and public health
concerns at specific sites. A thorough evaluation of
such concerns will help communities, LEAs, and
local, tribal and state leaders choose locations that
can achieve multiple objectives from school
facility investments while minimizing potentially
adverse environmental and health issues.
Assessing and balancing multiple potential risks
and benefits while considering renovation or
expansion of an existing facility or prospective
new sites is not a simple task, and there is no
single tool available to accomplish it. The
following sections, Identify Desirable School
Location Attributes (see Section 4.3), and
Consider Environmental Hazards (see Section
4.4), highlight considerations that should be taken
into account as local communities establish their
own school siting criteria, and the Environmental
Review Process section (see Section 5) of the
guidelines describes a process for identifying and
assessing environmental hazards.
4.2. Before the Siting Process
Begins
4.2.1. Develop a Long-range School
Facilities Plan
School siting decisions should be integrated with
broader community planning efforts, including
transportation, health care, libraries, parks and
historic districts, to name a few. Many
communities across the country use data-driven,
community-based processes to create and
implement comprehensive plans that set forward
strategies and policies that support future growth
and development.35 Development of a long-range
school facilities plan can help LEAs to identify
important projections of long-term school and
community needs such as student enrollment,
operational costs and infrastructure to use in
making school siting decisions. LEAs should
engage with planning commissions, boards of
supervisors and/or city councils from the outset
to develop long-range school facilities plans that
link to and complement comprehensive
community plans. Through this linkage, the long-
range school facilities plan would incorporate
community growth and the school district at large
in the school siting process, rather than
considering the potential school locations in
isolation from other important community
planning issues.
EPA encourages LEAs to prepare a long-range
school facilities plan that does the following:
• Projects school district enrollments for the
foreseeable future (e.g., 5 - 20 years);
Identifies existing school infrastructure
that may need to be improved or replaced;
• Establishes the need for additional
instructional or multiuse space, if any,
based on projections;
• Works with local authorities to consider
broader community needs such as emergency
shelters, community meeting space, sports
and recreation;
• Develops a plan for meeting new space
needs that includes various approaches such
as renovating or reconstructing school
facilities on existing school grounds,
constructing school buildings on newly
acquired sites and leasing space in existing
buildings;
• Includes approximate dates for opening
new school facilities;
35 San Diego Unified School District, "Long-Range Facility Master
Plan." Available at:
http://www.sandi.net/cms/lib/CA01001235/Centricity/Domain/82/Lon
g_Range_Facilities_Master_Plan/Section_l/ALL_Sectionl.pdf.
Environmental Siting Criteria Considerations
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Targets enrollment size by type of facility;
and
• Factors in other local and regional
planning cycles and potential funding or
resource streams, such as connections with
existing or new street, park, residential or
commercial infrastructure.
The LEA's long-range plan should be reviewed and
commented on by the public, including other local
public entities (e.g., municipalities, planning
departments). Finally, the long-range plan should
be approved by the LEA.
4.2.2. Consider Whether a New School Is
Needed
The first criterion to consider is whether a new
school is needed. Communities should consider
renovation, repair and/or expansion options
before deciding to build a new school. The terms
"old" and "obsolete" are not synonymous. Many
existing schools can be retrofitted with new
technologies to expand their useful life, possibly at
a lower cost and with fewer environmental
impacts (e.g., energy savings, less impact on open
space) than new construction. A school that is too
small for an existing population may be expanded
or may serve a narrower grade configuration or a
special program. Using existing facilities offers
other benefits that new construction often cannot.
For example, many older school facilities were
built at a time when schools were planned to
serve as the focal point in a neighborhood not only
for education but also for community events,
libraries and open play fields. Continued use of
existing schools can encourage physical activity
because they are often located in the most
walkable and bikeable parts of a community.
Renovating existing neighborhood school facilities
can provide an impetus for community
revitalization, have an impact on neighboring
property values, encourage investment in schools
by community members, and preserve
irreplaceable community assets.
It is important to consider both direct and indirect
costs associated with building in a new location,
such as the cost of site acquisition, transportation,
traffic congestion, operation and maintenance,
environmental cleanup, necessary infrastructure
improvements and long-term monitoring and
maintenance costs. In addition, renovation and/or
expansion of an existing building can be part of a
community revitalization effort or serve as an
impetus for starting a broader revitalization effort.
Siting policies that discourage renovation or
expansion of existing schools and favor building
larger new schools can contribute to
disinvestment in existing neighborhoods. This
disinvestment further contributes to the physical,
social and economic decline seen in many
neighborhoods where a large percentage of low-
income, African-American and Hispanic or Latino
students live.36
Consider taking the following actions to decide
whether a new school is needed:
Evaluate the existing school's current
facilities and potential facilities (through
renovation/rehabilitation) and the full costs
of alternatives, including educational, fiscal,
environmental and public health impacts.
• Evaluate the school for health,
environmental and safety risks from both
onsite and offsite sources of potential
contamination.
NOTE: The Environmental Protection Agency
(EPA) recommends that districts periodically
inspect existing schools for potential
environmental health and safety risks using
tools designed for that purpose such as EPA's
Healthy School Environments Assessment
Tool (HealthySEAT; www.epa.
gov/schools/healthyseat/) or the NIOSH
Safety Checklist Program for Schools, (www
.cdc.gov/niosh/docs/2004-101/) Where
deficiencies are found, EPA recommends
identifying and implementing steps to reduce
student and staff exposure to potential
36 Ad-Hoc Coalition for Healthy School Siting, "Revising CDE School
Siting Policy Documents: How California's School Siting Policies Can
Support a World-Class Educational System," Submitted to the
California Department of Education by the Ad-Hoc Coalition for
Healthy School Siting (January 31, 2008). Available at:
http://citiesandschools.berkeley.edu/reports/School_Siting_Policy_Brie
f_013108.pdf.
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hazards, to the maximum extent practical (see
Section 9.14).
Evaluate the physical characteristics of
existing schools for their potential to meet
changing community needs. Is the school
ideally located to serve residents of the
community, including senior citizens?
Evaluate the effect on the educational and
social development of the students in the
community of constructing a new building,
renovating or expanding an existing facility or
closing a school.
Evaluate the ongoing value of a school
building as a public asset and identify how
the community in the immediate vicinity of
the school will be affected by renovating the
school, building a new school or closing the
school. Is the school a treasured part of the
town? Is the building a landmark that defines
the neighborhood?
Conduct an analysis of school system
operation savings and costs that would be
anticipated from renovating, building or
closing a school.
Consider potential increases in
transportation costs that would come from
moving the school to a new, more distant
location, including infrastructure (additional
buses, bus stops, street improvements, traffic
signals, etc.), fuel, increased air pollutant
emissions from buses and privately owned
vehicles and traffic congestion.
Determine if the school is accessible to
students, faculty and other employees with
disabilities (i.e., Americans with Disabilities
Act (ADA) and Section 504 compliant). If not,
what would be the cost of retrofitting an older
inaccessible building so that it meets ADA and
Section 504 requirements?
Evaluate stated preferences, goals and
alternatives within a community's
comprehensive plan, projected capital
investments in infrastructure and other
strategic investment commitments.
Evaluate the capacity of existing
infrastructure. If you build a new school, will
the facility be on public water and sewer? If
the LEA expands an existing school on a well
and septic system, can the septic field be
expanded?
Consider opportunities to partner with
other government services (e.g., parks,
health clinics and libraries) that can help
promote wellness and active transportation
choices.
Plan how to ensure the safety of the
children in the existing school during
renovation and construction. If major
renovation is undertaken or a new building is
built on an existing site, there is the potential
for significant disruption of construction and
demolition materials. It is important that best
management practices are used during
renovation and construction to prevent
exposure to these materials.
More information on renovating older and historic
buildings, environmental cleanup and community
planning can be found on the Resources page of
the guidelines website, (www.epa.gov/
schools/siting/resources.html#LINKS_community
_planning)
4.2.3. Consider Whether the New School
Will Be a High Performance/Green School
More than ever, technology, expertise and public
support exist to allow communities to build
superior learning environments that can support
higher achievement and provide healthier
learning environments while also saving energy,
resources and significant amounts of money. Often
referred to as healthy high performance schools
or green schools (see Section 10), these are
facilities that integrate all aspects of the design
process starting with selection of the design team
and the school location to design schools that
meet multiple educational, environmental and
community goals. The environmental goals of such
facilities include energy and water efficiency,
healthy indoor air, safer materials selection
(including life-cycle cost consideration), and
reduced environmental impact from the school.
The technologies and practices used to achieve
these goals are often integrated into the
curriculum and other student learning
opportunities.
Environmental Siting Criteria Considerations
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LEAs can use elements from green rating systems,
such as the U.S. Green Building Council's
Leadership in Energy and Environmental Design
(LEED; www.usgbc.org/DisplayPage.aspx?
CategoryID=19) for Schools Rating System and the
Collaborative for High Performance Schools.
(CHPS; www.chps.net/dev/Drupal/node) Both
LEED and CHPS rate schools based on sustainable
site selection and development, indoor
environmental quality, materials and resources,
energy atmosphere, water efficiency and
innovation. Because high performance/green
schools are based on the principle of integrated
design, in which all aspects of the school are
designed with a clear understanding of how the
various systems and decisions affect each other,
the decision to build a green school or renovate an
existing school to meet green standards should be
made before establishing siting criteria.
To ensure that a new school is energy efficient,
LEAs can design it to earn the ENERGY STAR (see
www.energystar.gov/newbuildingdesign). Building
orientation and shading strategies and renewable
energy technologies, such as geothermal heat
pumps, wind turbines and solar panels, can help
increase energy efficiency and reduce greenhouse
gas emissions. EPA encourages local governments
and communities to investigate and, where
appropriate, integrate healthy high performance
school or green school principles into their location
selection and school planning and operation
processes. Links to more information on green
building (www.epa.gov/greenbuilding) are
available on the Resources page of the guidelines
website, (www.epa.gov/schools/siting/resources)
The focus of these guidelines is on school siting,
but there are many tools and resources available
to ensure that school environments are healthy
throughout the lifecycle of the school building.
EPA has a considerable body of guidance and
regulations that are specifically geared toward
existing schools, which is available at
www.epa.gov/schools. EPA recommends that
districts periodically inspect existing schools for
potential environmental health and safety risks
from both onsite and nearby hazards using tools
designed for that purpose. These include EPA's
Healthy School Environments Assessment Tool
(HealthySEAT; www.epa.gov/schools/
healthyseat/) or the NIOSH Safety Checklist
Program for Schools, (www.cdc.gov/niosh/docs/
2004-101/) Where deficiencies are found, EPA
recommends identifying and implementing steps
to reduce student and staff exposure to potential
hazards (see Section 9.14), to the maximum extent
practical. In some cases, school specific
improvements can reduce potential hazards; in
other cases, such as widespread air pollution or
water quality issues, a community wide approach
may be called for.
4.3. Identify Desirable School
Location Attributes
State and local policies and practices should
support school locations that promote healthy
people and healthy behaviors, including physical
activity, healthy environments, and healthy
communities. School siting decisions influence
growth and development patterns and are
influenced by these patterns. Many communities
across the country are increasingly interested in
ensuring that growth and development meet
multiple community goals, including improving
public health; supporting revitalization efforts;
strengthening fiscal responsibility; increasing
transportation choices; providing opportunities to
live, work, play and attend school in convenient
locations; and limiting emissions of greenhouse
gases, criteria air pollutants and air toxics.
Selecting healthy, safe school locations in the
neighborhoods of the students the schools serve
helps meet many of these goals (see Exhibit 4:
Desirable Attributes of Candidate Locations).
Community centered schools encourage students
to walk and bike between home, school and
centers of community activity. In addition,
locations that allow community access to school
playgrounds and facilities encourage physical
activity outside of school time. The location of
schools in neighborhoods may allow more
children to participate in after-school activities
such as clubs, intramural and physical activity
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clubs, interscholastic sports or activities
sponsored by the community at local libraries,
parks and community centers. As discussed in
Principle 3 (see Section 1.4.3) in the About the
Guidelines section (see Section 1), schools located
within neighborhoods can also increase access to
public transportation for students, faculty and
staff in the neighborhood and in surrounding
communities.37'38
4.3.1. Select Locations That Do Not Increase
Environmental Health or Safety Risks
During the initial screen of candidate locations,
the LEA and SSC should seek to avoid locations
that are either on or are in close proximity to land
uses that may be incompatible with schools, if
acceptable alternative sites exist within the
neighborhood(s) being served by the new school.
These incompatible land uses may include
contaminated sites that have not been remediated
(i.e., cleaned up) to at least a residential use
standard, clusters of industrial facilities, or other
potential hazards identified in Exhibit 6: Screening
Potential Environmental, Public Health and Safety.
The section, Consider Environmental Hazards (see
Section 4.4), describes some principles used to
define environmental criteria and the typical
environmental and safety issues that the school
siting process should consider and address to
ensure that the location chosen does not pose
unacceptable environmental and public health
risks.
If no alternative locations exist, it is critically
important that the LEA and SSC fully explain the
absence of alternatives in a transparent manner
and fully engage the public in identifying and
37 Ariel H. Bierbaum, Jeffrey M. Vincent and Deborah L McKoy,
"Putting Schools on the Map: Linking Transit-Oriented Development,
Families, and Schools in the San Francisco Bay Area," Center for Cities
and Schools, Institute of Urban and Regional Development, University
of California Berkeley (June 2010). Available at:
http://citiesandschools.berkeley.edu/reports/Putting%20Schools%20o
n%20the%20Map_ Final_JullO_appendices.pdf.
38 Ariel H. Bierbaum, Jeffrey M. Vincent and Deborah L. McKoy,
"Linking Transit-Oriented Development, Families and Schools."
Community Investments (Summer 2010) 22:2.18-21. Available at:
www. frbsf.org/pu blications/community/investments/1008/A_Bierbau
m.pdf.
implementing both site-specific and community-
wide exposure and risk reduction strategies to
protect the health and safety of students and staff.
The LEA and SSC should consult with regional
planning authorities to be cognizant of future
plans for development or facilities that may result
in environmental or health threats to the school
location (e.g., large industrial facilities). Exhibit 5:
Factors Influencing Exposures and Potential Risks,
introduces some potential mitigation options for
potential environmental, safety and health
hazards.
4.3.2. Locate Schools Near Populations and
Infrastructure
Consider establishing clear goals and criteria to
give preference to locations near existing
populations and close to facilities and
infrastructure that support school programs to
minimize transportation and infrastructure costs
and their related environmental, economic, public
health and sustainability impacts. Additional
school capacity and the location of new schools
often influence the location of residential
development.39 School location is a critical aspect
of quality community planning. Schools built on
the fringes of communities can contribute to
outward migration from city centers, which can
cause disinvestment in existing neighborhoods
and can hurt local economies. This phenomenon is
particularly common when new school sites
require the extension of infrastructure, making
undeveloped areas more attractive for residential
and commercial development.
Flexibility with respect to school size and site size
allows communities to retain and upgrade (or
replace on the same site, when necessary) existing
schools. Smaller schools tend to be easier to locate
near population centers, minimizing
transportation needs and commuting exposures to
traffic-related air pollution. Goals and criteria to
39 Upper Grand District School Board, "Planning Department
Frequently Asked Questions." (Accessed on September 16, 2011)
Available at: http://www.ugdsb.on.ca/planning/article.aspx7id =4722.
Environmental Siting Criteria Considerations
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give preference to locations near existing
populations include:
Avoiding building schools in remote
locations that are not accessible by walking,
biking and public transportation;
• Maximizing proximity to program support
facilities such as community museums,
theaters, libraries, program centers,
recreational and enrichment activities and
downtown commercial areas;
Developing joint use agreements (see
Section 10) to facilitate school access to
community facilities and to allow community
access to school facilities;
Considering proximity to other schools.
There may be local reasons to minimize or
maximize distance between schools, such as
the desire to promote diversity or reduce
isolation in the LEA's schools; and
Avoiding locations that will require new
infrastructure such as roads, water/sewer or
utilities.
Locating a school in the community it serves may
result in proximity to pollution sources. Such
situations should be addressed by considering
information on associated hazards and the
availability and effectiveness of mitigation options
for addressing the environmental hazards, as well
as the potential additional cost and time involved.
Similar analyses for alternative options for
locating the school should be made. With that
information, communities should seek to balance
the benefits of a community centered school with
any potential environmental and public health
risks.
4.3.3. Consider Implications of the School
Location on Transportation Options
Transportation is a major factor in a school's
overall environmental impact. Schools that offer
more transportation choices can reduce the
amount of land that is paved, reduce automobile
and bus traffic and pollution and encourage
walking or biking to school. Scientific literature on
school travel shows clearly that the farther a
school is from a child's residence, the less likely it
is that the child will walk or bike to school, and
that virtually no children walk over two miles to
school.40'41 Connecting a school to a network of
sidewalks, bike paths and other infrastructure
encourages physical activity by making walking or
biking safe and enjoyable. It is also important to
provide walking and biking routes that do not
bring children close to large roads, highways and
other major pollution sources (for both health and
safety concerns). Site size, location and design all
play a role in determining whether walking or
biking will be an option for students. Locations
that provide access for students and staff via
public transit will also reduce vehicle use as well
as potentially promote increased physical activity
in getting to the transit stops from both home and
school.
Transportation costs, either to the school district
or to the families it serves, are also important to
consider. For example, transportation costs to the
district can include the cost to purchase, maintain
and store buses; the cost of fuel and personnel;
and the cost associated with an increase in school
bus mileage. The costs to families may be direct
(e.g., a fee for students to ride the bus) or indirect
(e.g., transportation-related taxes and fuel costs
associated with personally transporting their
children to school). The siting process should also
account for transportation cost externalities, such
as the health implications of exposure to exhaust
while riding the school bus or from idling vehicles.
Low-income and minority families can be
especially impacted by transportation costs since
children may not have the option of being driven
to school and often need to walk, bike, use the
school bus or take public transportation. This
reinforces the need to locate schools within
reasonable distance and provide a safe biking and
40 Lawrence Frank and Company, Inc., "Youth Travel to School:
Community Design Relationships with Mode Choice, Vehicle
Emissions, and Healthy Body Weight," Prepared for U.S.
Environmental Protection Agency, Washington, DC, December 2008.
Available at: www.epa.gov/smartgrowth/pdf/youth_travel.pdf.
41 Noreen C. McDonald, "Active Transportation to School: Trends
Among U.S. Schoolchildren, 1969-2001," American Journal of
Preventive Medicine (2007) 32:6. 509-516. Available at:
http://dot.ga.gov/localgovernment/FundingPrograms/srts/Document
s/news/Trends_Among_US_School_Children.pdf.
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walking environment for these populations. LEAs
should also consider how these costs may change
over the life of the school.
Communities should consider establishing goals
and criteria to give preference to locations that
will promote alternative modes of transportation,
including walking or biking. Minimum acreage
requirements, school funding formulas and
building codes often favor construction of new
schools over the renovation of existing
neighborhood schools; however, giving preference
to locations that will promote the use of public
transportation, walking or biking or that require
shorter driving distances will reduce
transportation costs for local government, as well
as parents and caregivers.42 School consolidation
policies should be carefully examined for their
impact on school transportation and students'
physical activity.
In new locations, schools can be designed to
encourage integration with future developments
by establishing street patterns, sidewalks and trail
networks that support walking and biking as
surrounding developments are constructed. This
can happen both as part of the design and
construction of the school campus and as a result
of subdivision regulations guiding development
within potential walking and biking distance from
a school's boundary.
The SSC should assess walkability and bikeability
of the area surrounding each school location
under consideration and evaluate the potential
long-term health effects of candidate locations on
the students and staff.43 A detailed example of
how to assess the bikeability/walkability of
candidate locations can be found in the "Active
42 Renee Kuhlman, "Helping Johnny Walk to School: Policy
Recommendations for Removing Barriers to Community-Centered
Schools," National Trust for Historic Preservation (2010). Available at:
www.preservationnation.org/issues/historic-schools/helping-johnny-
walk-to-school/helping-johnny-walk-to-school.pdf.
43 Safe Routes to School Program Arizona Department of
Transportation, "Active School Neighborhood Checklist," Arizona
Department of Transportation, ver. 14, August 6, 2010. Available at:
http://www.adotenhancement.com/SafeRou tes/PDF/Documents_Activ
e_School_Neighborhood_Checklist.pdf.
School Neighborhood Checklist"
(www.epa.gov/schools/siting/resources.htmlttLI
NKS_cleanup_regulations_and_processes)
developed in Arizona. The aim of the checklist is to
provide decision makers with a quantitative tool
for evaluating the potential long-term health
impacts of candidate school locations on the
children who will attend them. LEAs may also
wish to consider conducting a health impact
assessment that seeks to balance the health
impacts of planning project alternatives, for
example changes of transportation on air
pollution and health risks. Information about
health impact assessments can be found on the
Resources page of the guidelines website.
(www.epa.gov/schools/siting/resources.htmlttLI
NKS_health_impact_assesments)
By completing an assessment for proposed or
existing school locations and comparing them,
LEAs may find that one location is clearly
preferable to others with regard to biking and
walking potential and/or health impacts. LEAs
should take the results of such assessments into
consideration when selecting school locations or
deciding whether to move from an existing
location. If there is only one candidate location, it
is still recommended that an assessment of
walkability/bikeability be conducted.
If walking routes for a location are unsatisfactory,
the school district should consider another
location or work with the city or county to have
safe walking routes installed before opening the
school. New or renovated schools can act as an
impetus for retrofitting or repairing sidewalk and
bike trail networks in existing communities. Some
localities may use different metrics and rules for
determining walking/biking boundaries, and
some may prioritize completion or repair of
sidewalks and trail networks near school
locations. Streets within realistic walking or
biking distance of the location should include clear
pedestrian pathways, bicycle routes, and speed
control measures (e.g., traffic calming, design
speeds).
Environmental Siting Criteria Considerations
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Commonly accepted maximum walking/biking
distances are:
Elementary schools: y2-mile radius around
school;
Middle schools: 1-mile radius around school;
and
High schools: iy2-mile radius around school.
The example in Exhibit 3, adapted from the
"Active School Neighborhood Checklist" created
by the Arizona Department of Transportation
(www.adotenhancement.com/SafeRoutes/PDF/D
ocuments_Active_School_Neighborhood_Checklist.
pdf), shows a middle school enrollment area that
exceeds one mile in radius and creates a
prohibitively long walking/biking trip for students
who live in the shaded areas.
4.3.4. Plan for and Develop Safe Routes to
School Programs that Can Support
Alternative Modes of Transportation
A growing number of communities are
implementing measures to improve the safety of
walking and biking to school. Many schools
participate in a program funded by the U.S.
Department of Transportation (DOT) called Safe
Routes to School (www.nhtsa.gov/People/
Injury/Pedbimot/Bike/Safe-Routes-2004/Index),
which encourages both infrastructure
improvements and education programs to help
more children safely walk or bike to and from
school. In addition to the federally funded
program, many schools offer similar programs
(also called safe passages or walk to school
programs) that facilitate and encourage safe
walking and biking to school. These programs
often educate community members, families,
students, administrators, faculty and staff on the
benefits of walking and biking to school and on
approaches to make walking and biking to school
a safe alternative. Related efforts include
improvements to existing infrastructure that
Exhibit 3: Example Enrollment Area that Creates a Prohibitively Long Walking/Biking
Trip for Some Students
11/2 miles
'<- (High schools)
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make routes to school safer and more convenient
for walking and biking. More information about
Safe Routes to Schools Programs can be found on
the Resources page of the guidelines website.
(www.epa.gov/schools/siting/resources.htmlttLI
NKS_Community_planning)
When planning for a new school location, the LEA
and the SSC should consider ensuring that safe
routes to school exist for children to bike and
walk. In addition, transit connections near walking
and biking routes may facilitate their use outside
of the immediate school neighborhood. Factors
related to walking and biking that should be
considered include:
The likelihood that bike lanes and paths,
adequate sidewalks and crosswalks will
be developed;
Access to building entrances for pedestrians
and bikers without crossing bus zones,
parking entrances, or student drop-off and
pick-up areas;
Connectivity to transit lines for students
outside the immediate neighborhood of a
school;
Bus flow plans that ensure pedestrian and
bike safety;
Accessibility for parents, students, teachers
and staff with disabilities; and
Walking and biking routes that do not cross or
run adjacent to highways, other large
roadways and transportation facilities (e.g.,
rail lines), and other large pollution sources.
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Relevance of Childhood Obesity to School Locations
Today, nearly one in every three (or more than 23 million) children in the United States is overweight
or obese, and physical inactivity contributes to this.44 Children who carry their obesity into
adolescence have up to an 80-percent chance of developing an associated chronic disease (e.g., high
blood pressure, high cholesterol and diabetes).45 This childhood obesity epidemic is the result of the
interaction of three identified factors: genetics, behavior and environment.46 Two of these factors are
associated with an ever-decreasing amount of physical activity in the lives of our children due, in
part, to how our communities are built. For example, a lack of sidewalks, safe bike paths and parks in
neighborhoods can discourage children from walking or biking to school as well as from
participating in physical activity. While childhood obesity does not discriminate across race and
ethnicity, studies show that a disproportionate number of minority children are overweight and
obese; while 30.7 percent of white children ages 2 to 19 are considered obese or overweight, 34.9
percent of African-American children and 38 percent of Mexican-American children are considered
so.47 Physical activity is especially important for youth not only because of its immediate health and
academic benefits, but also because participation in physical activity tracks from youth into
adulthood.48 See Principle 3 (see Section 1.4.3) in the About the Guidelines section for further
discussion (see Section 1).
44 American Academy of Pediatrics Committee on Environmental Health, "The Built Environment: Designing Communities to Promote Physical
Activity in Children," Pediatrics (June 2009) 123:6. 1591-1598. Online article available at:
http://aappolicy.aappublications.Org/cgi/content/full/pediatrics:123/6/1591.
45 U.S. Department of Health and Human Services, "The Surgeon General's Call to Action to Prevent and Decrease Overweight and Obesity," U.S.
Department of Health and Human Services, Public Health Service, Office of the Surgeon General, 2001. Available at::
www.surgeongeneral.gov/topics/obesity/calltoaction/CalltoAction.pdf.
46 Ibid.
47 Cynthia L Ogden, Margaret D. Carroll and Katherine M. Flegal, "High Body Mass Index for Age Among U.S. Children and Adolescents, 2003-
2006," Journal of the American Medical Association, Washington, DC (May 2008) 299:20. 2401-2405.
48 R.M. Malina, Institute for the Study of Youth Sports, Michigan State University, "Tracking of physical activity and physical fitness across the
lifespan," Research Quarterly for Exercise and Sport (September 1996) 67(Suppl 3). 548-57. Available at: www.ncbi.nlm.nih.gov/pubmed/8902908.
Environmental Siting Criteria Considerations
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4.3.5. Consider the Potential Use of the
School as an Emergency Shelter
Although schools are built with a primary mission
of providing education services to youth, schools
can, and often do, serve multiple purposes for
their communities. Schools located and designed
to withstand natural disasters and terrorist
attacks not only protect students, faculty and staff
from harm, but can also serve as emergency
shelters in the immediate aftermath of a disaster,
particularly when proper emergency
preparedness plans are coordinated among school
officials, local emergency management authorities
and voluntary relief organizations (such as the
American Red Cross). In some jurisdictions, it may
be required or encouraged for certain school
facilities to be designed or available to serve as an
emergency shelter for the community.
For some communities, schools may be the best
suited structure to serve as a post-disaster shelter.
Schools frequently contain gymnasiums or other
large multipurpose spaces that can shelter large
numbers of residents and frequently have food
preparation and storage capacity. Further, school
building locations tend to be well-known among
residents and sited within the communities they
serve. Because schools are public property, the
financial costs of using school facilities
temporarily are often minimal. Thus, choosing a
school location that is central to the community
and easily accessible to residents can aid in
disaster preparedness, planning and recovery.
The Federal Emergency Management Agency, the
Department of Health and Human Services, the
Red Cross and other governmental and non-
governmental entities have translated the lessons
learned from Hurricane Katrina and subsequent
disasters into better planning and operational
considerations for both emergency and longer
term community shelters. Links to these resources
are available in the emergency planning section of
the Resources page of the guidelines website.
(www.epa.gov/schools/siting/resources.htmlWLI
NKS_emergency_planning_and_response)
4.3.6. Summary
Exhibit 4: Desirable Attributes of Candidate
Locations is intended to summarize some of the
important attributes for communities to consider
in identifying candidate sites for school.
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Exhibit 4: Desirable Attributes of Candidate Locations
Feature Description Distance Recommendation Potential Benefit
No
unacceptable
environmental
or public
health risks
Community
facilities
Poses the least
potential for exposure
and risks to children
and staff from
pollutants in air, soil
and water
Nearby community
facilities, parks, public
pools, etc.
Site-
specific
Vi mile
Conduct thorough and
transparent
environmental review of
environmental risks
Locate school such that
neighborhood resources
are within walking/biking
distance of schools
and/or joint use is
available onsite
Reduced risks to children and staff
Avoid remediation costs
Reduced potential liability and
disruption due to environmental
issues
Ability to walk or bike to compatible
student resources
Reduced space required for parking
Less air pollution
Increased exercise
References and
Resources49
Meaningful Public
Involvement
(see Section 3)
Environmental Review
Process
(see Section 5)
Evaluating Impacts of
Nearby Sources of Air
Pollution
(see Section 6)
Quick Guide to
Environmental Issues
(see Section 8)
Community Centered
Schools Resources
Emergency Planning
Resources
Green/High
Performance School
Resources
9 Visit the Resources website for additional information (www.epa.gov/schools/siting/resources.html).
|ooips
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School Siting Guidelines
Feature
Attendance
boundary
Neighborhood
access via
street
connectivity
and
infrastructure
Sensitive land
preservation
• References and
Description Distance Recommendation Potential Benefit 49
H Resources
Area in which most
students live
Presence of sidewalks,
bike lanes, crosswalks,
transit stops, etc.
Critical habitats,
important farmland,
parks, etc.
Vi mile to
1% miles
Vi mile
Site-
specific
Locate school such that a
large portion of the
student body lives within
Vi mile (elementary) to
I1/? miles (high school) of
school
Ensure that safe routes to
and from school are
available for students
Avoid siting new schools
on or in close proximity to
existing sensitive land
uses
Ability to walk or bike to
compatible student resources
Reduced space required for
parking
Reduced bus transportation costs
• Less air pollution
Increased exercise
Ability to walk or bike to
compatible student resources
Reduced space required for
parking
Reduced bus transportation costs
• Less air pollution
Increased exercise
• Increased pedestrian and bike
safety
Preservation of critical land uses
Community Centered
Schools Resources
Community Centered
Schools Resources
Green/High
Performance School
Resources
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Feature
Renewable
energy
Public water
and sewer
Other
infrastructure
• References and
Description Distance Recommendation Potential Benefit 49
H Resources
Potential to use
alternative energy
sources such as
geothermal heat
pumps, solar or wind
Ability to tap into the
public water supply and
sanitary services; review
the county sewer and
water plan for
boundary areas
Presence or absence of
adequate roads,
adequate traffic lights
and telecommunication
infrastructure
Site-
specific
Site-
specific
Site-
specific
Make use of renewable
natural resources for
energy generation
If your school has to drill a
well and become its own
water source, it is a Public
Water System and subject
to the regulations of the
Safe Drinking Water Act.
If your school is on a
septic system, you will
need to determine if the
soils are suitable
according to tribal, state,
municipal and/or county
regulations.
Take advantage of
previous investments in
infrastructure
Contributes to green energy and
sustainability
Little maintenance or upkeep
No added regulatory or technical
expertise needed to maintain a
water and septic system
Less costly to have municipal
services
Avoided or reduced costs of
building or extending
infrastructure
Energy
Efficiency/Renewable
Energy Resources
Green/High
Performance School
Resources
Water
Community Centered
Schools Resources
o
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4.4. Consider Environmental
Hazards
The primary purpose of establishing
environmental criteria for school siting is to guide
the screening and evaluation of candidate school
locations for natural, safety and environmental
hazards to identify the location that poses the
least potential health and safety risk to students
and staff and financial risk to the community.
While the typical steps and procedures that
should be included in an effective environmental
review are described in the Environmental
Review Process section (see Section 5), this
section describes some principles used to define
environmental criteria and the typical
environmental and safety issues that the school
siting process should consider and address to
ensure that the location chosen does not pose
unacceptable environmental and public health
risks. EPA strongly recommends identifying
and evaluating hazards associated with a
location prior to taking title or ownership of
that property, or in the case of leased space,
prior to executing the lease.
4.4.1. Potential Onsite Hazards
Current or prior site uses
A large number of properties in the United States
have been contaminated by past uses or naturally
occurring hazards, such as high levels of arsenic in
ground water or radon in rock formations. Some
of these properties fall under the oversight of EPA,
in which case EPA works together with state,
tribal and local authorities to assess and
remediate the site. Other known contaminated
properties may be under the jurisdiction of the
Department of Defense, the Department of Energy
or other federal land managers, such as the
Bureau of Land Management or the Bureau of
Indian Affairs in the Department of Interior, while
others may be dealt with directly by state, tribal
and local authorities. There is also an unknown
number of sites that may be contaminated but
have not yet been identified by federal, state, local
or tribal authorities.
Applicability of the Guidelines
The school siting guidelines are NOT
designed for retroactive application to
previous school siting decisions. They are
designed to inform and improve the
school siting decision-making process
from this point forward. In developing
these guidelines, EPA seeks to strengthen
information exchange and cooperation
between LEAs, state and tribal education
agencies and their environmental
counterparts to better serve school
children, parents, staff and their
communities in providing safe school
environments.
EPA recommends that districts
periodically inspect existing schools for
potential environmental health and safety
risks using tools designed for that
purpose such as EPA's Healthy School
Environments Assessment Tool
(HealthySEAT; www.epa.gov/schools/
healthyseat/) or the NIOSH Safety
Checklist Program for Schools.
(www.cdc.gov/niosh/docs/2004-101/)
Where deficiencies are found, steps to
reduce student and staff exposure to
potential hazards should be identified
and implemented (see Section 9.13).
Documentation of contaminated sites can be
housed in many different locations (e.g., federal or
state environmental regulatory agency, local
health or planning department, private property
owner). This can make it difficult to find a
complete record of the contamination history at
the site. Efforts are underway to consolidate these
different information sources through geospatial
and Internet accessible methods. Currently
members of the public can use EPA's
MyEnvironment search application
(www.epa.gov/myenvironment) to find a cross
section of environmental information based on
location. Additionally, members of the public can
contribute to the information collection effort
through their own recollections as neighbors or
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employees. The public should be engaged to help
establish historical uses of potential school sites
and adjacent sites and to assess the likelihood and
possible presence of contamination. Because these
groups may also have frequent contact with the
site, they can significantly contribute to efforts to
ensure compliance with site use restrictions as
part of long-term site management plans. The
Meaningful Public Involvement section provides
more information on engaging the public in the
school siting process (see Section 3).
Existing structures
While there are economic, social and
environmental benefits to renovating/reusing an
existing structure for a school, it is important for
the LEA and the SSC to be aware that a number of
products used historically in building construction
(e.g., asbestos, lead, PCBs) are now recognized to
be potentially hazardous to the health of children
and adults in certain situations, such as when
disturbed or managed unsafely by improperly
trained staff or contractors. LEAs considering
renovating existing schools or structures for
school use or adapting other existing structures
for educational purposes should weigh the
hazards and the costs of the safe removal or
management of these hazardous materials
compared to the steps and costs associated with
evaluating and acquiring sites to construct new
school facilities. Links to more information on
considerations related to existing buildings are
provided in the Resources page of the guidelines
website.
(www.epa.gov/schools/siting/resources.htmlttLI
NKS_maps_and_mapping)
Natural hazards
The potential for natural hazards should be
explored in decisions to renovate existing schools,
as well as all potential new school locations. The
natural hazards may be common or unique to the
area and may include the site's geology (naturally
occurring hazards such as elevated levels of radon,
arsenic or other naturally occurring toxic
materials), areas of seismic activity, flooding or
frequent wildfires, or areas prone to extreme
weather events. Additional consideration may
need to be given to natural hazards where school
facilities are also planned or renovated to serve as
temporary or longer term emergency shelters.
Links to more information on natural hazards are
provided in the Resources page of the guidelines
website, (www.epa.gov/schools/siting/
resources.html#LINKS_natural_hazards)
4.4.2. Potential Nearby Hazards
There is a wide range of potential environmental
and safety hazards that may be located in close
proximity to a prospective school location. The
offsite hazards may change over time as areas are
developed for industrial, transportation or other
new uses; existing facilities change production
processes, activity or configuration; or unforeseen
events, such as spills, occur. Identifying, evaluating
and planning for potential hazards from nearby
sources is a critical component of successful
school siting. Characterizing potential risks from
nearby hazards is challenging because of the wide
range of variables that influence whether there is
an actual exposure to a potential hazard that may
pose a risk. Additional factors to consider are
whether physical, engineering or other controls
can reduce or remove exposures, thus reducing
risk, if such measures are properly maintained.
Exhibit 5: Factors Influencing Exposures and
Potential Risks, presents some of the
environmental hazards that may be on or located
near candidate sites, the variables that influence
the potential for exposure and risk, and mitigation
options for each hazard. In some cases, the
mitigation options differ if there will be a new
school facility constructed (N) or if there is an
existing structure that is being renovated (E).
These differences are designated in the table.
Environmental Siting Criteria Considerations
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Exhibit 5: Factors Influencing Exposures and Potential Risks
Potential
Hazard
Air Pollution
(see Section 8.1)
Potential
Variables
Potential Mitigation Options
N=New schools
E=Existing structure
Type and volume of contaminant
released
Distance from the source
Nearby traffic type, fuel, volume and
speed (mobile sources)
Stack height, facility practices and type
of pollution control employed
(stationary/point sources)
Timing of operations (stationary/point
sources)
Meteorological conditions (e.g.,
prevailing wind direction and wind
speed)
Atmospheric stability and mixing
Regulatory compliance
Intensity of use
Presence of natural or man-made
buffers (e.g., trees, hills, buildings)
Planning and zoning
Adopt an area-wide approach to
address air pollution issues (N/E)
Maximize distance from
transportation or other pollution
sources(N)
Vegetation buffers (N/E)
Anti-idling policies (N/E)
Limiting bus or personal car use on
and near campus
(N/E)
Enhanced indoor filtration/air
cleaning (N/E)
Locating sensitive activities and
outside air intakes away from
sources (e.g., locate playgrounds
and classrooms away from source;
place parking lots, utilities closer)
(N/E)
Timing of HVAC system operations
(N/E) or industry operating periods
(N/E)
Limiting outdoor activities during
high exposure periods (N/E)
Soil
Contamination
Type of contamination
Extent of contamination
Concentration of contamination
Depth of contamination
Potential transport (e.g., runoff or
migration to ground water, air
transport)
Geology and soil characteristics
Water table
Access or exposure potential (e.g.,
dermal contact/ingestion)
Barriers (e.g., plants, grass, ground
cover, pavement)
Site cleanup and removal (N/E)
Onsite treatment (N/E)
Engineering controls (e.g., cap,
venting systems, vapor barriers)
(N/E)
Institutional controls (N/E)
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Potential
Hazard
Use of Agricultural
Pesticides
(see Section 8.12)
Potential
Variables
Use pattern (application rate, crop type)
Environmental conditions (wind,
temperature, etc.)
Toxicity of the pesticide
Volatility
Persistence
Potential Mitigation Options
N=New schools
E= Existing structure
Application of Integrated Pest
Management measures to reduce
pesticide use (N/E)
Choice of pesticide active
ingredients (N/ )
Oversight and strict enforcement of
product label use directions and
drift restrictions (N/E)50
Use of drift reducing application
technologies and best management
practices (N/E)
Enhanced indoor filtration/air
cleaning (N/E)
Locating sensitive activities and
outside air intakes away from
sources (e.g., locate playgrounds
and classrooms away from source;
place parking lots, utilities closer)
(N/E)
Timing of HVAC system operations
(N/E)
Limit opening of classroom doors
and windows during periods of
potential spray drift (E)
Limiting outdoor activities during
high potential exposure periods ( )
Notification when pesticides are
applied (N/E)
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50 Buffer zones are specified on all pesticide product labels. The buffer zones provide flexibility based on several factors such as
application rate, field size, application method, and soil characterization.
Environmental Siting Criteria Considerations
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Potential
Hazard
Ground Water
Contamination
Surface Water
Pollution
Safety Hazards
Noise
(www.epa.gov/
schools/siting/
resources.html#
LINKS_noise)
Odors
Potential
Variables
Type of contaminant(s)
Type and frequency of contact with
contaminated water
Type of contact with contaminated
water/route of exposure (e.g., ingestion)
Extent of contamination
Concentration of contaminants
Extent of vapor intrusion (for certain
contaminants)
Type of contaminant(s)
Type and frequency of contact with
contaminated water/route of exposure
(e.g., dermal)
Extent of contamination
Concentration of contaminants
Stormwater runoff
Frequency
Intensity of hazard (e.g., explosion vs.
flooding)
Distance
Timing and intensity of source
Presence of natural or man-made
buffers (e.g., hills, noise barriers)
Timing of operations
Meteorological conditions (e.g.,
prevailing wind direction and wind
speed)
Potential Mitigation Options
N=New schools
E=Existing structure
Seek alternative drinking
water sources or install
water treatment systems
(N/E)
Restrict access to water
bodies (N/ )
Phytoremediation (N/E)
Mitigation system for vapor
intrusion (N)
Improve riparian buffers
(N/E)
Restrict access to water
bodies (N/ )
Green roof, rain gardens
and barrels (N/ )
Emergency response plans
(N/E)
Emergency shelter design
incorporated (N)
Active noise control (N/ )
Install or preserve noise
barriers (e.g., highway
barriers or other noise
buffers) (N/E)
Locating sensitive activities
and outside air intakes
away from sources (e.g.,
locate playgrounds and
classrooms away from
source; place parking lots,
utilities closer) (N/E)
Enhanced indoor
filtration/air cleaning (N/E)
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4.4.3. Screening Locations for Potential
Environmental Hazards
The initial screening process of identifying and
narrowing potential school location choices takes
into account a wide range of school siting
considerations and challenges. Among the most
important of these is to identify potential
environmental and public health concerns as early
in the process as possible to fully understand the
potential costs and benefits of candidate locations
before deciding to pursue a particular site.
Unanticipated environmental issues can be
extremely costly in terms of cleanup costs, time
delays, community concern and potential loss of
support for siting choices. A full understanding of
the potential risks of candidate sites to ensure that
a prospective school site does not pose
unacceptable health and safety risks to students
and staff is very important but can be costly and
time-consuming. For this reason, it may be
desirable to try to avoid sites that have onsite
contamination or are in very close proximity to
pollution generating land uses at the initial stage
of identifying candidate sites if other acceptable
locations exist in the community that may pose
fewer environmental challenges.
Exhibit 6: Screening Potential Environmental,
Public Health and Safety Hazards, below, contains
a list of potential environmental and safety
hazards that should be identified, evaluated and
weighed, along with other factors, in choosing a
school location. In general, the closer a potential
hazard is to a candidate location for a school, the
more important it is to gain an early
understanding of the potential risks that may be
associated with that hazard. Exhibit 6 is intended
to be used in conjunction with the example
Environmental Review Process (see Section 5)
and with Evaluating Impacts of Nearby Sources of
Air Pollution (see Section 6).
Screening perimeters can help the LEA and SSC
quickly identify activities or features on or in the
area surrounding a prospective school location
that have the potential to pose a hazard to
students and staff and warrant further evaluation.
These include a wide range of potential ongoing
sources of air, water and land contamination as well
as features or activities that may pose safety risks
from accidental releases. For potential school
locations identified within the "screening perimeter"
of an environmental feature, further study is
warranted to ensure that the potential risks
associated with that feature are not significant.
Screening perimeters are intended to facilitate:
• Rapid identification of land uses near candidate
school locations that could potentially pose
health and safety hazards to students and staff;
• Consultation with appropriate state, tribal, local
and other authorities, local stakeholders and
the public to assist with the evaluation; and
Consideration of appropriate mitigation or
separation strategies to reduce potential risks
within the context of the broader school siting
decision-making process.
Determining screening distances for various
hazards is, to a large degree, a matter of best
professional judgment. Several jurisdictions have
adopted screening distances based primarily on
existing state or local rules, law, ordinance, policy
or guidance. Links to this information are
provided on the Resources page of the guidelines
website (www.epa.gov/schools/siting/
resources). In the following table, EPA has
included recommended screening distances based
on existing approaches at the state and local level
as approximate distances within which EPA
recommends that potential hazards should be
identified and considered for additional study.
NOTE: Screening distances are intended to
identify potential land uses near candidate school
locations that warrant further consideration
rather than to identify land uses that may be
incompatible with the location of schools.
Screening distances, alone, may not be predictive
of the actual potential for a source located within
that distance to present an environmental or
health hazard. Potential hazards associated with
candidate school locations should be evaluated as
part of the site screening and evaluation process.
Environmental Siting Criteria Considerations
-------
School Siting Guidelines
Exhibit 6: Screening Potential Environmental, Public Health and Safety Hazards
IMPORTANT: This table is intended to assist with the initial screening of candidate locations but is NOT a substitute for case- and site-specific
evaluation of potential risks and hazards. It is intended to be used in conjunction with the example Environmental Review Process (see Section 5) and
Evaluating Impacts of Nearby Sources of Air Pollution (see Section 6). For more information on typical environmental hazards that may be encountered
during the school siting process, see the Quick Guide to Environmental Issues in Section 8). Existing applicable federal, state, tribal or local statutes,
ordinances, codes or regulations take precedence over the recommendations contained in this table. Users should check with state, tribal and local
authorities for applicable requirements or other recommendations.
Feature/Land
Use
Onsite buildings
or structures
(including all
leased space)
Desman
Potential Hazard(s)
Recommendations
JLI witiity rei iineiei zvuiuuiiuit
All onsite or adjacent
buildings/structures
slated for reuse,
renovation or
demolition.
Legacy contaminants
in existing structures
including lead and
other heavy metals,
asbestos, PCBs, vapor
intrusion/(VOCs),
mold, radon,
pesticides, pests
• For existing school
buildings, chemicals
from laboratory, art,
shop, drama,
maintenance,
cleaning, grounds
• Structure may not
meet current building
codes (e.g., for
seismic activity)
All onsite structures slated
for demolition, reuse or
renovation
Evaluate for the
presence of hazardous
materials or conditions.
Age, location, condition
and type of structure,
and the history of use
are critical factors to
consider in assessing
potential risks. Identify
all potential hazards and
remediate as
appropriate.
1 Additional
Information51
• Lead
• Heavy Metals
• Asbestos
• PCBs
• Vapor Intrusion/
(VOCs)
• Mold
• Radon
• Mercury
• Pesticides
• Air Pollution
• Risk Assessment
51 See the Resources page of the guidelines website for links related to the topics listed under the 'Additional Information.' (www.epa.gov/schools/siting/resources)
-------
Recommendations AHHitinnnl ^^1
Feature/Land Use Description Potential Hazard(s)
Contaminated
sites (formerly or
currently
regulated under
Superfund, RCRA
hazardous waste
sites, state-
regulated
hazardous waste
sites, or
unremediated
sites under
federal, tribal or
state orders or
agreements for
cleanup)
Properties that have or
are managing
hazardous waste
onsite, or have had
releases of hazardous
waste in the past, and
are under federal
(CERCLA, RCRA Subtitle
C), tribal or state
regulation.
Air pollution
• Dust
Soil contamination
Ground water
contamination
Vapor intrusion into
structures
• Surface water
contamination
Odors
• Accidental
release/spill of
hazardous chemicals
Screening Perimeter Evaluation
Identify and evaluate all
facilities within~l mile of
prospective locations
Applies to both onsite as well
as adjacent or nearby sites
Evaluate on a case- and
site-specific basis. See
Exhibit 5 for potential
variables and mitigation
options.
Regulating agencies should
be consulted to obtain
environmental status of the
site, if it has been assessed.
The site may have had
contamination removed or
addressed, and be safe for
use, or the site may still
need additional cleanup.
The site should not be used
for a school unless
regulating agencies can
confirm that the potential
for unsafe human
exposures has been
prevented.
Informal •
» Air Pollution
• Risk Assessment
• Maps and
Mapping
• Vapor Intrusion/
(VOCs)
Heavy Metals in
Soil and Ground
Water
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Recommendations
Feature/Land Use Description Potential Hazard(s)
Solid waste
landfills and
transfer stations
Properties that have or
are managing non-
hazardous solid waste.
Air pollution
Soil contamination
Ground water
contamination
Vapor intrusion into
structures
• Surface water
contamination
Odors
Pests and disease
vectors
Diesel emissions and
heavy truck traffic
Fires
Screening Perimeter Evaluation
Identify and evaluate all
facilities within ~1 mile of
prospective locations
Applies to both onsite as well
as adjacent or nearby sites
Evaluate on a case- and
site-specific basis. See
Exhibit 5 for potential
variables and mitigation
options.
Regulating agencies
should be consulted to
obtain environmental
status of the site, if it has
been assessed. The site
may have had
contamination removed
or addressed, and be safe
for use, or the site may
still need additional
cleanup. The site should
not be used for a school
unless regulating agencies
can confirm that the
potential for unsafe
human exposures has
been prevented.
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• Heavy Metals in
Soil and Ground
Water
• Vapor Intrusion/
(VOCs)
• Risk Assessment
• Maps and
Mapping
• Water
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Recommendations
Feature/Land Use Description Potential Hazard(s)
Screening Perimeter Evaluation
Formerly Used
Defense Sites
(FUDS)
Properties formerly
owned, leased,
possessed or used by
the Department of
Defense (DOD) or its
components that were
transferred from DOD
control prior to the
enactment of the
Superfund
Amendments and
Reauthorization Act
(SARA). The FUDS
program
communicates with
regulatory agencies,
tribes and the public to
ensure proper
characterization and
cleanup of past DOD
lands.
Unexploded
ordnance (FUDS)
Discarded military
munitions
Munitions
constituents
Surface water
contamination
• Ground water
contamination
Legacy contaminants
in existing structures
including lead and
other heavy metals,
asbestos, PCBs, vapor
intrusion/(VOCs),
mold, radon,
pesticides, pests
Identify and evaluate all
facilities within ~1 mile of
prospective locations
Applies to both onsite as well
as adjacent or nearby sites
Consult with state, tribal
and local authorities to
identify sites.
1 Additional
Information51
• Formerly Used
Defense Sites
• Maps and
Mapping
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School Siting Guidelines
Recommendations
Feature/Land Use
High-traffic
roads and
highways
Distribution
centers, bus
terminals, bus
garages and
truck-stops
Description roteniiai nazara(S)
High-traffic roads or
roads with heavy diesel
truck traffic.
Facilities with more
than 100 trucks/buses
per day, or more than
40 refrigerated trucks
per day.
Air pollution
Noise
• Accidental
releases/spills of
hazardous chemicals
• Pedestrian and bike
safety
Air pollution,
including diesel
emissions
Soil contamination
• Ground water
contamination
• Surface water
contamination
Vapor intrusion
• Heavy truck or bus
traffic
Screening Perimeter
Identify and evaluate all high-
traffic roads and highways
within ~V2 mile
Roads farther away with a
high likelihood of accidental
releases should also be
considered
Identify and evaluate all major
distribution centers within ~V2
mile
Centers farther away with a
high likelihood of accidental
releases should also be
considered
Evaluation
In general, air pollutant
concentrations will be
highest closer to the
source, decreasing with
distance from the road.
Many factors affect the
magnitude and extent of
impacts, so the potential
variables and mitigation
options described in
Exhibit 5 should be
evaluated. Consider
additional mitigation
strategies for locations
near high-traffic roads.
Also, consider potential
adverse consequences
related to inability of
students to walk/bike to
school, etc.
Evaluate on a case- and
site-specific basis. See
Exhibit 5 for potential
variables and mitigation
options.
(Additional
Information51
• Roads
• Air Pollution
• Noise
• Risk Assessment
• Water
• Risk Assessment
• Maps and
Mapping
• Vapor Intrusion/
(VOCs)
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Recommendations AHHitinnnl
Feature/Land Use Description Potential Hazard(s)
Large industrial
facilities
Other large
sources
Fossil fuel power plants
(more than 50 MW),
incinerators, refineries,
chemical/
pharmaceutical/rubber
and plastics plants,
cement kilns, metal
foundries and smelters,
other large industrial
facilities.
Metal platers
(especially chrome),
rendering plants,
sewage treatment
plants, composting
operations, fertilizer or
cement plants, large
manufacturing
facilities.
Air pollution
Soil contamination
Ground water
contamination
Surface water
contamination
Accidental
releases/spills of
hazardous chemicals
Odors
Heavy vehicular traffic
Air pollution
Soil contamination
• Ground water
contamination
Surface water
contamination
Accidental
releases/spills of
hazardous chemicals
Odors
Screening Perimeter Evaluation
Identify and evaluate all large
industrial facilities within ~V2
mile
Identify and evaluate all other
large sources within ~V2 mile
Evaluate on a case- and
site-specific basis. See
Exhibit 5 for potential
variables and mitigation
options.
Consult with local air
quality agencies to
determine sites with high
concentrations nearby.
Evaluate on a case- and
site-specific basis. See
Exhibit 5 for potential
variables and mitigation
options.
Consult with local air
quality agencies to
determine appropriate
separation.
Information51
» Air Pollution
• Risk Assessment
• Maps and
Mapping
• Vapor Intrusion/
(VOCs)
Water
• Air Pollution
• Risk Assessment
• Maps and
Mapping
• Vapor Intrusion/
(VOCs)
Water
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School Siting Guidelines
Recommendations
Feature/Land Use
Gas stations and
other fuel
dispensing
facilities
Dry cleaners
Description roteniiai nazarci(S)
Large gas station
dispense more than 3.6
million gallons per
year.
Facilities using
perchloroethylene or
similarly toxic
chemicals.
Air pollution
Soil contamination
• Ground water
contamination
Vapor intrusion into
structures
Heavy vehicular traffic
J
Air pollution
Soil contamination
• Ground water
contamination
Vapor intrusion into
structures
Screening Perimeter
Identify and evaluate gas
stations and other fuel
dispensing facilities within
-1,000 feet of prospective
school locations
Applies to both onsite as well
as adjacent or nearby
locations
Identify and evaluate dry
cleaning operations within
-1,000 feet of prospective
school locations
Applies to both onsite as well
as adjacent or nearby
locations
Evaluation
Evaluate on a case- and
site-specific basis. See
Exhibit 5 for potential
variables and mitigation
options.
Consult with state, tribal
and local authorities for
applicable requirements.
Evaluate for spills, leaking
underground storage
tanks, potential air
emissions.
Evaluate on a case- and
site-specific basis. See
Exhibit 5 for potential
variables and mitigation
options.
Consult with state, tribal
and local authorities for
applicable requirements.
Consult with local
environmental agencies to
determine locations with
high concentrations.
(Additional
Information51
• Air Pollution
• Risk Assessment
• Maps and
Mapping
« Underground
Storage Tanks
• Vapor Intrusion/
(VOCs)
- Air Pollution
• Risk Assessment
• Maps and
Mapping
• Vapor Intrusion/
(VOCs)
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Recommendations
Feature/Land Use
Other area/small
sources
Large agricultural
growing
operations
Large
concentrated
animal feeding
operations
Description roteniiai nazarci(S)
Auto body shops,
furniture
manufacturing and
repair; wood product
manufacturing or
processing; printing,
electronics and chip
manufacturing;
charbroilers,
commercial
sterilization, back-up
generators; small
neighborhood metal
platers
Operations employing
aerial pesticide
spraying
Animal feeding
operations
Air pollution
Soil contamination
Ground water
contamination
Surface water
contamination
Odors
Vapor intrusion into
structures
Air pollution (from
volatilization and
drift)
• Soil contamination
• Ground water
contamination
• Surface water
contamination
Air pollution
• Soil contamination
• Ground water
contamination
• Surface water
contamination
Odors
Screening Perimeter
Identify and evaluate other
small sources within -1,000
feet of prospective school
locations
Applies to both onsite as well
as adjacent or nearby
locations
Identify and evaluate all large
agricultural growing
operations within ~3 miles
Identify and evaluate all
animal feeding operations
within -1-3 miles
Evaluation
Evaluate on a case- and
site-specific basis. See
Exhibit 5 for potential
variables and mitigation
options.
Consult with local health
and/or environmental
agencies to determine
locations with high
concentrations.
Evaluate on a case- and
site-specific basis. See
Exhibit 5 for potential
variables and mitigation
options.
Evaluate on a case- and
site-specific basis. See
Exhibit 5 for potential
variables and mitigation
options.
Consult with local health
and/or environmental
agencies to determine
locations with high
concentrations.
(Additional
Information51
• Air Pollution
• Risk Assessment
• Maps and
Mapping
« Air Pollution
• Risk Assessment
• Maps and
Mapping
• Water
• Concentrated
Animal Feeding
Operations
• Air Pollution
• Risk Assessment
• Maps and
Mapping
• Water
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School Siting Guidelines
Recommendations
Feature/Land Use
Ports
Rail yards,
intermodal
freight terminals
and major rail
lines
Description roteniiai nazara(S)
Marine ports with more
than 100 truck
visits/day
• A major service and
maintenance rail yard;
Rail lines serving more
than 50 trains/day
(excluding electric light
rail, except for safety)
Air pollution
Noise
• Soil contamination
• Surface water
contamination
Heavy vehicular traffic
Accidental
releases/spills of
hazardous chemicals
Air pollution
Noise
Odors
Soil contamination
Ground water
contamination
Vapor intrusion into
structures
• Accidental
releases/spills of
hazardous chemicals
Fire/explosions
Safety
Large truck traffic
Screening Perimeter
Identify and evaluate all
port facilities within ~1 mile
Ports farther away with a
high likelihood of accidental
releases should also be
considered
Identify and evaluate all
major rail yards, intermodal
freight terminals and rail
lines within ~1 mile
Rail facilities farther away
with a high likelihood of
accidental releases should
also be considered
Evaluation
Evaluate on a case- and site-
specific basis. See Exhibit 5
for potential variables and
mitigation options.
Evaluate on a case- and site-
specific basis. See Exhibit 5
for potential variables and
mitigation options.
Consult with local air quality
agencies to determine
locations with high
concentrations.
Consider additional
mitigation approaches.
(Additional
Information51
• Air Pollution
• Noise
• Risk Assessment
• Maps and
Mapping
• Vapor Intrusion/
(VOCs)
• Air Pollution
• Noise
• Risk Assessment
• Maps and
Mapping
• Vapor Intrusion/
(VOCs)
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Recommendations
Feature/Land Use Description Potential Hazard(s)
Rail lines
Airports and
heliports
All rail lines (excluding
electric light rail)
All commercial and
military airports,
consider flight
patterns/runway
configuration
Air pollution
Noise
Odors
• Soil contamination
• Ground water
contamination
Physical hazards due
to derailment
Hazardous cargo
spills
Train road crossings
and access to rail
tracks
Safety concerns near
runways
Noise
Air pollution
Screening Perimeter Evaluation
Identify and evaluate all rail
lines within -1/2 mile
• Rail lines farther away with a
high likelihood of accidental
releases should also be
considered
Identify and evaluate all
locations within -2 miles
from runways
Evaluate on a case- and site-
specific basis. Evaluate
safety based on cargo,
speed, traffic, etc. See
Potential Variables under
Exhibit 5.
Consult with local air quality
agencies to determine
locations with high
concentrations.
Consider additional
mitigation approaches.
Evaluate on a case- and site-
specific basis. See Exhibit 5
for potential variables and
mitigation options.
Consult with state, tribal and
local authorities for
applicable requirements.
Consult with local air quality
agencies to determine
locations with high
concentrations.
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• Rail Yards and
Rail Lines
• Maps and
Mapping
• Noise
• Airports
• Maps and
Mapping
• Noise
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School Siting Guidelines
Recommendations
Feature/Land Use Description Potential Hazard(s)
Power lines
Cellular phone
towers
Hazardous
material
pipelines
High voltage power
lines more than 50 kV.
All cellular phone
towers and antennas.
Oil pipelines, high
pressure natural gas
pipelines, chemical
pipelines, high pressure
water lines.
Exposure to
electromagnetic fields
Safety concerns if
power lines fall
Exposure to
electromagnetic fields
Fall distance of
towers
Soil contamination
Ground water
contamination
Accidental
release/spills of
hazardous materials
• Fire/heat from
flammable fuels
Flooding/erosion
from water
Explosion hazard
Screening Perimeter Evaluation
Identify and evaluate all
high voltage power lines
within -500 feet of
prospective school locations
Applies to both onsite as
well as adjacent or nearby
locations
Identify and evaluate cell
towers within -200 feet of
prospective school locations
Applies to both onsite as
well as adjacent or nearby
locations
Identify and evaluate
hazardous material
pipelines within -1,500 feet
of prospective school
locations
Applies to both onsite as
well as adjacent or nearby
locations
Consult with state, tribal
and/or local authorities for
requirements.
Variable, depending on
voltage and if lines are
above ground or below
ground.
Review and apply Federal
Communications
Commission regulatory
guidance.
No hazardous pipelines on
site (except natural gas
serving school).
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• Electromagnetic
Fields
• Electromagnetic
Fields
• Pipelines
• Maps and
Mapping
• Water
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Recommendations
Feature/Land Use
Reservoirs, water
or fuel storage
tanks
Geologic features
Description roteniiai nazarci(S)
All aboveground large
volume liquid storage
tanks
Earthquake faults,
liquefaction zones,
volcanic/geothermal
activity, landslide/lahar
zones, flood zones,
methane zones,
naturally occurring
hazardous materials
(examples: asbestos,
uranium, radon) areas,
etc., reservoirs, high
water table
Potential for
inundation in an
accident
• Surface water
contamination
• Ground water
contamination
Vapor intrusion into
structures
Air pollution
Natural hazards
Air pollution
Soil contamination
Surface water
contamination
Ground water
contamination
Dust
Moisture intrusion
Screening Perimeter
Identify and evaluate
reservoirs, water or fuel
storage tanks within -1,500
feet of prospective school
locations
Applies to both onsite as
well as adjacent or nearby
locations
Identify and evaluate
potential geologic hazards
within ~Vi mile of
prospective school locations
Applies to both onsite as
well as adjacent or nearby
locations
Evaluation
Evaluate drainage direction
and emergency planning
options.
Evaluate geologic/
geotechnical hazards for
every location.
(Additional
Information51
* Aboveground
Storage Tanks
• Maps and
Mapping
• Water
• Natural Hazards
• Maps and
Mapping
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5. Environmental
Review Process
5.1. Overview
While the decision to build a new school is
primarily focused on the educational needs of
children in the community and reflects a great
many local factors and considerations, a full
understanding of the environmental issues
associated with each candidate site is essential for
a fully informed school siting decision.
The example environmental review process
presented in this section describes a process of
evaluating candidate sites that are under serious
consideration as a location for a school. EPA
recommends that all sites under serious
consideration undergo an initial screen (see
Section 5.5) and preliminary environmental
assessment (see Section 5.6). If no environmental
concerns are found in the preliminary assessment,
no further assessment is needed. If potential
environmental concerns are found, the local
education agency (LEA) (see Section 10) should
select a different site or perform a comprehensive
environmental assessment (see Section 5.7) to
ensure that environmental concerns are identified
and remediated (i.e., cleaned up) or mitigated, as
You will see the word "site" mentioned
throughout this section, which is an
established term in the environmental
profession. Its use should not be
interpreted to reference only vacant sites
or greenfields; it includes locations (sites)
with existing buildings.
appropriate. If remediation or mitigation is
necessary to prevent exposures, site-specific
remediation/mitigation measures (see Section 5.7
and 5.8) and a long-term stewardship plan (see
Section 5.9) should be developed, reviewed by the
public and implemented.
A full understanding of the potential risks of
candidate sites to ensure that a prospective school
site does not pose unacceptable health and safety
risks to students and staff is very important but
can be costly and time-consuming. For this reason,
it may be desirable to try to avoid sites that have
onsite contamination or are in very close
proximity to pollution generating land uses at the
initial stage of identifying candidate sites if other
acceptable locations exist in the community that
may pose fewer environmental challenges.
5.2. Why Is an Effective
Environmental Review of
Prospective Candidate Sites
So Important?
Children, particularly younger children, may be
more vulnerable when exposed to contaminants
in both indoor and outdoor environments. There
are multiple pathways for potential exposures to
contaminants in air, water or soil that should be
considered during the site evaluation process.
Indoor pathways can include vapor intrusion into
structures from soil and ground water and poor
indoor air quality from infiltration of air
contaminants through windows, doors and
ventilation air intakes. Children competing in
outdoor sports or playing on school grounds could
be exposed to contaminants present in soil, water
and outdoor air on school grounds. Therefore, it is
important to determine whether a site is
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contaminated or could be impacted by
contaminants that may migrate to the site from
nearby air, land and water sources. If these
contaminants reach a level that poses a threat to
the health of children and staff, cleanup or other
mitigation actions may be required to prevent
unacceptable exposures. These contaminants may
be present due to historical and current industrial
activity, unsafe demolition practices, illegal
dumping or through material brought to a site,
such as fill, which could have resulted in soil,
ground water or surface water contamination.
EPA recommends that all properties or structures
proposed for use as a school be carefully
evaluated for potential environmental
contaminants and potential exposures of children,
staff and visitors before making final decisions to
use a site or structure for a school. The site
evaluation process should identify and evaluate all
potential safety hazards and sources of
environmental contamination that may be present
at the site or which may migrate to the site from
nearby sources.
The environmental review process for candidate
school sites is designed to answer the following
questions:
Are site surface soils, subsurface soils, soil
gases, ground water or surface water
contaminated with hazardous materials and
substances to a degree that the site should be
remediated before use or should not be used for
school purposes (i.e., onsite contamination);
Are there offsite sources of pollution,
contaminants or other environmental hazards
affecting the site such that the hazards should
be mitigated before use of the site or the
location should not be used for school purposes
(i.e., offsite environmental impacts); and
Are there environmental and public health
impacts associated with putting a school on the
site that should be mitigated or that are so
significant that the site cannot safely be used for
school purposes (i.e., impacts of the project on
the environment)?
NOTE: LEAs, as well as states and tribes (see
Section 7), are encouraged to adopt and use an
environmental review process comparable to the
process outlined in this section to the maximum
extent possible. However, EPA recognizes that
elements of the process outlined may be beyond
the current capacity of some LEAs, states, tribes
and other participants in the process to fully
implement with existing authorities, expertise and
resources. EPA encourages LEAs, states, tribes,
communities and other interested organizations
to work collaboratively with each other to identify
opportunities to leverage existing resources as
well as to identify and work toward fulfilling
needs for improving local, state and tribal capacity
to conduct a rigorous site evaluation process and
to safely operate risk reduction measures such as
lead encapsulation systems.
Existing State Requirements
Some states, such as California, Maryland,
Minnesota, New Jersey, New York and
Washington, require sponsors of new
school construction projects to assess the
environmental impact of the project as part
of a state environmental review process.
Other states have environmental review
laws including Connecticut, Georgia,
Hawaii, Indiana, Montana, North Carolina,
South Dakota, Virginia and Wisconsin. The
extent to which human health impacts are
considered in such reviews varies. More
information can be found on the Resources
page of the guidelines website.
(www.epa.gov/schools/siting/resources.ht
ml#LINKS_States)
5.2.1. The Importance of Meaningful Public
Involvement
An essential prerequisite to an effective site
review and selection process is to develop and
formalize substantive public involvement in site
selection decisions (see Section 3). LEAs should
develop a communication plan at the beginning of
the process. When draft and final reports are
available for public comment, written notice of the
Environmental Review Process
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results of the reports should be posted on the
website, sent to those identified in the
communications plan and should include:
A statement that a report has been completed;
A brief statement in plain language describing
its specific components and results;
• The location where people can review a copy of
the report or an executive summary written in
the appropriate foreign language (if applicable);
• Announcement of a public comment period that
provides a reasonable opportunity for
meaningful public involvement (typically 30 -
90 days, as determined by the circumstances,
LEA practice or recommendations of the state
or tribal environmental agency);
Instructions and addresses for submitting
public comments; and
The date, time and location of any scheduled
public meetings.
More information on the process for establishing
and maintaining meaningful public involvement
can be found in the Meaningful Public
Involvement (see Section 3).
5.3. Recommended
Environmental Review Process
The example environmental review process
presented in this section and illustrated in the
flow charts describes a transparent, thorough,
prospective process for evaluation of potential
school sites and structures. The purpose of the
process is to ensure that all potential hazards are
addressed prior to the decision to acquire land or
use a particular location or structure for a school
or other purpose where children will spend a
significant amount of time (see Section 1.1).
If no significant environmental and public health
issues are found during the initial screening stages
(Stage 1, Section 5.5 and Stage 2, Section 5.6), no
further assessment is needed. Later stages should
be used for those sites that may have
contamination issues (onsite or from nearby
sources) that must be resolved prior to use for a
school.
Ideally, the LEA should not acquire or lease any
location for school use until the appropriate
environmental review has been completed (e.g.,
Stage 2, Section 5.6, for sites with no or few
environmental issues and Stage 5, Section 5.9, for
sites with significant contamination issues). The
most resource intensive environmental reviews of
candidate school locations occur in Stages 3-5.
The following site review and selection process
recommends state and tribal environmental
regulatory approval and oversight for evaluation
of onsite contamination of candidate sites. States
and tribes (see Section 7) can also provide
technical assistance for an evaluation of offsite
environmental hazards and the potential
environmental impacts associated with placing a
school on a candidate site. However, the actual
tribal or state and local oversight relationships for
various steps in the environmental review process
may vary, with state or tribal policies mandating
greater or lesser oversight
All state and most tribal environmental regulatory
agencies (http://www.astswmo.org/Pages/
Resources/State_Agency_Links.htm) have
programs in place to evaluate and approve
cleanup plans of onsite contamination for specific
types of sites or projects. Few states currently
require sponsors of new school construction
projects to assess the environmental impact of the
project as part of a state environmental review
process. EPA encourages LEAs to seek technical
assistance on assessment from environmental
regulators in the absence of other legislative or
regulatory requirements.
State and tribal education agencies and their local
education counterparts will benefit from
involvement and technical assistance from the
state or tribal voluntary cleanup program or
brownfields response program in identifying, as-
sessing and ensuring safe school site selection in
accordance with state and federal requirements.
Potential health and environmental risks posed by
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locations near Superfund sites or facilities regu-
lated under the Resource Conservation and
Recovery Act (RCRA) can best be addressed
through
consultation with appropriate tribal, state and
federal hazardous site cleanup staff.
Special Considerations for Existing
Structures/Leased Space
EPA recommends that existing
structures/leased space be subject to a
thorough environmental review
consistent with these guidelines prior to
use as a school. Existing structures at the
site may have additional considerations
for environmental review, including, but
not limited to, the concern that a
structure may not have been built and/or
remediated to an adequate standard for
occupation by students (e.g., with respect
to the presence of toxic substances,
potential vapor intrusion, or seismic
activity) and that existing structures may
not be accessible for intrusive sampling
of onsite contamination.
5.4. Stages of Site Review
The recommended process for evaluating
candidate school sites should be performed by en-
vironmental professionals (see Section 10) and will
benefit from public involvement (see Section 3) at
multiple steps in the process. The environmental
review begins with project scoping of the candidate
site followed by a preliminary environmental
review. If no significant issues are found in the
preliminary assessment, no further assessments
are needed. If potential environmental hazards are
identified in the preliminary assessment, the
environmental review should continue to Stage 3,
which begins the more detailed or comprehensive
environmental review, or another site should be
selected. The process of environmental review
culminates in a final evaluation that responds to
comments received from the public and the
agencies providing oversight of the process.
• Stage 1 - Project Scoping/Initial Screen of
Candidate Sites (see Section 5.5)
• Stage 2 - Preliminary Environmental
Assessment (see Section 5.6)
• Stage 3 - Comprehensive Environmental
Review (see Section 5.7)
• Stage 4 - Develop Site-specific Remediation/
Mitigation Measures (see Section 5.8)
• Stage 5 - Implement Mitigation/Remediation
(see Section 5.9)
• Stage 6 - Long-term Stewardship Plan
(see Section 5.10)
It is important to note that the full process for
environmental review can be quite lengthy if site
remediation and mitigation are necessary. The
LEA may want to consider alternative locations
early on rather than take a site through the entire
environmental review process.
Environmental Review Process
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Exhibit 7: Stages of Site Review
STAGE 1: Project Scoping/Initial Environmental Screen of Candidate Sites (Section 5.5)
STAGE 2: Preliminary Environmental Assessment (Section 5.6)
Is the site acceptable from an
environmental perspective?
Environmental review^
process for site is
complete
STAGE 3: Comprehensive Environmental Review (Section 5.7)
Is the site acceptable from
an environmental
perspective?
Does the LEA decide to
mitigate/remediate
environmental hazards so
site can be safely used for a
school location?
Environmental review^
process for site is
complete
STAGE 4: Develop Site-Specific Mitigation/Remediation Measures (Section 5.8)
STAGE 5: Implement Remedial/Mitigation Measures (Section 5.9)
Environmental review
process for site is
complete
STAGE 6: Long-term Stewardship (Section 5.10)
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Maintain long-term stewardship
to ensure that contaminant levels
are safe for use of the school
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5.5. Stage 1: Project Scoping/Initial Screen of Candidate Site
Exhibit 8: Stage 1: Project Scoping/Initial Screen of Candidate Site
START
STAGE 1: Project Scoping/Initial Environmental Screen of Candidate Sites
1. Develop a public involvement plan to implementthroughout the
environmental review process
2. Identify preliminary candidate sites using the environmental siting
criteria
(see Environmental Siting Criteria Considerations, Section 4)
3
3. Screen out sites that do not meet the environmental siting criteria
considerations
\
4. Designate the site(s) to carry forward to preliminary environmental
assessment
T
Go to STAGE 2:
Preliminary Environmental
Assessment
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This stage of the environmental review process
begins when the LEA decides to proceed with a
school facility project. At this point the school
siting committee (SSC) (see Section 3.3) should be
tasked with identifying candidate locations for the
school project and plan to give the public an
opportunity to comment (see Section 3.7) on the
preferred location that is selected.
The SSC would typically begin with a review of
possible locations for the project and screen sites
using a variety of siting criteria considerations
(see Section 4) that would include, but not be
limited to, community, environmental, planning
and transportation factors, and public health
considerations. The scope of criteria considered
by the SSC could also include cost, availability,
educational programs, services to be provided,
zoning and other considerations appropriate to
the locality. The screening should also assess the
likelihood of obtaining the various environmental,
historical, cultural and other land use approvals
and permits relevant to the proposed school site.
For example, such an evaluation is required in
New Jersey under the School Development
Authority Environmental Screening Report
(www.njsda.gov/Business/Doc_Form/PDFsForms
/RE_Manual.pdf), beginning on page 15 of
Appendix A. Many of the factors that will be
considered by the SSC are beyond the scope of
these guidelines. While all of these factors play an
important role in school siting decisions, the
remainder of this section will focus on
environmental factors that should be considered
by the SSC in recommending appropriate locations
for schools.
The SSC and LEA may wish to consult existing
state or tribal site inventories to streamline the
acceptance or rejection of sites. The screening
activity may need to be facilitated or supported by
advisers from various disciplines, including
environmental professionals and consultants.
Support from federal, state, tribal or local
government may be needed at this stage as well.
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5.6. Stage 2: Preliminary Environmental Assessment
Exhibit 9: Stage 2: Preliminary Environmental Assessment
(D
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STAGE 2: Preliminary Environmental Assessment
1
1. Identify environmental professional to evaluate the site(s) and conduct preliminary
environmental assessments
If all preferred
sites are
eliminated. Go to
Stage 1, Step 2
t
Eliminate site
from further
consideration
NO
Potential onsite contamination
(Section 5.6.1)
Potential offsite contamination
(Section 5.6.2)
Potential impacts of the project on the environment
(Section 5.6.3)
Positive environmental attributes of candidate locations
(Section 5.6.4)
I
2. Task environmental professional to develop a preliminary environmental
assessment report (Section 5.6.5)
I
3. Submit the report to state or tribal environmental regulatory agency for
preliminary review (Section 5.6.5)
I
4. Post the draft report for public comment (Section 5.6.5)
• Modify the report to address substantive issues raised during the public review
phase
I
5. Submitthe report and public comments to state or tribal environmental
regulatory agency for finalreview (Section 5.6.5)
I
6. Consider findings of the final preliminary environmental review report
(Section 5.6.6)
Environmental review
( process for site is
V complete
Go to STAGE 3:
Comprehensive Environmental
Review
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Once the LEA designates candidate sites for the
project, the LEA should engage an environmental
professional (see Section 10) to conduct the
necessary environmental reviews for the
project.52 Because LEAs may have limited
experience and limited resources for conducting
or overseeing the work described in the
guidelines, the LEA may need assistance from
federal, state, tribal or local government agencies
to guide or even undertake this work. If the local
government has an environmental department,
the LEA should consult with them as they may be
in the best position to oversee contractors or
otherwise help with the environmental review
process.
The preliminary environmental assessment of the
site is intended to:
• Identify issues related to the environmental
suitability of the preferred site; and
Identify issues to be addressed in detail during
the next stage of environmental review (Stage 3,
Comprehensive Environmental Review, Section
5.7) if environmental issues are identified and
the site continues to be considered.
The first step of the preliminary environmental
assessment involves four environmental reviews,
which can be conducted concurrently.
Environmental Site Assessment (ESA) of onsite
contamination;
Preliminary environmental assessment of
offsite environmental impacts;
Preliminary environmental assessment of
impacts of the project on the environment; and
The qualifications of an environmental professional needed to
conduct ESA's are defined in ASTM International Standard E1527-05
(www.astm.org/standards/el527.htm); also see U.S. Environmental
Protection Agency, "All Appropriate Inquiries Rule: Definition Of
Environmental Professional," U.S. Environmental Protection Agency,
Washington, DC, EPA 560-F-05-241, October 2005. (Accessed on
September 16, 2011) Available at:
http://epa.gov/brown fields/aai/ep_deffactsheet.pdf.
Preliminary environmental assessment of
desirable environmental attributes of candidate
locations.
The following four environmental reviews should
be combined into a preliminary environmental
assessment report when they have been
completed.
5.6.1. Environmental Site Assessment (ESA)
of Onsite Contamination
An Environmental Site Assessment (ESA) initially
examines the site history and former use of the
property, and may include interviews with nearby
property owners and residents, to assess potential
for onsite contamination of surface soils,
subsurface soils, soil gases, ground water and
surface water that may be contaminated.
The purpose of the ESA is to identify the presence
or the likely presence of any environmental
hazards on a property based on historical and
current land uses that might pose health risks. An
ESA, as a preliminary environmental assessment
process, will help identify issues for decision-
making as well as screen for issues that may need
to be addressed in greater detail. The industry
standard for ESAs is the ASTM International
Standard E1527-05.53 (www.astm.org/Standards/
E1527) The ESA will be based on a review of
public and private records of current and past
land uses, historical aerial photographs,
environmental databases and the files of federal,
tribal, state and local regulatory agencies. In
addition, the assessment includes conducting a
site visit, inspecting adjacent properties and
interviewing people familiar with the site's
history, including past and present owners.
Many lenders and insurers require an ESA prior to
property acquisition to obtain Comprehensive
Environmental Response, Compensation, and
ASTM E1527-05 Standard Practice for Environmental Site
Assessments: Phase I Environmental Site Assessment Process sets
forth the activities to be conducted and information to be gathered.
The standard is used during real property transfers.
(www.astm.org/standards/el527.htm)
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Liability Act (CERCLA; also known as
"Superfund") (www.epa.gov/superfund/
policy/cercla) liability protections such as:
• The bona fide prospective purchaser protection
(www.epa.gov/compliance/cleanup/revitalizati
on/bfpp);
• Contiguous property owner protection
(www.epa.gov/compliance/cleanup/revitalizati
on/cpo); and
The innocent landowner defense
(www.epa.gov/oecaerth/cleanup/
revitalization/ilo).55
The Environmental Review Process section of the
Resources page (www.epa.gov/schools/siting/
resources.html# LI NKS_environmental_review_pro
cess) lists links to ASTM standards related to site
assessment for commercial transactions.
Additionally, an eligible LEA may apply for an EPA
Brownfields Assessment Grant to conduct an ESA
on one or multiple sites and will be required to
have completed one if the LEA intends to apply for
an EPA Brownfields Cleanup Grant. The LEA may
also be required under state or tribal laws or
regulations to ensure that all potential hazards are
identified, including those that are beyond the
scope of CERCLA. Tribal and state voluntary
cleanup programs often provide guidance and
oversight during real property transfer
transactions. ESAs conducted for proposed school
sites should also address non-CERCLA related
potential hazards from both onsite and offsite
sources (see Exhibit 6: Screening Potential
Environmental and Safety Hazards).
Ultimately, an ESA or subsequent environmental
site assessment is used to determine if further
54 Comprehensive Environmental Response, Compensation, and
Liability Act, U.S. Code 42 (1980) §§9601 et seq.
55 In the CERCLA liability context, an ESA, usually called "All
Appropriate Inquiries," (see: http://www.epa.gov/brownfields/aai) is
usually a prerequisite to obtaining any of these liability protections. If
the LEA intends to obtain and maintain any of these CERCLA liability
protections, it must conduct an ESA within one year prior to
acquisition, with certain elements updated within 180 days prior to
acquisition.
action or no further action is required for the site.
For example, if a review of records shows onsite
environmental contamination exceeds state, tribal
or local standards, a comprehensive
environmental review would need to be
conducted before the site could be developed as a
school. Many states have established a variety of
environmental standards to support cleanups. In
some cases, states or tribes have developed
guidance or rules specifically to guide the school
siting process when considering environmental
contamination. In other cases, states or tribes
have other standards that have been developed
for more generic purposes that may be
appropriate for assessing the suitability of
candidate school sites. When state or tribal
standards exist, they should be used. In the
absence of such standards, states and tribes may
wish to employ EPA risk assessment methods for
the establishment of cleanup levels, (www.epa
.gov/oswer/riskassessment/risk_superfund)
The environmental standards used to evaluate site
contamination should be based on either 1)
standards developed for schools or residential use
or 2) risk based levels set for residential use. If
further action is required, the ESA report should
specify recognized environmental conditions for
further study.
5.6.2. Preliminary Environmental
Assessment of Offsite Environmental Impacts
In the preliminary environmental assessment of
offsite environmental impacts, the environmental
professional should identify potential
environmental hazards surrounding the candidate
site such as from old waste sites (including
Superfund sites), localized air pollution (e.g., rail
lines, industrial facilities), hazardous material
pipelines and others. Hazards of potential concern
and the screening distance from the site for which
potential hazards should be identified for
evaluation are described in Exhibit 6: Screening
Potential Environmental and Safety Hazards.
Some level of air quality analysis should be
considered for every new school site prior to
project approval by the LEA. This analysis should
Environmental Review Process
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at a minimum include criteria air pollutants (i.e.,
ground-level ozone, sulfur dioxide, lead, carbon
monoxide, nitrogen oxides and particulate matter)
and hazardous air pollutants (e.g., air toxics such
as benzene, formaldehyde and diesel exhaust).
Depending on the location of the site, the analysis
may require database reviews, contaminant
transport and dispersion modeling, monitoring,
health risk assessments, site reconnaissance
and/or other methods. For more specific guidance
see Evaluating Impacts of Nearby Sources of Air
Pollution (see Section 6).
The Emergency Planning and Community Right-
To-Know Act56 (www.epa.gov/oecaagct/
lcra#Hazardous%20Chemical%20Notification%2
Oand%20Inventory%20Reporting) gives
communities access to information on toxic and
hazardous chemicals inventories in their
communities. Additionally, Section 112(r) of the
Clean Air Act57 requires facilities that produce,
handle, process, distribute or store certain
chemicals to develop and submit a Risk
Management Plan to EPA, which is also available
to communities.58
5.6.3 Preliminary Environmental
Assessment of Impacts of the Project on the
Environment
In assessing a potential site for new school
construction (rather than renovating or expanding
an existing school or adapting another structure),
LEAs should consider the environmental impacts
of building a school on the new location, in
addition to potential health and safety risks to the
surrounding community. An environmental
impact review conducted during the preliminary
environmental assessment identifies potential
significant impacts of the project on the
surrounding environment and human health, as
well as construction and regulatory obstacles that
cannot be overcome. An environmental impact
56 Emergency Planning and Community Right-To-Know Act, U.S. Code
42 (1986) §§11001 et seq.
57 Clean Air Act, U.S. Code 42 (1970) §§7401 et seq.
58 U.S. Environmental Protection Agency, "Risk Management Plan
Rule." Last modified September 19, 2011. Available at:
http://www.epa.gov/osweroel/content/rmp/.
review may be required by a state or tribal
environmental regulatory agency or planning
board (e.g., for large school construction projects).
The outcome of the environmental impact review
could result in rejecting a site from further
consideration either by the state or tribe or by the
LEA. The potential categories for consideration
that should be assessed may include:
Community amenities;
Existing infrastructure; and
Potential impacts or hazards.
Potential impacts that should be assessed may
include:
Local utilities such as water supply, sewage
service and electricity;
Increases in local traffic and congestion as well
as impacts on pedestrian safety;
Hydrology/water quality such as coastal
wetlands, floodplains and stream encroachment
constraints;
Public land such as displacement of parks;
Access to public resources such as parks and
libraries;
Historic or archeological resources;
Threatened or endangered plant or animal
species;
Habitat loss;
Aesthetics such as lighting or noise from
stadiums;
Hazards and hazardous materials related to
transport and disposal of onsite contamination
removed from the site during cleanup;
Agricultural resources such as displacement of
farmland;
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• Air quality such as emissions from construction,
including engine exhaust and dust from
clearing, grading and burning;
Geology/soils such as creating slope instability
during construction;
Mineral resources such as displacing drilling
rights;
Public services such as police and fire;
Ability to serve as an emergency shelter;
Excessive community relocation and
displacement impacts;
Time spent traveling to and from school;
Walk/bike route audits; and
Percentage of students who could walk/bike to
school.
5.6.4. Preliminary Environmental
Assessment of Desirable Environmental
Attributes of Candidate Sites
Desirable environmental attributes of a given site
should also be assessed, such as the site's
proximity to residences where future students live
(so students would be able to walk or bike to
school); whether sidewalks, crosswalks and
streets in proximity to the site provide safe routes
to school; the availability of public transportation
to and from the site; and access to community
resources, such as libraries, community centers,
parks and other features. See Exhibit 4: Desirable
Environmental Attributes of Candidate Sites.
5.6.5 Review of the Preliminary
Environmental Assessment Report
Once the environmental professional has
completed the four reviews described earlier, a
report should be developed and submitted for the
review steps that follow.
Preliminary agency review of the preliminary
environmental assessment report
The LEA will need to comply with the state's
requirements for environmental review and
would typically submit the draft preliminary
environmental assessment or additional
assessments to the state or tribal environmental
regulatory agency (www.astswmo.org/Pages/
Resources/State_Agency_Links.htm) for any site it
is considering pursuing. When state or tribal
requirements are not present, the LEA should
secure an agreement with the state or tribal
environmental regulatory agency for review of the
draft ESA results. It is desirable to have the state
or tribe review the offsite contamination
assessment, environmental impact assessment
and assessment of desirable environmental
attributes as well.
Public comment on the preliminary
environmental assessment report
All four reviews that comprise the preliminary
assessment report should be made available to the
public and relevant local agencies (e.g., the local
department of transportation and the local police)
for comment. To aid with the understanding of
these work products, the environmental
professional or the LEA should prepare a plain
language summary of the preliminary
environmental assessment reports for the
community, including translation for non-English
speaking stakeholders, if applicable.
If the preliminary environmental assessment
report recommends no further action, the LEA
should release the work conducted (e.g., reports
submitted to the state, any responses and other
supporting assessments) for public comment and,
if appropriate, hold a public hearing, before
formally adopting the recommendations of the
preliminary review. If the preliminary
environmental assessment report recommends
further action, public review of the preliminary
environmental assessment report may occur
during Stage 3 (see Section 5.7).
Regardless of the findings, the components of the
preliminary review report should be subject to
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public comment. The LEA should follow the steps
described earlier (see The Importance of
Meaningful Public Involvement, Section 5.2.1) to
solicit public comment on the preliminary
environmental assessment report and proposed
next steps based on review findings. A public
comment period may be required by the state or
tribal regulatory agency, particularly if the
preliminary review indicates that no further
environmental review is necessary and no other
method of securing public comment are likely. The
information listed earlier should be included in a
public notice. More information on effective public
involvement can be found in the Meaningful Public
Involvement section (see Section 3).
Final agency review of preliminary
environmental site assessment
Prior to final state- or tribal-level review, the LEA's
report should be modified to address substantive
issues raised during the public review phase. The
state or tribal environmental regulatory agency
(www.astswmo.org/Pages/Resources/State_Agen
cy_Links.htm) should also review all comments
received on the preliminary environmental
assessment report and determine whether no
further action is required on the site or whether
further action (e.g., a comprehensive
environmental review) is required.
5.6.6. SSC and LEA Review and
Recommendation
After the state or tribal environmental regulatory
agency responds to the findings of the final
preliminary environmental assessment report and
determines whether further action is needed, the
SSC and the LEA should review the findings of the
preliminary environmental assessment report and
make a recommendation on the project. The
recommendation should be based on the
Preliminary Assessment Report and public
comments received. The purpose of this review is
for the LEA to either:
1. Proceed with plans for construction if no
further remediation or study is required;
2. Continue evaluating the potential
environmental hazards at the site with a
comprehensive environmental review; or
3. Eliminate the site from further consideration
and pursue alternative locations.
If the recommendation is to proceed with
construction or with a comprehensive
environmental review, decisions should be
explicitly described and steps should be taken to
involve the public to the greatest extent possible.
If the recommendation is to proceed with
construction of a new school because no further
remediation or study is required (no further
action is needed), the governing body of the LEA
should formally accept and document the findings
of the review and then proceed with the project.
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5.7. Stage 3: Comprehensive Environmental Review
Exhibit 10: Stage 3: Comprehensive Environmental Review
(D
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Goto
Stage 1,
Step 2
t
STAGE 3: Comprehensive Environmental Review
1. Identify environmental professional to conduct the comprehensive environmental
assessment (Section 5.7)
NOTE: Comprehensive environmental reviews are only needed for potential
environmental hazards Identified In the preliminary environmental assessment and
may Include review of onslte contamination, offslte environmental hazards and/or
impacts on the environment.
2. Task environmental professional to develop a workplan that defines the goals and
rationale of the sampling strategy and the sampling methods and procedures
(Section 5.7.1)
• Post the workplan for public comment
• Submit the workplan to state and tribal environmental regulatory agency for review
3. Task environmental professional to conduct comprehensive environmental review
(Sections 5.7.1-5.7.3)
4. Task environmental professional to draft a final report of all comprehensive
environ mental reviews that were conducted (Section 5.7.4)
• Develop preliminary plans and cost estimates for any mitigation/remediation measures that
may be needed for the site
5. Submit the draft report to state or tribal environmental regulatory agency for
preliminary review (Section 5.7.4)
6. Post the draft report for public comment (Section 5.7.4)
• Modifythe report to address substantive issues raised during the public review phase
7. Submit the final report and public comments to state or tribal environmental
regulatory agency for final review (Section 5.7.5)
& Make final comprehensive environmental review report available to the public
(Section 5.7.5)
9. Consider findings of the final comprehensive environmental review report
(Section 5.7.7)
Eliminate site
from further
consideration
Is the site
acceptable from an
en vironmentai
perspective?
Does the LEA decide to
mitigate/remediate
environmental hazards so
site can be safely used for a
school location?
Environmental review^
process for site is
complete
Go to STAGE 4:
Develop Site Specific Mitigation/Remediation Measures
Environmental Review Process
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If the LEA decides to conduct a comprehensive
environmental review, the environmental
professional (see Section 10) employed or hired to
perform the assessment will conduct a more
thorough examination of the potential issues
identified in the preliminary environmental
review.59 The LEA is encouraged to work with its
state or tribal environmental program to assist
with this effort. The following description of the
comprehensive environmental review includes
assessment of onsite contamination, offsite
environmental hazards and potentially significant
environmental impacts of the proposed school on
the surrounding environment. It is important to
note that it may not be necessary to perform all
three comprehensive reviews. The findings from
the preliminary environmental review can be used
to determine which assessment(s) is/are needed
to fully characterize the site.
The purpose of the comprehensive environmental
review is to gather and analyze data on
environmental hazards and impacts identified in
the Preliminary Environmental Review, and
evaluate the risks posed to children's health,
public health and the environment based on the
contamination or impacts found. The
comprehensive environmental review also
includes developing preliminary plans and cost
estimates for mitigating or reducing risks. The
cost of the comprehensive environmental review
will depend on the complexity of the site. LEAs are
strongly encouraged to work with their state or
tribal environmental regulatory program to
identify critical environmental factors that need to
be considered in the environmental assessment
process.
In many states, the only portion of the
comprehensive environmental review that is
subject to review and approval by the state
The qualifications of an environmental professional needed to
conduct ESA's are defined in ASTM International Standard E1527-05
(www.astm.org/standards/el527.htm); also see U.S. Environmental
Protection Agency, "All Appropriate Inquiries Rule: Definition Of
Environmental Professional," U.S. Environmental Protection Agency,
Washington, DC, EPA 560-F-05-241, October 2005. (Accessed on
September 16, 2011) Available at:
http://epa.gov/brownfields/aai/ep_deffactsheet.pdf.
environmental regulatory agency is the onsite
contamination component. An oversight review of
the offsite and environmental impact reports
should also be completed, but the agency that
conducts the review will vary from state to state.
The environmental professional should prepare
draft reports for each review being performed,
and the LEA should publish those drafts for public
comment. All final drafts should consider public
comments. The final drafts should be subject to
review and approval by the SSC and LEA. To
capture a range of considerations the three
reviews that follow (or whichever of the three
reviews that are needed, based on the preliminary
environmental review) can be conducted
concurrently.
The comprehensive environmental review should
also include an evaluation of the potential risks
posed to children's health, public health or the
environment based on the contaminants identified
at the site. This evaluation should include:
A conceptual site model that includes a
written description and graphic depiction of all
possible pathways of exposure that could result
in children, school staff and the community
being exposed to potentially harmful
contaminants at the school site (e.g., inhalation,
soil ingestion, dermal);60 and
• A description of potential health
consequences of long-term and short-term
exposure to any potentially harmful
contaminants, to the extent feasible.
5.7.1 Comprehensive Environmental
Review of Onsite Contamination
If the state or tribal regulatory agency concurs
with the findings from the preliminary
environmental assessment and no further action
60 Many conceptual site models have been developed. For example,
there is a model in Section 3.1 of the Regional Screening Level
Guidance available at: www.epa.gov/reg3hwmd/risk/human/rb-
concentration_tableAisersguide.htm and California has a model
available at:
www.dtsc.ca.gov/SiteCleanup/upload/Appdx_Al_083108.pdf.
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is required, the review for onsite contamination is
complete.
If the preliminary environmental assessment (see
Section 5.6) shows that further assessment of
onsite contamination is necessary, the
environmental professional should conduct a
comprehensive environmental review to
determine if hazardous materials are present, or if
there is potential for a release of a hazardous
material or substance that could pose a health
threat to children, staff or community members.
The comprehensive environmental review should
also assess the need for cleanup based on levels of
contamination found and identify the cleanup
standards that will be used.
Before any work is done on the comprehensive
environmental review, the LEA should develop a
public involvement plan (see Section 3) that
ensures meaningful public and community
involvement in the comprehensive environmental
review process. The plan should indicate what
mechanisms the LEA will use to involve the public.
The LEA should submit the public involvement
plan to the state or tribal regulatory agency for
comment before comprehensive environmental
review activities begin; in some cases, this may be
a state or tribal requirement.
Before conducting any sampling for the detailed
comprehensive environmental review, the
environmental professional should prepare a
workplan that defines the following:
The goals of the sampling;
• The rationale for the sampling strategy,
including the number and location of sampling
sites and what substances to analyze in the
samples; and
• The sampling methods and procedures that will
be used, and the analytical methods and
procedures, in accordance with quality
assurance plan requirements.
The comprehensive environmental review may
include full-scale grid sampling and analysis of
soil, soil gases (if any), and potentially surface
water, ground water and air (www.epa.gov/
schools/siting/resources) to accurately define the
type and extent of contamination present at the
candidate site. State or tribal environmental
regulatory agency (www.astswmo.org/
Pages/Resources/State_Agency_Links.htm)
review of the workplan should be obtained prior
to the initiation of sampling. Prior to sampling, the
LEA should obtain signed access agreements from
property owners.
Criteria for establishing the degree of cleanup
needed should be based on state or tribal cleanup
Engineering and Institutional Controls
and Community Involvement
Engineering controls and institutional
controls are tools to ensure that sites
remain safe by preventing potential
exposures to contaminants and
preventing land uses likely to create
exposures (see Section 8.15).
Communities have an important role to
play in ensuring engineering and
institutional controls remain in place and
are effective in preventing potential
exposures. Through the community
involvement and planning process, the
community can become familiar with the
nature of residual contamination,
engineering controls and institutional
controls that place restrictions on how
the land can be used. They can help LEAs
meet their obligations by reporting
actions in conflict with those land use
restrictions to LEA management and
tribal or state environmental regulatory
authorities. The LEA and the SSC also can
continue to play a role in updating the
community about their inspection,
monitoring and maintenance efforts, with
the assistance of tribal or state technical
oversight, as appropriate. See the Quick
Guide for Environmental Issues (see
Section 8.15) for information about
engineering and institutional controls.
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rules or guidance, where they exist. The
environmental standards used to evaluate site
contamination should use either 1) standards
developed for schools or residential use or 2) risk-
based levels designed to be protective for
residential use. If cleanups are going to leave
residual contamination that exceeds residential
use levels, engineering and institutional controls
(see Section 8.15) and long-term stewardship (see
Section 8.16) should be included to provide a safe
environment.
The process of identifying the capability of the
state, tribal or local agencies to maintain
institutional and/or engineering controls and
implement long-term stewardship will vary with
the jurisdiction. For example, communities with
well established environmental departments are
more likely to be familiar with institutional and
engineering controls and long-term stewardship,
especially if there are sites within their
community where institutional and engineering
controls and long-term stewardship have been
employed. In situations where the local
government lacks the resources, expertise or
authority to implement and enforce
institutional/engineering controls as part of
overseeing long-term stewardship plans, state or
tribal staff may need to assume this responsibility.
If staff or resources are not available to support
institutional and engineering controls and long-
term stewardship that would be needed, a site
that requires these tools should not be selected
because exposures without institutional and
engineering controls and long-term stewardship
could pose unacceptable risks to students and
workers.
When environmental testing is completed, and
remedial actions are undertaken to prevent
potential environmental exposures, it may be
important to preserve the ability to pursue cost
recovery in the future, in cases where legal cost
recovery mechanisms exist. The environmental
professional should keep detailed records during
all phases of the environmental assessment and
remediation and is required to sign
documentation of their findings and
recommendations. Photo documentation,
complete field notes, written notification to
property owners of environmental conditions and
provisions to allow property owners to obtain
split samples for analysis are all recognized
methods to preserve cost recovery rights.
5.7.2. Comprehensive Environmental
Review of Offsite Environmental Hazards
Using the list of offsite hazards identified in the
preliminary environmental assessment report
(Stage 2, see Section 5.6), the environmental
professional should evaluate and estimate the
risks those hazards may pose to future users of
the school site. (If no nearby hazards were
identified in the preliminary environmental
review, no further review of offsite environmental
hazards is needed.) The environmental
professional should identify both the risks that
can be mitigated and those that cannot be
mitigated and identify measures to reduce these
risks to the extent feasible. Old waste sites,
including Superfund sites, industrial air pollution
sources, rail lines, rail yards and highways are
examples of the kind of hazards that would be
evaluated at this stage (See Exhibit 6: Screening
Potential Environmental and Safety Hazards). The
report about offsite hazards should discuss
whether feasible mitigation measures are
available that would eliminate all significant risks.
For more specific guidance see Evaluating Impacts
of Nearby Sources of Air Pollution (see Section 6).
5.7.3. Comprehensive Environmental
Review of Impacts of the Project on the
Environment
Using the list of potential significant
environmental impacts (e.g., habitat and water
quality) identified in the preliminary
environmental assessment (see Section 5.6), the
environmental professional should evaluate and
report potential impacts the project may have on
the surrounding environment and propose
alternatives to mitigate or eliminate those
impacts. The report should discuss what
environmental impacts will remain even after
mitigation measures are taken. (If no potential
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significant environmental impacts were identified
in the preliminary environmental review, no
further review of impacts of the project on the
environment is needed.)
5.7.4. Development and Review of
Comprehensive Environmental Assessment
Reports
The environmental professional should prepare a
draft report that combines the findings of the
environmental assessment(s) performed in the
comprehensive environmental review. This draft
comprehensive environmental review report will
also describe proposed and alternative mitigation
measures to reduce potential risks and impacts.
Through findings and conclusions with supporting
data, the report should document potential
impacts that:
Are not considered to be of concern;
Could be effectively managed though
mitigation; and
• May pose significant or unacceptable risks even
after all feasible mitigation steps have been
implemented.
The LEA should submit the draft comprehensive
environmental review report to the
environmental agencies involved in the regulatory
oversight of the school siting decision, which may
include tribal, state, other local agencies or federal
agencies (such as Bureau of Indian Education or
Department of Defense), and the public upon its
completion by the environmental professional. To
solicit public comment, the LEA should post the
draft comprehensive environmental review on the
project website and should follow the steps
described earlier in this section.
The LEA and state or tribal environmental
regulatory agency should evaluate public
response to the notice and modify the public
involvement plan (e.g., by extending the comment
period), as necessary, to ensure meaningful public
input throughout the school siting process. The
LEA should address all substantive comments
received during the comment period.
The state, tribal, local or federal environmental
regulatory agency that is overseeing the conduct
of the comprehensive environmental review
should review all comments received. The agency
may then accept or reject the conclusions of the
review or request revisions. In some cases (e.g.,
due to timing or access constraints), the
comprehensive environmental review may not
characterize all environmental hazards. A
separate supplemental site investigation may be
necessary prior to determining the potential need
for remediation/mitigation. The process for
conducting a supplemental site investigation
should follow the steps identified earlier for the
comprehensive environmental review. If accepted,
the state, tribal, local or federal environmental
regulatory agency may concur with the finding
that no further action is required or that a
remedial action workplan is required if the LEA
decides to pursue development of the site. The
agency will explain in detail the reasons for
accepting or rejecting the comprehensive
environmental review report and the basis for its
determination.
5.7.5. Final Comprehensive Environmental
Review Report
Following the public comment period the
environmental professional, in consultation with
the LEA and the SSC, should evaluate and respond
to all public comments and incorporate those
comments into a final comprehensive
environmental review report.
The final report should then be forwarded to the
SSC and to relevant public agencies. To solicit
public comment, the LEA should post the final
comprehensive environmental review on the
project website and should follow the steps
described earlier in this section.
5.7.6. Cost Estimates and Schedules of
Remediation and/or Mitigation Measures
If the final report of potential environmental risks
and impacts includes proposals for mitigation
measures (e.g., institutional controls (see Section
8.15), engineering controls (see Section 8.15),
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encapsulation of lead based paint (see Section
8.16), enclosure of asbestos (see Section 8.8), and
long-term stewardship (see Section 10), potential
cost estimates and schedules of implementation
should be developed in coordination with facility
planners (e.g., architects and local agencies). In
addition, preliminary cost estimates and
schedules for implementation of any remediation
of onsite contamination should be prepared,
including, where appropriate, the cost of
maintaining and monitoring controls over the life
of the school. These preliminary cost and schedule
estimates for mitigation and remediation should
then be forwarded to the SSC and LEA.
5.7.7. SSC Review and Recommendation
The SSC should review:
• Final comprehensive environmental review
report;
Preliminary cost estimates and schedules for
remediation and mitigation; and
Public comments received on these documents.
The SSC should recommend to the LEA whether
the environmental reports adequately
characterize potential environmental concerns at
the candidate site. Following this determination,
the SSC can recommend to the LEA whether to
proceed or eliminate the site from further
consideration based on public health risks, costs
and schedule impacts, public concerns and other
factors.
The LEA should then review the committee
recommendations, including any analysis of
potential alternatives, impacts to public health,
project costs/schedule impacts, public concerns,
etc., and decide to certify the environmental
reports or request further revisions to the reports.
Following this determination, the LEA may
approve proceeding with the project at the site for
which the comprehensive environmental review
was completed or decide to eliminate the site from
further consideration. If the LEA decides to
eliminate the site from further consideration, the
LEA should work with the SSC to identify another
preferred location for environmental review that
begins at Stage 2 (see Section 5.6) or Stage 3 (see
Section 5.7), depending on what assessment has
already been performed for the new preferred
location. In those instances, records of
environmental investigation, findings and
decisions should be retained.
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5.8. Stage 4: Develop Site-specific Mitigation/Remediation Measures
Exhibit 11: Stage 4: Develop Site-specific Mitigation/Remediation Measures
STAGE 4: Develop Site-Specific Mitigation/Remediation Measures
Goto
Stage 1.
Step 2
1. Task environmental professional to develop a remedial action
workplan, including a preliminary long-term stewardship plan
if the remedial action includes the use of institutional controls,
engineering controls and/or long-term mitigation measures.
(Sections 5.8.1-5.8.4)
2. Submit draft workplan to the state or tribal environmental
regulatory agency (Section 5.7.5)
I
3. Post the workplan for public comment (Section 5.7.5)
4. Submit the final workplan to the state or tribal environmental
agency for review and approval (Section 5.7.5)
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Go to STAGE 5:
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5.8.1. Offsite Mitigation Measures
In addition to remediation of onsite
contamination, the LEA should coordinate with
the appropriate state, tribal and local government
agencies to implement any necessary offsite
mitigation measures, such as installing traffic
signals, signage, utilities, etc., as well as identify
potential measures that can be implemented at
the proposed school site to mitigate hazards from
offsite pollution sources by eliminating exposures
to pollutant hazards. For more specific guidance
see Evaluating Impacts of Nearby Sources of Air
Pollution (see Section 6).
5.8.2. Onsite Remediation Measures
If the LEA decides to proceed with a site where
contamination will be cleaned up, a remedial
action workplan should be developed and
submitted to the state regulatory agency for
approval. Typically, an environmental
professional will assist with the workplan. When
designing cleanup activities, the LEA should
recognize that young children will be present on
the site and evaluate assumptions used in
establishing cleanup standards and remedial
response. When available, the state and LEA
should use cleanup levels that are explicitly
protective of early life sensitivity to toxicants and
early life exposures.
NOTE: Typically, cleanup levels for sites intended
for residential use are appropriate for use at sites
considered for a future school use. State and tribal
programs may recommend cleanup levels based
on their review of the specific site characteristics,
contaminants present on the site and other
factors. Where cleanup is needed, all cleanup work
should be completed and approved by the state or
tribal regulatory agency prior to occupancy of the
school. In cases where residual waste or
contamination will remain on site following
cleanup, a careful and objective evaluation of the
capacity of the school district and local and state
authorities should be completed to ensure safe
operations and that institutional and engineering
controls (see Section 8.15) will be maintained (i.e.,
long-term stewardship) over the long term and be
subject to public review before the decision is
made to rely on such controls. Where state or
tribal regulators have approved cleanup to
restricted reuse standards, LEAs need to secure
funds or post a bond to ensure the continued
monitoring and maintenance of institutional and
engineering controls.
The remedial action workplan should:
Identify methods for cleaning up the site to
contaminant levels that meet the applicable
environmental and public health standards;
Contain a financial analysis that compares
estimated costs over the life of the school for
the identified cleanup methods that will bring
the site into compliance with applicable safety
standards;
• Recommend a cleanup plan from the
alternatives identified, including a description
of long-term maintenance, monitoring and the
cost of any institutional or engineering controls
and long-term stewardship implemented as
part of the cleanup (preliminary site
maintenance plan);
Explain how the recommended cleanup
option will prevent children from being
exposed to the environmental hazards found
at the site or on any adjoining contaminated
parcels; and
• Clearly describe the responsibilities and
long-term environmental stewardship
obligations of the LEA (or other responsible
party) for inspection, maintenance and
reporting associated with any engineering
control implemented as part of the cleanup.
If cleanups are going to leave residual
contamination on the site that require
implementation and maintenance of
engineering/institutional controls (see Section
8.15), LEAs should ensure that the site cleanup
plan is approved by the state or tribe for state or
tribal voluntary cleanup sites.
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5.8.3. Remediation Techniques
Although the specific remedial response measures
prescribed in a remedial action workplan will
need to be tailored to the particular
characteristics of a given site, a number of
environmental conditions in need of remediation
are routinely encountered at existing and
proposed school locations. The environmental
professional and the state or tribal environmental
regulatory agency should have the expertise
needed to develop each of the remediation options
that follow.
The following text provides examples of situations
that might be encountered. These examples are
being provided because they highlight scenarios
that have been repeated in different locations
throughout the country. They highlight types of
contamination and remedies that have been
employed. See the Quick Guide to Environmental
Issues, Section 8, for additional information about
the examples below, and see the Resources
(www.epa.gov/schools/siting/resources) page of
the guidelines website for links related to
environmental issues that may be encountered for
some sites.
Example 1
The presence of volatile organic compounds
(VOCs) in soil and ground water (see Section 8.3)
may require mitigation measures to protect
against potential vapor intrusion into overlying
school buildings. Common contaminants in soil
and ground water that can cause a vapor intrusion
concern include benzene (e.g., from gasoline) and
dry cleaning and degreasing solvents (e.g.,
trichloroethylene and perchloroethylene). If these
or other volatile contaminants are present and the
LEA decides to proceed with the site, there are
ways the facility can be located on the property,
designed and engineered to minimize the
potential for vapor intrusion and include
mitigation equipment for future use, if needed, at
a lower cost than if retrofitted after construction.
When constructed, periodic indoor air testing is
often warranted, and depending on the
concentration and potential duration of exposure,
remedial actions such as the installation of an
underground soil vapor recovery system may be
required to eliminate a potential vapor intrusion
concern. Water quality testing may also be
required. If ground water is found to be
contaminated, monitoring wells may need to be
drilled at the site, and long-term water monitoring
may be required.
Example 2
The presence of petroleum in soil and ground
water (see Section 8.5) as a result of leaking
underground storage tanks may require soil and
ground water remediation. If the soil is excavated,
and if separated phase petroleum is floating on
the water table, it usually requires recovery and
offsite treatment and disposal. Contamination
from underground storage tanks can also result in
vapor intrusion concerns, which are discussed in
the earlier example.
Example 3
In some cases, structural fill is brought onto a site
to provide a reliable structural surface for
construction, and in other cases, the soils on the
site are composed of historic fill (see Section
8.14). If fill is contaminated, it can present a
potential risk to students or staff. If feasible, the
LEA should clean up the site to residential use
levels, which may involve removal of fill material.
Where removal of large quantities of fill material
is infeasible, institutional/engineering controls
and an enforceable long-term stewardship plan,
approved by an environmental regulatory agency,
may be utilized to eliminate exposure to
contaminated soil. Landscaping plans need to be
compatible with the engineering control. For
example, plants with only a shallow root zone may
be allowed but trees may be prohibited.
Example 4
The presence of banned pesticides (see Section
8.12) may be encountered in soil and ground
water at existing and proposed school sites as a
result of former agricultural and pest
management practices. Some of these pesticides
do not readily degrade, and as a result may
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present a potential exposure when soil is
excavated. Depending on prior uses of the site,
sampling for pesticides may be appropriate to
consider in the development of the
comprehensive environmental review plan
described earlier in Stage 3 (see Section 5.7).
5.8.4.
Plan
Preliminary Long-term Stewardship
If the remedial action workplan includes partial
cleanup in conjunction with the use of
institutional and engineering controls to prevent
potentially harmful exposures to contaminants,
the LEA should develop a preliminary long-term
stewardship plan as part of the remedial action
plan to ensure full consideration of long-term
feasibility and cost. A preliminary long-term
stewardship plan should include:
Identification of contaminants of concern
and, if possible, maps showing the location of
contamination, property boundaries, and
institutional and engineering controls;
Proposed plans to contain contaminants,
including any engineering and institutional
controls to be used;
• Long-term maintenance and monitoring
measures necessary to ensure the long-term
integrity of engineering and institutional
controls;
A detailed evaluation of the resources and
expertise necessary to implement the plan and
a discussion of alternative measures considered
and the basis for their rejection;
• A demonstrated commitment of funding
sufficient to ensure the implementation and
maintenance of all plan components over the
long term (i.e., the life of the school);
A remedial action workplan that addresses
cleanup of the entire contaminated site when a
school is proposed for only a portion of a known
contaminated site. In this case, the long-term
stewardship plan should outline the ongoing
security measures which will ensure that only
authorized persons can gain access to the
unremediated portion of the contaminated site;
Plans for monitoring institutional and
engineering controls should include
timeframes for monitoring (annual
monitoring reviews should be adopted at
least for the first few years when institutional
controls/engineering controls are employed),
recordkeeping and reporting;
Conditions and procedures for modification
and termination of institutional controls;
and
Recommendations for the final site sampling
to be done after the cleanup has been
completed to ensure that all residual
contamination is less than the cleanup goals
denned for the site. Such sampling
recommendations should be designed to
discover the highest possible concentrations of
contamination at the candidate site.
There are a number of resources that document
types of remediation, costs and effectiveness for a
range of contaminants, engineering controls and
institutional controls that can be effective in
managing contaminants, including EPA's Office of
Solid Waste and Emergency Response onsite
cleanup (www.epa.gov/oswer/cleanup/index)
and EPA's Clu-In (www.clu-in.org/) websites,
which are listed on the Resources (www.epa.gov/
schools/siting/resources) page of the guidelines
website. While these websites provide extensive
materials, the cost, effectiveness and variety of
methods will vary with the site and need to be
properly monitored and maintained to remain
protective.
5.8.5. SSC and State or Tribal Agency
Review and Public Comment
The LEA should secure state or tribal regulatory
agency review and approval of the remedial action
workplan prepared by the environmental
professional. Upon submitting this plan to the
state or tribal environmental regulatory agency,
the draft remedial action workplan should be
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made available to the SSC for review and
comment. Once the workplan is submitted to the
state or tribal agency for approval, the LEA should
post the draft comprehensive environmental
review on the project website and follow the steps
described earlier to solicit public comment.
A public hearing on the remediation plan should
be conducted in the neighborhood or jurisdiction
of the candidate site. The LEA should publish a
notice of the hearing in newspapers of general
circulation, including foreign language
newspapers if the school district has a sizable
number of non-English speaking parents, and post
a notice on the LEA and project websites stating
the date, time and location of the hearing.
After the public hearing and review of any
comments received during the public comment
period, the state or tribe should approve the
remedial action workplan, approve the workplan
with revisions or disapprove the workplan. If the
state or tribe requires additional information, a
copy of the state's or tribe's comments and the
responses prepared by the environmental
professional in coordination with the LEA should
be made available to the SSC and be posted on the
project website. Any additional information
submitted by the LEA to the state or tribe should
also be made available to the SSC.
The state or tribe should explain in detail the
reasons for accepting or rejecting the workplan.
Before approving a workplan, the state or tribe
should make an explicit finding that the LEA has
the requisite capacity to oversee and manage the
remediation/mitigation measures and
institutional and engineering controls proposed in
the remedial action workplan.
After the state or tribe approves the workplan, the
SSC may also review the plan and recommend to
the LEA whether to proceed with acquiring the
site and implementing the remediation plan. The
LEA should not begin constructing the school until
site clearance has been provided by the state or
tribal environmental regulatory agency, following
its approval of the remediation activities (post-
Stage 5).
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5.9. Stage 5: Implement Remedial/Mitigation Measures
Exhibit 12: Stage 5: Implement Remedial/Mitigation Measures
STAGE 5: Implement Remedial/Mitigation Measures
1. Commence with the remediation of onsite contaminants and mitigation
ofoffsite sources of pollutants
2. Conduct samp ling to verify cleanup goals have been met and mitigation
measures of offsite sources of pollutants have been successful
3. Document successful implementation of the plan and final sampling
results, and compile into a report
4. Post the report for public comment
5. Submit the report to the state or tribe for review
Do remedial actions and
mitigation measures fully
address environmental hazards
so that no long-term
stewardship is needed to prevent
school occupants' exposure?
6. Revise the preliminary long-term stewardship plan
(developed in Stage 4, Step 1)
1
7. Post the final long-term stewardship plan for publiccomment
I
8. Send long-term stewardship plan to state and tribal authorities for
approval
Go to STAGE 6:
Long-term Stewardship
'Environmental review
process for site is
complete
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Prior to the onset of any school construction at the
candidate site, EPA recommends the remediation
of the site as defined in the remedial action
workplan be completed. If engineering controls
are required as part of remediation, construction
of those controls may begin following approval by
the state or tribal environmental regulatory
agency.
Remediation measures taken to reduce risks from
offsite hazards can be conducted prior to or
during school construction activities, depending
on the mitigation measures being implemented.
Appropriate state, tribal and local environmental
agencies should be consulted before and after the
remediation measures are installed to ensure that
the mitigation controls taken will reduce
exposures to the environmental hazards of
concern. For more specific guidance see
Evaluating Impacts of Nearby Sources of Air
Pollution (see Section 6).
Final sampling, in accordance with sampling
procedures in the comprehensive environmental
review or the remedial action workplan, should be
conducted to verify that cleanup goals have been
met. Documentation regarding the
implementation of the plan and all final sampling
results should be compiled into a report and
submitted to the LEA and SSC for posting on the
project website and also submitted to the state or
tribe for review, which may require additional
sampling and/or remediation efforts as the state
or tribe deems appropriate. Any modifications to
the remedial action workplan should also go
through the appropriate public review processes
described earlier.
Toward the completion of remedial activities, the
environmental professional should revise the
preliminary long-term stewardship plan (LTSP)
developed in Stage 4, Section 5.8, which will set
forth, in detail, the specific manner in which
institutional and engineering controls will be
employed. The preliminary LTSP should address
all contamination left on site following
remediation that would prevent residential use.
The preliminary LTSP should be submitted for
public review and comment in the same manner
undertaken for all of the preceding plans and
reports and should be submitted to the state or
tribe for approval prior to the commencement of
construction. A critical component of such a plan
is a clear commitment for the funding and other
support needed to effectively monitor and ensure
the integrity and effectiveness of any institutional
and engineering controls.
A description of the recommended contents of the
preliminary or final LTSP follows:
A site description that includes:
- Historical uses of the site and relevant
adjacent historical uses;
- A summary of the environmental
evaluation of the site including details on
the location and extent of soil/water
contamination in excess of regulatory
standards; and
- A summary of the remedial work done at
the site along with the test results.
• A clear depiction of the institutional and
engineering controls that includes:
- Accurate maps showing the institutional
and engineering controls;
- A description of the long-term
environmental stewardship obligations
along with a statement of who will be
responsible for their implementation; and
- A public document that outlines the
responsibilities for maintaining both
engineering and institutional controls,
provided contamination levels warrant the
controls.
Specific contingency plans that describe
engineering control restoration activities
should the engineering control be disturbed;
A description of prohibited activities (e.g.,
digging) in areas constructed with an
engineering control to maintain the integrity of
the engineering control;
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A definition of the minimum professional
requirements (i.e., licensed professional
engineer) for maintaining the engineering
control, including where appropriate any
necessary training of school staff responsible
for managing school grounds including:
- Identification/creation of a position within
the schools facility department for a
technically knowledgeable person trained
and responsible for oversight of the school
and grounds;
- Training on techniques for monitoring
cracks in the school foundation and
breaches in the engineering control;
- How to handle and/or report problems
with equipment and remedial systems; and
- How to handle complaints and comments
about environmental conditions at the
school.
A compliance monitoring program to be
carried out by qualified environmental
professionals, as necessary, that will include:
- Routine inspections, tests and
maintenance of engineering and
institutional controls to ensure their
continued effectiveness;
- Tests for the presence of contaminants in
the soil, soil gas, ground water and indoor
and ambient air on the school grounds if
an engineering control is disturbed;
- Procedures for recordkeeping and
reporting;
- Allocation of responsibilities for these
activities among LEAs, state or tribal
agencies, school officials and staff; and
- An independent review by a licensed
professional engineer not affiliated with
the school.
A public accountability/oversight plan that
includes:
- The prominent placement of signage
within the school that clearly defines the
extent of the contaminated areas along
with appropriate institutional and
engineering controls on the property, and
directs readers to appropriate personnel
and documents for further inquiry;
- Development of a "due care plan," to be
kept onsite and made available to the
public electronically, that summarizes key
elements and responsibilities for
implementing the plan in a lay-accessible
manner;
- Measures to promote the long-term,
institutional and public memory of the
plan through activities designed to
promote awareness by students, staff and
the community, such as guest speakers and
dedication of a section of the school or
local library to the history of the site,
remediation strategies and oversight and
stewardship measures; and
- The establishment of regular reporting
mechanisms that publicly disseminate
information on the location of controls,
compliance status and monitoring reports
in a manner consistent with the notice
provisions discussed earlier and including
relevant local and tribal or state
environmental agencies. Included in this
should be testing reports that clearly
describe the purpose of the testing, sample
locations and collection procedures, and
analytical methods used. The release of
these reports should:
Be accompanied by a meaningful
opportunity for the public to provide
comment and meet with school
officials responsible for maintaining
the engineering controls; and
Target outreach and communications
about release of reports to parents and
school workers (should be notified
yearly about where and how to obtain
information about contamination,
remediation activities and ongoing
monitoring).
School building construction should begin only
after the state or tribal authority approves the
final long-term stewardship plan and determines
that the site is ready for construction. Engineering
controls may be implemented before, during or
after construction, depending on the type of
controls to be used.
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5.10. Stage 6: Long-term Stewardship
Exhibit 13: Stage 6: Long-term Stewardship
STAGE 6: Long-term Stewardship
1. Implement long-term stewardship plan
2. Incorporate key components of long-term stewardship plan into other
facilities and operational plans
Goto
Stage 4,
Stepl
t
3. LEAs and state or tribal environmental regulatory agency should conduct
periodic reviews of the effectiveness of remedial measures and
engineering and institutional controls used at the site
Implement
Remedial/Mitigation
Measures
Are remediation and
mitigation measures being
effectively implemented to
prevent school occupants'
exposures to environmental
hazards?
Maintain long-term stewardship to
ensure that contaminant levels are
\ safe for use of the school
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LEAs should incorporate key components of the
long-term stewardship plan into other facility and
operational plans and training materials for
principals, facility staff, groundskeepers and
contractors. The long-term stewardship
component of the school management plan
memorializes the remedial actions that were
performed, monitoring of well locations, the
standards to which the remediation was
performed, the location of material removed and
replaced, and tests and confirmatory sampling of
materials brought as replacement fill and any
wastes or material left capped in place. This plan
describes in detail the specific manner in which
institutional and engineering controls will be
employed in the future and by whom. The final
plan should clearly show figures and drawings of
those locations where soil or water quality
remains above residential use standards,
including as-built drawings depicting the
engineering control. The plan should clearly
define the roles and responsibilities for
maintaining the engineering controls, and these
responsibilities should be memorialized in an
institutional control such as a deed restriction that
stays with the property even when bought, sold or
donated. Where offsite sources of contamination
exist, area-wide partnerships may be an effective
tool to address contamination.
After the school project is complete and the school
is opened, the state or tribal environmental
regulatory agency should conduct a periodic
review of the effectiveness of remedial measures
and engineering and institutional controls used at
the site. Annual assessments of school sites may
also be required as part of a school facility
operation plan or long-term facility plan or as part
of local government master planning or
comprehensive plan updates and reporting. One
potential model for such reviews is the five-year
review EPA currently conducts for Superfund
sites. Five-year reviews61 (www.epa.gov/
superfund/cleanup/postconstruction/5yr)
61 U.S. Environmental Protection Agency, "Superfund Five-Year
Reviews." Last modified August 9, 2011. Available at:
http://www.epa.gov/superfund/cleanup/postconstruction/5yr.htm.
provide an opportunity to evaluate the
implementation and performance of a remedy to
determine whether it remains protective of
human health and the environment. These
reviews will also be useful in identifying new
sources of environmental hazards arising after
school construction and occupancy.
When employing institutional/engineering
controls, plans should be developed to address
issues that might arise. For example, the failure of
an institutional or engineering control should
trigger immediate notification by the LEA of the
staff, parents and community, as well as state or
tribal authorities. Actions may be needed to
ensure that students or staff are not exposed to
contamination. School emergency preparedness
plans should provide for ensuring that students
and staff will not be at risk in the event of the
failure of engineering controls. Plans should also
outline requirements for personnel to monitor
engineering controls, which might be a
combination of maintenance staff and
environmental engineers. Complaints or concerns
related to the performance of engineering and
institutional controls should be tracked and
responses to those complaints/concerns
documented.
To help ensure that the management of
institutional and engineering controls will receive
the attention they require, the procedures for
management of institutional and engineering
controls should be part of the school facility
operations procedures. The procedures should
include monitoring requirements, effectiveness
and integrity review requirements, any
performance review requirements (such as
calibration procedures) and documentation
requirements. Because these documents can be
challenging for a lay audience, a summary written
in plain language (and translated for non-English
speaking stakeholders) should be available to
community members. Routine monitoring,
reviews for the effectiveness and integrity of the
remedy, and reporting all need to continue for as
long as contamination levels do not meet safe
levels for use of the school.
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I Environmental Review Process
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6. Evaluating
Impacts of Nearby
Sources of Air
Pollution
6.1. Overview
This section provides guidance on assessment of
offsite environmental hazards during the
environmental review process (see Section 5.1). It
can be complex to measure and understand the
potential risks to school occupants that may be
associated with air emissions sources situated in
the vicinity of the proposed school location. The
local education agency (LEA) (see Section 10) and
school siting committee (SSC) (see Section 3.3)
should consider any potential impacts from
nearby sources of air pollution early in the
selection process. Airborne pollutants from
nearby emission sources can directly contaminate
the ambient air at the location or be deposited on
the site over time. Sources of these air pollutants
are varied, but most are human-made, including:
Mobile sources (e.g., cars, trucks and buses on
roadways; trains and rail yards; ships and port
facilities; planes and airport equipment);
Stationary major sources (e.g., factories,
refineries, power plants); and
Local area sources (i.e., collections of small
point sources, such as auto-body spray shops or
dry cleaners).
The Environmental Protection Agency (EPA)
identifies pollutants of interest in evaluating air
quality at a particular location either as criteria
pollutants or toxic air pollutants, also known as
hazardous air pollutants (HAPs).
Criteria pollutants refer to six common air
pollutants that are regulated through the
development of human health-based and
environmentally-based criteria (i.e., science-
based guidelines) that are used to set the
National Ambient Air Quality Standards
(NAAQS).62 They are particles (often referred to
as particulate matter), ground-level ozone,
carbon monoxide, sulfur dioxide (S02), nitrogen
dioxide (N02) and lead. States with areas where
ambient concentrations are above the NAAQS
(nonattainment areas) are required to develop
plans to bring them into attainment.
• Air toxics are pollutants that are known or
suspected to cause cancer or other serious
health effects, such as reproductive effects or
birth defects, or adverse environmental effects.
The current list of HAPs is available on EPA's
Technology Transfer Network Air Toxics
website, (www.epa.gov/ttn/atw/188polls) In
addition to this list, diesel emissions are
considered a mobile source air toxic. Brief
summaries of the pertinent toxicity information
on these HAPs and information on where more
comprehensive and primary data can be
obtained are located at www.epa.gov/ttn/
atw/hlthef/hapindex.
62 U.S. Environmental Protection Agency, "National Ambient Air
Quality Standards (NAAQS)." Last modified August 4, 2011. Available
at: www.epa.gov/air/criteria.
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As discussed in the Environmental Siting Criteria
Considerations (see Section 4) and Environmental
Review Process (see Section 5) sections, the initial
screen of potential locations for schools should
consider potential onsite and nearby
environmental and safely hazards. In general, the
LEA and SSC should seek to avoid locations that
are in close proximity to land uses that may be
incompatible with schools, such as those included
in Exhibit 6: Screening Potential Environmental
and Safety Hazards, particularly in cases where
acceptable alternative locations exist that may
pose fewer environmental challenges and still
meet other important school siting criteria.
If an LEA is considering locations that are in
proximity to air pollution sources that may pose
potential risks, an understanding of those
potential exposures and risks is essential. Due to
the many variables involved (such as those
included in Exhibit 5: Factors Influencing
Exposures and Potential Risks from Nearby
Hazards), assessing risks from air pollution is
inherently complex and should be performed by a
trained environmental professional with
monitoring, modeling and risk assessment
expertise. The overall process involves the
following components:
Thorough familiarity with the potential school
location's layout (see Section 6.2), including
local meteorology, topography and the land use
of the surrounding neighborhood;
• Initial assessment of existing air quality
monitoring and modeling information (see
Section 6.3) to gauge air quality in the
neighborhood around a potential school
location;
Development of an inventory of pollution
sources (see Section 6.4) and associated
emissions that may impact the air quality at a
location;
• Screening evaluation of potential air quality
(see Section 6.5) and, if feasible, health impacts
potentially associated with a location's air
quality based on modeling and/or monitoring
assessments; and
Development of an environmental assessment
report (see Section 6.6) containing descriptions
of activities, conclusions and recommendations.
Public involvement (see Section 3) is an important
part of evaluating the impacts of nearby sources of
air pollution. The LEA and SSC should inform the
public about the evaluation and give opportunities
for public comment on assessment reports and, in
cases where mitigation is needed, on potential
mitigation measures.
Examples of Local Air Toxics Monitoring
(www.epa.gov/schools/siting/resources)
EPA's Initiative on Assessing Outdoor
Air Near Schools: In 2009, EPA embarked
on an initiative to understand whether
outdoor toxic air pollution poses health
concerns to school children. This initiative,
"Assessing Outdoor Air Near Schools,"
(www.epa.gov/schoolair) is instructive
about some of the types of school air
monitoring efforts that have been
performed and provides useful examples
of assessing outdoor air near schools.
Community-Scale Air Toxics Ambient
Monitoring Projects (www.epa.gov/
ttn/amtic/local): Since 2003/2004, EPA has
conducted periodic Community-Scale Air
Toxics Ambient Monitoring grant
competitions to support state, local and
tribal communities in identifying and
profiling air toxics sources, characterizing
the degree and extent of local air toxics
problems, and tracking progress of air
toxics reduction activities. The Community-
Scale Air Toxics Ambient Monitoring
website has grant information, final project
reports and a training module, How to
Create a Successful Air Toxics Monitoring
Project, (www.epa.gov/ttn/amtic/airtox-
daw-2011.html#how)
Evaluating Impacts of Nearby Sources of Air Pollution
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6.2. Location Layout and Study
Area
The study area around a potential location will
vary with the land use (i.e., urban vs. rural), the
nature of nearby emission sources (i.e., major
stationary sources, mobile sources, area sources),
and the types of pollutants (i.e., gaseous or
particulate). The recommended screening
perimeters included in Exhibit 6 should be
considered as a rule of thumb for the
environmental professional. Depending on the
wind directions and the existence of large major
emission sources upwind of the candidate school
location (i.e., the direction of the prevailing wind
carries the air from around the source toward the
school), the environmental professional may need
to adjust the study area.
6.3. Initial Assessment of Area
Air Quality
An initial assessment of air quality around a
potential school location should make use of
existing data that is representative of conditions
in the neighborhood around the location.
Air quality monitoring can play multiple roles in
the initial assessment. Early in the assessment, the
environmental professional should evaluate local
air quality monitoring data as a means of initially
gauging air quality at a location. To facilitate
access to data on criteria pollutants, EPA's
AirExplorer website (www.epa.gov/airexplorer)
is an online collection of user-friendly tools for
visualizing and mapping air monitoring data.
AirExplorer allows users to download monitoring
data for monitoring sites in a specific area,
produce graphs of monitored air quality and
visualize locations using Google Earth. As an initial
screen of site conditions, monitored air quality
data at nearby stations may be compared to the
level of the NAAQS. Nearby monitoring data may
also be available for assessing air toxics at a
potential location. EPA's AirData website
(www.epa.gov/air/data) allows users to query
and map air quality data from locations across the
country. Compared to criteria pollutant
monitoring, air toxics monitoring data are
generally more limited in their coverage and in
the amount of time the monitors have been
operating. State, tribal and local air agencies may
also have local air quality monitoring data that can
be used in this initial assessment.
Existing air monitors will vary in the extent to
which they represent air quality at a particular
location. Monitors are more representative of a
potential school location when they share
similarities in the types of nearby sources, land
uses, topography and meteorological conditions
present. The environmental professional should
document the extent to which existing monitors
are likely to represent air quality conditions at a
candidate school location.
EPA's National-Scale Air Toxics Assessment
(NATA) (www.epa.gov/ttn/atw/natamain) is a
screening tool that provides modeled estimates of
average ambient air pollutant concentrations, and
associated cancer risk, across broad geographic
areas such as counties and states. NATA can be
used to identify and prioritize emission sources,
locations and pollutants of interest for further
study. However, NATA is not a definitive means
for pinpointing specific risk values at a site or
characterizing or comparing risks at local levels,
such as between neighborhoods or between
candidate school locations. Consequently, other
information sources are necessary to assist in
developing the initial assessment.
With available data in hand, the environmental
professional should conduct an initial assessment
of air quality conditions at the candidate location.
The environmental professional should note
whether local monitoring data are available for
both criteria pollutants and air toxics and when
available data are limited to NATA. An initial
screening assessment of air quality at the location
may include comparison of criteria pollutant
levels to the NAAQS and characterizing risks
associated with air toxics in and around the
potential location.
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If the environmental professional determines that
there is a basis for air quality concern due to high
ambient concentrations, or there is insufficient
information to determine whether a concern is
present, additional site-specific analyses
(description to follow) should be considered. For
environmental professionals needing more site-
specific air quality information, onsite monitoring
or local air quality modeling should be considered.
Air monitoring and modeling are complex and
expensive to conduct. For the monitoring and
modeling to provide accurate and relevant
information, the activities must be appropriately
performed. The assessment plan and the results
should be clearly communicated to stakeholders
before, during and after completion of the
monitoring and/or modeling.
The following steps pertain to refined site-specific
analyses that may be performed.
6.4. Inventory of Air Pollutant
Sources and Emissions
The environmental professional should develop or
obtain an inventory of all the potential pollution
sources, both large and small, within the study
area. Developing the inventory should include
consulting with the state, tribal or local air agency
(e.g., permits, monitoring) and EPA Regional
Offices (www.epa.gov/aboutepa/index.html
#regional) to determine what data resources may
be available that can provide additional
information for inventory development. The state
agencies (www.epa.gov/air/where) are
particularly useful in that they may have
emissions data or other studies that are not
reported at the national level. When local
information is unavailable from state, tribal or
local air agencies, other information sources can
be used, such as EPA's AirData website,
(www.epa.gov/air/data) which queries large
national databases such as the National Emission
Inventory (NEI) (www.epa.gov/oar/data/neidb)
and allows users to download emission data on
local sources permitted to emit criteria pollutants
and air toxics. At a minimum, this pollutant
inventory should include:
• The name of each point and industrial area
source;
A description of the source (e.g., point source,
mobile source, fugitive emission, major or area
source); and
The distance from the source to the study area.
For point and industrial area sources, also include:
Their locations (i.e., street address,
latitude/longitude);
• The ongoing activity at the source;
The pollutants emitted or released (i.e., criteria
pollutant, or chemical name and Chemical
Abstracts Service number for toxics); and
The emission rate of each pollutant (e.g.,
pounds/year or tons/year).
Highways and other transportation facilities may
be nearby emission sources. However, detailed
emissions information is often not readily
available for these sources, and mobile source
inventories are usually developed by allocating
emission factors from broad geographic areas
using estimated values. As such, when assessing
nearby transportation sources, local data on
activity such as use (e.g., vehicles per day, trains
per day) and time of operations (e.g.,
morning/evening rush hours for highways, ship
and truck activity in ports) should be collected
and applied to emission rate estimates to develop
local inventories. The NATA (www.epa.gov/ttn/
atw/natamain/) and NEI (www.epa.gov/
oar/data/neidb) databases may also contain
information on some transportation facilities in an
area. The environmental professional should
consult with transportation and urban planning
agencies to identify the location and activity of all
transportation facilities in the area, such as state
departments of transportation and metropolitan
planning organizations for metropolitan areas
with at least 50,000 residents. These
organizations can also provide information on
future planned infrastructure in the area that may
impact air quality around the school location.
Evaluating Impacts of Nearby Sources of Air Pollution
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More information on considering nearby
highways and other transportation facilities,
including goods movement (see Section 8.2), is
included in the Quick Guide to Environmental
Issues (see Section 8).
The environmental professional should recognize
that all databases have limitations. They may not
be up-to-date; they may not have the most
accurate location information for some of the
sources in the study area; or they may not identify
all the potential sources in the study area. Also,
the data contained in these databases may be
aggregated at some larger level (e.g., county or
state level) and lack the necessary detail for the
study area. Therefore the environmental
professional should be prepared to utilize
additional methods, such as an on-the-ground
visual survey, often called a "windshield survey,"
to complete the pollutant inventory.
A windshield survey is extremely valuable for
identifying those sources not available through
national and regional databases and agencies,
identifying new sources that have recently opened
near the location, and verifying whether sources
identified in the initial database reviews are still
operating. The survey can be informed by maps,
aerial photographs, online resources and local
government records (e.g., utility records, tax
records). Also, documents, such as the South Coast
Air Quality Management District's "Air Quality
Issues in School Site Selection Guidance
Document," (www.aqmd.gov/prdas/aqguide/
doc/School_Guidance.pdf) can provide the
environmental professional with useful guidance
for identifying general categories of emission
sources for inclusion in the survey.
If new sources are discovered during the
windshield survey, or if modifications are
observed in known sources, the environmental
professional should contact the state or tribal air
agency and the EPA Regional Office to fill in data
gaps. If source-specific emission details are not
available, these agencies may recommend
surrogate parameters (e.g., emissions profiles and
emission rates) to help complete the inventory. To
quantify the extent of emissions from nearby
roads and other sources, emission models may be
employed. For example, the environmental
professional can use EPA's Motor Vehicle
Emission Simulator (MOVES) (www.epa.gov
/otaq/models/moves/index.htm) to calculate
emission rates for individual road links, and EPA's
AP-42 (www.epa.gov/ttnchiel/ap42/) can be
used for stationary and area sources.
In interpreting the impact of nearby sources on a
school location, it is helpful to evaluate
meteorological conditions present at the
prospective location. For instance, potential
school locations that are situated predominantly
downwind of an air pollution source may realize
greater impacts than those that are located
upwind of the source. However, even if a potential
location is situated upwind of a source based on
historical wind data, there will still be occasions
when the location will be downwind of the source.
In addition, for highways and other traffic sources,
pollutants can travel upwind of the road because
of air flows created by the vehicles operating on
the roadway. Thus, for roadway sources, there
may not be a significant difference between
upwind and downwind locations with regard to
air pollution impacts.
Based on the inventory and on professional
judgment pertaining to the many factors
influencing exposures and potential risks (see
Exhibit 5), the environmental professional should
determine whether there is reason for initial
concern related to air pollutant exposures at the
location and determine if onsite ambient air
monitoring is warranted prior to choosing the
location.
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6.5. Screening Evaluation of
Potential Air Quality
6.5.1. Local Air Quality Modeling
If the environmental professional determines that
additional information pertaining to local air
quality beyond that developed in the initial
assessment is needed, air quality modeling may be
considered as a means to provide this information.
In particular, dispersion models are tools that
calculate the air quality impacts of nearby sources
at downwind locations. They may be used to
model ambient concentrations of both criteria
pollutants and air toxics and to estimate the
magnitude of nearby sources' impacts on air
quality at a given location.
Dispersion models require information on
emission rates of nearby sources (from an
emission inventory (see Section 6.4) as previously
discussed), meteorological conditions at a
location, and information on terrain and land use
in the vicinity of the candidate location. There are
two major categories of dispersion models:
screening models and refined models.
Screening models estimate the maximum
likely impacts of a given source, generally at the
receptor with the highest concentrations. These
models are intended to eliminate the need for
more detailed modeling in cases that will clearly
not create ambient concentrations of concern.
For many sources in simple terrain, the
SCREENS (www.epa.gov/ttn/scram/
dispersion_screening.htm) model may be used
to estimate maximum ground-level
concentrations resulting from a single source.
For roadways and intersections, the CAL3QHC
model (www.epa.gov/ttn/scram/dispersion_
prefrec.htm#cal3qhc) may be used to estimate
likely maximum concentrations at locations
nearby.
Refined models use detailed local information
and simulate detailed atmospheric processes to
provide more specialized and accurate
estimates of how nearby sources affect air
quality at downwind locations. Relative to
screening models, refined models can require a
significant investment of time and resources to
conduct a proper analysis. AERMOD
(www.epa.gov/ttn/scr am/dispersion_prefrec.ht
m#aermod) is EPA's general-use model
recommended for a wide range of sources in all
types of terrain. For most situations, AERMOD is
an appropriate model for estimating the impact
of nearby sources on air quality near a potential
location.
6.5.2. Onsite Air Quality Monitoring and
Risk Analysis
If the environmental professional determines that
onsite monitoring is warranted, and upon
authorization by the LEA, the environmental
professional should develop and implement an
onsite air quality monitoring and analysis study.
The objective of the study is to determine whether
the targeted air pollutants identified in the
inventory are present at the location in
concentrations that may pose either short-term or
long-term health risks to children or adults that
may utilize the school facility. Monitoring can also
capture impacts from sources that were not
explicitly included in any local scale modeling,
including unreported or unidentified sources.
Ambient air monitoring, however, is costly in
terms of the time, resources and technical
expertise required to generate meaningful data.
To minimize these costs as much as possible, a
short-term monitoring approach can be used as an
initial screen to determine if a location is suitable
for future development. In addition, passive and
other portable sampling techniques can also be
used in screening monitoring to compare and
evaluate multiple potential school locations.
Throughout the monitoring activity, the
environmental professional should review the
monitoring and analysis procedures to confirm
compliance with the appropriate quality
assurance and quality control (QA/QC) protocols
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and assess local meteorological conditions during
monitoring activities to identify any possible
impacts on the sample collection. There are a
number of studies and programs described on
EPA's website that provide examples of local
monitoring activities. EPA's "Assessing Outdoor
Air Near Schools" (www.epa.gov/schoolair)
Initiative provides useful guidance for this
approach relative to air monitoring and the
determination of potential adverse health impacts.
EPA's Community-Scale Air Toxics Ambient
Monitoring Projects (www.epa.gov/ttn/amtic/
local) website should also be consulted for
recommendations on conducting air toxics
monitoring analyses. Both websites include
information on QA project plans for outdoor air
monitoring. The NO2 near-road monitoring
website (www.epa.gov/ttnamtil/nearroad)
provides some information on pilot studies
conducted at several cities in the United States
using passive sampling devices.
6.5.3. Development of Pollutant Specific
Screening Criteria
An important step in determining a location's
acceptability is the identification of a set of
screening criteria for each of the targeted air
pollutants. These criteria should be protective of
children's health. As discussed in Principle 1 (see
Section 1.4.1) in the About the Guidelines (see
Section 1) section, children are more vulnerable to
environmental exposures than adults.
For criteria pollutants, these criteria may be based
on comparison with the relevant NAAQS. For air
toxics, the criteria should screen for the potential
of adverse health effects resulting from both
short-term (i.e., acute) and long-term (i.e.,
chronic) exposures at the location. If using a
dispersion model to assess potential exposures,
the output should be formatted to reflect the
averaging times relevant to the screening criteria.
In a short-term monitoring study, established
reference concentrations, dose-response
assessments or other similar benchmarks may not
be available for all of the pollutants
detected. Consequently, the environmental
professional may need to employ other
approaches to identify appropriate screening
criteria, including the development of surrogates
for use in lieu of established acute values. The
environmental professional will also need to
evaluate the air sampling data for potential
adverse health impacts resulting from chronic
exposures to pollutants at the location. Therefore,
the environmental professional should develop
health-based screening criteria that can be used as
long-term comparison levels. The development of
suitable screening criteria for chronic exposures
depends on the availability of two different types
of long-term comparison levels:
A cancer-based comparison level that is an
estimated continuous (i.e., 24 hours per day,
365 days per year) exposure concentration set
at an acceptable lifetime cancer risk. EPA
typically considers lifetime cancer risks in the
range of 1 in one million to 100 in one million to
be acceptable. In some situations, other
acceptable risk levels could be appropriate.
A noncancer-based comparison level, such as
the reference concentration or a comparable
value, which is the estimated continuous (i.e.,
24 hours per day, 365 days per year) exposure
concentration considered likely to be without
adverse effects over a lifetime.
In deriving the chronic screening criteria, priority
should be given to the use of relevant and
appropriate air standards (e.g., the NAAQS) as
well as EPA's risk assessment guidance and
precedents. Data from EPA's Integrated Risk
Information System (www.epa.gov/iris/) can also
be used to derive the appropriate screening
criteria. Integrated Risk Information System
contains both Inhalation Unit Risk values for
chemicals with carcinogenic effects and reference
concentrations for chemicals with chronic,
noncancer health effects. Other data sources can
be found on the following websites:
EPA Office of Air's Technology Transfer
Network Air Toxics (www.epa.gov/
ttn/atw/toxsource/summary);
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California Environmental Protection Agency
Office of Environmental Health Hazard and
Assessment (www.oehha.ca.gov/air);
Texas Commission on Environmental Quality
(www.tceq.texas.gov/toxicology);
New Jersey Department of Environmental
Protection (www.state.nj.us/dep/daq/); and
Agency for Toxic Substances and Disease
Registry (www.atsdr.cdc.gov/mrls).
An example of how both acute and chronic
screening criteria have been established for
previous air toxics monitoring studies can be
found at www.epa.gov/schoolair/pdfs/
UsesOfHealthEffectsInfoinEvalSampleResults.pdf.
6.5.4. Evaluation of Potential for Adverse
Acute and Chronic Health Impacts
With analytical results in hand and screening
criteria in place, the environmental professional
can begin an evaluation of the location's potential
air quality impacts on acute and chronic health
effects. Those sample results showing pollutant
concentrations less than the screening criteria
indicate acceptable air quality and do not require
further action. Those pollutants determined to be
present at concentrations above the screening
criteria should be flagged for further
consideration in the final report.
When evaluating onsite monitoring data, the
environmental professional will also need to
consider the potential impacts of the location's
meteorology on any samples collected. This will
require comparing the meteorological data taken
on actual sampling days against those data taken
onsite over all the days within the monitoring
period, as well as available data from a nearby
weather station. This will enable the
environmental professional to determine the
representativeness of the samples collected with
respect to what might be expected over the longer
term.
For an example of how to compare monitored
values to acute and chronic screening criteria, go
to the school air toxics monitoring project at
www.epa.gov/schoolair/pdfs/UsesOfHealthEffect
sInfoinEvalSampleResults.pdf.
When several locations are being considered, a
comparison of potential health impacts at
alternative locations may help in identifying the
location with the lowest risk.
6.6. Development of an
Environmental Assessment
Report
After completing the comparison, the
environmental professional should prepare and
submit an environmental assessment report.
When developing recommendations for the
report, the environmental professional will need
to consider and weigh a variety of factors. Among
these is the fact that the screening levels were
developed specifically to be conservative
indicators of the risk of an adverse health effect.
Exposures at or above a specific screening level do
not necessarily indicate that a risk exists; rather it
indicates that as exposures increase above an
indicator, there is an increasing potential for risk
of adverse health effects.
Taking into account these factors and the results
from the environmental assessment, the final
report may include one of several
recommendations. If no pollutants of concern
have been identified at concentrations greater
than the acute or chronic screening criteria, the
report may conclude that the location is
acceptable from an air quality perspective. In
those instances in which either or both of the
acute or chronic screening criteria are exceeded
by a pollutant, the report may conclude that the
location is unacceptable from an air quality
perspective or that additional measures (e.g.,
additional monitoring, site-specific risk
assessment) are required. If no candidate
locations are available that are without air quality
concerns, the report should describe what
mitigation options may be available for the
candidate school location.
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At a minimum, the final report to the LEA and SSC
should describe and discuss the following:
• Study area, including the sources, activities and
emissions located within area boundaries;
• Pollutant inventory process, including the
identification of the pollutants targeted for
monitoring;
Modeling approach and modeled
concentrations for locations in and around the
site;
Monitoring approach and results, including
actual measured pollutant concentrations,
projections of potential longer term
concentrations and a comparison of these
concentrations against national and regional
averages;
Acute and chronic screening criteria,
including the process for selecting and/or
deriving the criteria;
• Comparison of pollutants against the
screening criteria, including potential health
effects and toxicity information for those air
toxics determined to be at the location;
• Potential for multipollutant impacts in those
cases where multiple pollutants have been
detected at levels above or just below their
respective comparison levels;
Identification and evaluation of potential
contributing sources;
Conclusions and recommendations for next
steps; and
Impacts of the uncertainty and limitations
associated with the recommendations arising
from limited sampling, location meteorology,
available toxicity information, etc.
The draft report should be made available for
public comment, as described in the Meaningful
Public Involvement, Section 3. The environmental
professional should consider public comments in
drafting the final report.
The LEA and SSC should review the environmental
professional's report and the public comments
received on the report and, in light of other
assessments being performed at the location,
determine next steps. To further clarify its
options, the LEA may elect to have the report
reviewed by a third party, such as a state, tribal or
federal agency, with expertise in the subject area.
In addition, the LEA may choose to identify and
evaluate actions (regulatory or otherwise) being
taken or planned nationally, regionally or locally
that may achieve emission and/or exposure
reductions in an acceptable time frame. The
decision about next steps should be based on the
weight of evidence supported by the
environmental professional's report, other data
developed during the environmental review
process (see Section 5.1), and the potential for
future reductions in exposure
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7. Recommendations
for States and Tribes
7.1. Overview
State and tribal involvement and oversight offers
many opportunities to enhance the work of local
education agencies (LEAs) (see Section 10) and
school siting committees (SSCs) (see Section 3.3)
in identifying potential sites or structures for
schools. This section identifies important steps
that states and tribes can take to enhance the
capacity of local communities to identify locations
for schools that enhance the educational process
by providing a safe and healthy environment for
children, teachers and staff.
7.2. Recommendations for
States
States often play an important role in community
school site selection decisions, depending on state
legislation, regulations and guidance. A number of
states (see Section 5.2.1) have developed
comprehensive school siting policies, including:
California: www.dtsc.ca.gov/schools/
index.cfm;
New Jersey: www.nj.gov/dep/
dccrequest/; and
Washington: www.ecy.wa.gov/
programs/sea/sepa/e-review.html.
At a minimum, state agencies are important
resources for communities on siting issues. For
example, states often serve as a central repository
for expertise in the many complexities associated
with choosing the best possible site. This is often
the result of promulgated legislation, state
regulations or state-specific recommendations
related to issues that are relevant to school siting
decisions. While individual LEAs may have limited
resources for investing in their own specialists,
states may be able to help defer the costs of such
expertise through centrally located resources that
can be made available to all state LEAs. For
example, a state-wide listing of environmental
professionals licensed or registered with a central
state agency can serve as an important resource
for LEAs needing highly qualified and well-
respected onsite evaluation of potential sites or
buildings.
Policies that Impact the Siting of
Potential Sources Near Schools
States, tribes and localities should
evaluate siting and permit processes that
influence where potential sources of
environmental pollution (see Source
categories identified in Exhibit 6:
Screening Potential Environmental and
Safety Hazards) may be allowed to locate
with respect to schools. While these land
use decisions are highly complex and
beyond the scope of these guidelines,
states, tribes and communities should
seek to avoid situations in which new
nearby sources of potentially harmful
pollutants are sited in such close
proximity to schools that they may pose a
potential hazard to the school occupants.
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Because land for development is becoming less
available in many states, officials at the state level
in these states often develop comprehensive state-
wide or regional land use and development plans.
Working together, LEAs and state officials can
effectively coordinate to identify appropriate
lands for locating schools. Establishment of state-
wide school siting policies and guidelines, where
they are not currently in place, can help states
promote educational, environmental, health and
safety objectives associated with school facility
construction and renovation. In some cases, states
have programs in place that allow them to
partially fund projects that meet state school
siting guidelines.63
7.2.1. State Resource Review
Many state agencies have expertise that can
contribute to sound school siting decisions and
implementation, including departments of
education, public health, transportation, planning,
parks, community development, historic
preservation and environment. Different agencies
will likely have staff with complementary
knowledge, expertise and skills that can be helpful
in various parts of the school siting process.
However, it may be challenging for LEAs and local
community residents to know which agencies to
contact for specific concerns and questions. States
are encouraged to share the expertise, available
assistance, state-level contacts and
responsibilities they have across agencies, and to
assign an office or agency to serve as the liaison
for school siting questions and assistance. In doing
so, states can review whether there are adequate
staff resources with appropriate expertise in place
to assist local communities with school siting
decisions and planning processes and develop a
plan to support local school siting efforts,
including addressing gaps in staffing and
resources as necessary.
Two of the ways states can support local
communities in the selection of potential school
63 For more information on existing state policies, see "50 State
Survey," conducted by Rhode Island Legal Services. Available at:
www.childproofing.org/school_siting_50_state.htm.
sites are to provide information from existing site
inventories to LEAs and to develop policies to
support local communities making school location
decisions. In addition, states are encouraged to
partner with LEAs to build capacity to effectively
manage waste or contamination that remains
through the implementation of engineering and
institutional controls (see Section 8.15) and long-
term stewardship (see Section 8.16).
There are several important steps that states can
take to support development of local capacity for
identifying appropriate locations for schools:
• Improved coordination across state programs
(see Section 7.2.2);
• Staffing and financial resources
(see Section 7.2.3);
• Participation in public meetings
(see Section 7.2.4); and
• Access to state information on school siting
(see Section 7.2.5).
7.2.2. Improved Coordination across State
Programs
Many existing state programs have the capacity to
support local land use decisions related to the
siting of schools. States are encouraged to enhance
coordination across state programs to assist local
communities with school siting decisions. Some
key factors for states to consider include:
Whether the existing state program
management structure is able to perform the
necessary coordination and supervision
between agencies needed to support LEAs in
making school siting decisions;
Which state and/or local agencies can
contribute to school siting and the
responsibilities of each agency; and
Whether there are legal and institutional
impediments that need to be addressed.
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Effective coordination across state programs can
help to ensure that the programs with
responsibility, knowledge and expertise in healthy
schools issues are engaged in the school siting
process. A state should consider identifying a
point of contact with responsibility for
coordinating across state agencies with
authorities, responsibilities, programs, policies,
guidelines or standards affecting decisions
concerning whether and where to build new
schools or carry out major expansion of existing
facilities, as well as coordinating other school
facility issues. States are also encouraged to
coordinate with local and regional planning
agencies to ensure locations selected for schools
meet multiple community goals.
Many states have processes to determine
appropriate land and resource uses for sites that
have residual contamination after cleanup; these
processes may already apply to school siting or
may be expanded to apply to school siting
decisions. State inventories of assessed or
remediated locations or structures as well as
those undergoing or planned for assessment and
cleanup may be useful to share with LEAs and
other state, public or private entities to ensure
safe reuses. It is essential that the agency and
department responsible for reviewing potential
school sites for potential environmental
contamination be identified early in the siting
process so that they will be appropriately
involved.
Local governments with robust environmental,
planning and health departments often bear
primary responsibility for managing
environmental health or contaminated site
cleanup programs. However, in many parts of the
country, local government resources to support
school siting decisions are very limited or perhaps
may not even exist. In these cases, the state
government frequently provides assistance to the
local agency or identifies a suitable third party to
manage efforts to determine appropriate land and
resource uses for properties with residual
contamination. These activities are particularly
important in situations where schools may be
constructed on sites with residual contamination
to ensure proper maintenance and oversight for
any necessary engineering or institutional
controls or long-term monitoring.
States may want to consider developing a formal
memorandum of understanding between agencies
to ensure that staff resources and expertise are
available to assist with school siting. For example,
the Iowa Department of Historic Resources has a
memorandum of understanding with the Iowa
Department of Education to provide information
about older and historic schools.64
7.2.3. Staffing and Financial Resources
An assessment of the human and financial
resources available in state agencies to support
local school siting decisions should address the
following questions:
How can staff with the appropriate expertise
assist local communities with school siting
decisions and planning processes; and
How can budgetary or other resource gaps be
overcome to safely renovate or site schools?
7.2.4. Participation in Public Meetings
State government representation at meetings with
the community is important when the state has
oversight responsibilities for environmental
cleanup or reuse planning. Even when oversight
responsibilities have been delegated to local
agencies, state government participation can be
helpful to ensure that the review process is sound
and that communications with the community are
effective and to reinforce that the special
sensitivities of children were considered as part of
the school location selection process.
64 State Historical Society of Iowa, "Historic Preservation." Accessed on
September 16, 2011. Available at: www.iowahistory.org/historic-
preservation/.
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7.2.5. Access to State Information on School
Siting
States should consider developing a publicly
available, easily accessible website/database to
provide a centralized source of information
pertinent to school evaluation and selection,
including:
Policies and procedures for site location
evaluation and review, including state-specific
guidance for evaluation of candidate sites, if
available;
Public involvement guidelines;
Mapping and other resources to assist in
evaluation of potential school locations;
Records of location reviews (e.g., findings,
description of site remediation activities,
institutional and engineering controls, decision
documents for cleanup and documentation of
sites that meet standards for residential use);
and
Surveys of historic properties, including
schools, case studies and awards given for
historic renovation, reports about costs of
renovation vs. costs of new construction.
7.2.6. State Oversight Roles
State environmental regulatory agencies may
oversee assessment and cleanup activities for
properties enrolled in their voluntary cleanup
programs. Many states have adopted risk-based
cleanup actions and determine level of cleanup
needed based on proposed reuse. Institutional
control tracking programs may be a part of their
program oversight as well. However, this state
regulatory oversight does not relieve the LEAs or
private property owners of their responsibility to
manage their property, monitor and maintain land
use controls and ensure safe site reuse.
Environmental evaluation
LEAs should work with state governments to
ensure all sites proposed for construction of new
schools, renovation of an existing building for
school use or expansion of existing schools have
received appropriate environmental approval
from the state agency prior to construction. Sites
should be assessed prior to acquisition or
donation to determine if there is potential
environmental contamination onsite or at
neighboring sites that could pose health or
environmental risks to children, faculty or staff,
and for their impacts on transportation, air quality
and accessibility.
Where proposed sites adjoin or abut a location
that has environmental or public health concerns,
LEAs should seek out the appropriate planning,
environmental and health review to ensure that a
potential site would be an appropriate and safe
location for a school.
Cleanup procedures
Although most states do not have school siting
procedures that specifically apply to site
investigation, sampling, cleanup, determination of
appropriate land and resource uses and long-term
stewardship, many do have these policies and
practices in place that apply more generally to
sites being considered for reuse. In general,
cleanups are tailored to meet the intended reuse.
Locations which are to be used for schools should
be cleaned up to levels that support residential
use. In the event that residual contamination
remains on the site, engineering and institutional
controls to prevent exposure and a clear,
documented long-term stewardship plan should
be in place at the location. For more information
see the Environmental Review Process, Section 5.
Meaningful public involvement
Meaningful public involvement (see Section 3)
throughout the school siting process is of critical
importance. Plans for public involvement should
be formalized prior to initiating the identification
of potential school sites. Details of site assessment
processes, findings, cleanup decisions (e.g., scope,
procedures, findings), land use restrictions
(engineering and institutional controls, see
Section 8.15) and subsequent school construction
plans should be provided to the public and subject
to community involvement and public notification.
108 I Recommendations for States and Tribes
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It is important for LEAs to develop a
communications plan to ensure effective public
involvement (see Section 3.4).
Local capacity to manage institutional and
engineering controls
States should establish standards to assess the
capacity of any party for management of
institutional or engineering controls at potential
school locations. The standards should be
designed to ensure the long-term integrity of any
institutional or engineering controls put in place
at potential school sites where residual
contamination or offsite hazards to be mitigated
exist. The capacity to manage engineering and
institutional controls should consider the
following:
Availability of accurate information on the
location or extent of institutional and
engineering controls, perhaps provided on a
map;
Establishment of, and participation in, a one-call
system (see Section 10) to protect against
human exposure to contaminated soil;
Establishment of a mandatory monitoring
program to routinely review institutional and
engineering controls to ensure their continued
effectiveness;
Establishment of enforceable institutional
controls, which require compliance;
Establishment of informational institutional
controls that effectively disseminate
information on the location of controls,
compliance status and monitoring reports to
interested stakeholders, especially parents,
state and local environmental officials;
Long-term budget commitment to provide
funds for the operation and maintenance of
institutional and engineering controls, including
required training of staff responsible for
maintaining controls;
Tracking of expenditures associated with
institutional and engineering controls by the
LEA so that historical expenditures can be used
to refine planning estimates for the cost of
maintaining institutional and engineering
controls;
Using more than one institutional control (i.e.,
"layering") to improve overall reliability and
effectiveness for managing the amount,
concentrations, toxicity and other
characteristics of the residual waste or
contamination; and
Availability of a process to report malfunctions
of controls.
7.2.7. State Policy Review
States are encouraged to review existing laws,
policies and regulations addressing school siting
to determine whether changes are needed to
encourage improved school siting decisions. Such
a review of existing policies across state agencies
would help identify gaps and outdated policies
that no longer serve state goals and objectives.
Education, health, environmental, planning, and
transportation agencies, as well as others, such as
the State Historic Preservation Officer, should
work together to consider how existing
regulations, policies and guidelines influence or
affect decisions about school renovation,
remodeling or the siting of new schools. Review of
existing guidelines or policies may focus on those
related to the following general topics:
Community involvement and public
participation in school siting and renovation
decisions;
Long-range school facilities plan;
School funding of new construction or to
support existing school renovation;
Prohibitions on state reimbursement of land
costs that force communities toward the lowest
cost sites, regardless of potential environmental
challenges;
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School size formulas or requirements for lot
size and access to recreational areas;
• Minimum school enrollment requirements;
• Environmental evaluation and associated costs;
Environmental cleanup (including cleanup
standards and long-term stewardship site
controls) and associated costs;
• Community use of schools (and joint use of
community resources such as libraries,
theaters, parks and ball fields);
Energy efficiency;
Sustainable development; and
Emergency preparedness and sheltering plans.
States may also consider developing policies,
guidelines or regulations with local health
jurisdictions to involve them in approval of school
sites, and states should provide local communities
with information related to state policies that
pertain to siting decisions.65
Public health policies should promote school sites
that do not lead to harmful environmental
exposures and that do facilitate physical activity,
healthy behaviors and healthy communities.
Schools located in the neighborhoods of the
students they serve will have an increased
number of children who walk, bike or take public
transit to and from school and will provide
families with access to playgrounds and facilities
that encourages physical activity outside of school
time. Policies related to environmental review
should facilitate assessment of locations before an
LEA purchases or leases a property. State policies,
laws and regulations can promote these goals in a
number of ways, including:
• Encourage the creation of long-range school
facilities plans (see Section 4.2.1) by LEAs,
including LEA guidance on how these plans can
65 For more information on existing state policies, see "50 State
Survey," conducted by Rhode Island Legal Services. Available at:
www.childproofing.org/school_siting_50_state.htm.
involve stakeholders and community members
and complement comprehensive plans and
other planning efforts at the municipal (and
state) levels. One resource is California's Guide
to Long-Range Facilities Plan (www.cde.ca.gov/
Is/fa/sf/longrangeplan.asp);
Do not require minimum number of acres
for school sites. Acreage requirements can
prevent LEAs from using smaller sites within
neighborhoods and force them to build schools
on large tracts of lands on the outskirts of
communities. The Council of Educational
Facility Planners International
(www.cefpi.org/) has abolished its "minimum
acreage standards" policy but many states still
have now-outdated laws based on this policy in
effect;
Encourage communities and LEAs to plan
and develop joint use agreements for
libraries, parks and ball fields for efficient use of
available land;
Do not favor larger enrollment schools,
which are challenging to build within
neighborhoods, in formulas for education
funding allocations;
Do not favor new construction over
renovation of existing schools in school
construction funding formulas (often called the
two-thirds rule or "60 percent" rule).
Renovation and modernization could help
achieve educational objectives by creating
school environments that support improved
academic achievement by helping to alleviate
the backlog of repair and maintenance projects.
In a study conducted in the Los Angeles Unified
School District (www.edfacilities.org/pubs/
LAUSD%20Report.pdf), researchers found that
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improvements in the quality of school facilities
led to an increase in student performance;66
Consider true long-term costs of a site
assessment/investigation, including land
acquisition, initial construction, long-term
busing costs and other transportation costs,
improvements to the utilities and street
network around the school, long-term site
location monitoring and maintenance costs in
policies on estimating costs for renovation
versus construction;
Encourage efficient location of schools and
judicious use of busing through school busing
reimbursement formulas and busing radius
policies;
Consider "walkability" infrastructure (e.g.,
adequate sidewalks, absence of traffic hazards,
safe routes to schools);
• School funding mechanisms at the state level
should allow time for proper analysis and
consideration of suitable sites for construction,
particularly at sites where environmental
concerns are involved;
• Provide technical support to LEAs during the
environmental review. Policies of state health
and environmental agencies should allow for
and encourage LEAs to partner with state
agencies in conducting a thorough
environmental review; and
Encourage public involvement throughout
the siting process.
In addition to policies related to environmental
review and cleanup, relevant policies include
those that promote public health and take into
account the impact of proposed or existing offsite
sources on existing schools.
66Jack Buckley, Mark Schneider and Yi Shang, "LAUSD School
Facilities and Academic Performance," Los Angeles Unified School
District, Unpublished report prepared as part of Building Educational
Services Together initiative, 21st Century School Fund, Washington,
DC. Accessed on September 16, 2011. Available at:
www.ncef.org/pubs/LAUSD%20Report.pdf.
7.3. Recommendations for
Tribes
Tribes are sovereign entities and play a central
role in community school site decisions when an
existing or potential school site is situated in
Indian country or on other tribal lands. This role
may also depend on what type of school is being
built, and whether a community, tribal or Bureau
of Indian Education school is on trust or tribal
lands. School siting decisions on tribal lands may
also depend on federal and tribal legislation,
regulations and guidance or memoranda of
understanding with state and local governments.
Tribal government coordination with federal,
state and local governments, as appropriate, is
also desirable. Tribal agencies can be critical
resources for communities on siting issues.
In cases where tribal members attend schools
outside of Indian country, tribes will want to
coordinate with state and local governments
about siting nearby schools. The balance of this
section will focus on situations where schools are
being sited inside Indian country.
In addition to the critical role of the local school
siting committees (SSCs) (see Section 3.3) in
identifying potential sites for new school
construction, tribal involvement and oversight
offers many advantages. For example, tribes can
be a central repository for expertise in the many
nuances associated with choosing the best
possible site, thereby ensuring that the site will
not only be suitable from the perspective of
environmental health and safety, but will also
respect the local traditions and customs of the
community.
Working together, LEAs and tribal level officials,
possibly in conjunction with states, can more
effectively coordinate to determine appropriate
lands for locating schools. Establishment of tribal
school siting policies and guidelines, where they
are not currently in place, can help tribes promote
educational, environmental, health and safety
objectives associated with school facility
construction and/or renovation.
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7.3.1. Review Tribal Expertise
Tribal councils and/or several tribal agencies,
including departments of education, public health,
transportation, historic preservation and
environment, can play an important role in school
siting decisions and implementation along with
local governments. Different agencies will likely
have staff with complementary knowledge,
expertise and skills that can be helpful throughout
the school siting process. Tribes are encouraged to
share existing inventories of contaminated sites
with local communities to assist with assessment
of potential school locations
(www.epa.gov/schools/siting/resources) and to
help to identify locations that may require the use
of engineering and institutional controls (see
Section 8.15) and development of a clearly
documented long-term stewardship plan to meet
standards for residential use. Local residents may
not know which agency to contact for specific
concerns and questions, so tribes are also
encouraged to coordinate across programs and to
assign an office or agency to serve as the liaison
for community members.
There are several important steps that tribes can
take to support development of local capacity for
identifying appropriate locations for schools:
• Coordination across tribal programs
(see Section 7.3.2);
• Staffing and financial resources
(see Section 7.3.3);
• Participation in public meetings
(see Section 7.3.4); and
• Access to information on school siting
(see Section 7.3.5).
7.3.2. Coordination across Tribal Programs
Enhanced coordination across tribal programs
with responsibility for healthy schools can play an
important role in informing local school siting
decisions. Among the institutional questions that
tribes should consider with respect to school
siting are:
Which tribal or other agencies need to be
involved in school siting; and
• Are there legal or institutional impediments
that need to be addressed?
Some tribal governments have established
processes to determine appropriate procedures
for addressing sites that have residual
contamination after cleanup. In other cases, tribes
work with federal partners to address these
issues. It is essential that the agency and
department responsible for reviewing potential
school sites for potential environmental
contamination is identified early, so that they will
be appropriately involved throughout the siting
process. Tribes are also encouraged to coordinate
with local and regional planning agencies to
ensure locations meet multiple community goals.
Tribes are encouraged to identify a point of
contact with responsibility for coordinating across
agencies with authorities, responsibilities,
programs, policies, guidelines or standards
affecting decisions concerning whether and where
to build new schools or carry out major expansion
of existing facilities, as well as coordinating other
school facility issues.
Tribes may want to consider developing a formal
memorandum of understanding with different
government agencies (federal, state, local) to
ensure that staff resources and expertise are
available to assist with school siting.
7.3.3. Staffing and Financial Resources
An assessment of the human and financial
resources available in tribal agencies should
address the following questions:
How can staff with the appropriate expertise
assist local communities with school siting
decisions and planning processes; and
How can budgetary or other resource gaps be
overcome to safely renovate or site schools?
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7.3.4. Participation in Public Meetings
Tribal government meetings with the community
are especially important when environmental
review activities need discussion with the
community. Even when oversight responsibilities
have been delegated to local agencies, tribal
government participation can be helpful to ensure
that the review process is sound and that
communications with the community are
effective, and to reinforce that the special
sensitivities of children were considered as part of
the school location selection process.
7.3.5. Access to Information on School
Siting
Tribes should consider developing a publicly
available, easily accessible website/database to
provide a centralized source of information
pertinent to school evaluation and selection,
including:
Policies and procedures for site evaluation and
review;
Public involvement guidelines;
Mapping and other resources to assist in
evaluation of potential school locations;
Records of location reviews (e.g., findings,
description of site remediation activities,
institutional and engineering controls, decision
documents for cleanup and documentation of
sites that meet standards for residential use);
and
Surveys of historic properties, including
schools.
7.3.6. Tribal Oversight Roles
Tribes are encouraged to identify and document
tribal roles and responsibilities for long-term
oversight early in the school siting process. If a
site that has not been cleaned up to standards for
residential use is selected for a school, tribal
agencies may oversee the environmental review
to ensure that institutional and engineering
controls and the long-term stewardship plan are
sufficient to prevent exposures to environmental
hazards. Alternatively, this role may be shared
with or delegated to a local agency or other
partner, provided the partner can demonstrate
the capacity to manage these important issues.
Environmental evaluation
LEAs should work with tribal governments to
ensure that all sites under tribal jurisdiction that
are proposed for renovation of an existing
building for school use, construction of new
schools or expansion of existing schools have
received appropriate environmental approval
from the tribal agency prior to construction. Sites
or buildings should be assessed prior to
acquisition or donation to determine if there is
environmental contamination onsite or at
neighboring sites that could pose health or
environmental risks to children, faculty or staff.
Federal review may also be needed.
Cleanup procedures
Although most tribes do not have procedures that
specifically apply to investigation, sampling,
cleanup, determination of appropriate land and
resource uses, and long-term stewardship of
potential school locations, they often do have
policies and practices in place that apply more
generally to locations being considered for reuse.
Locations selected for use as schools should be
cleaned up to standards for residential use.
Cleanups should also follow cleanup plans that
have clearly delineated contamination and verify
that cleanup efforts have been effective. In the
event that a site does not support residential use
because of residual contamination, institutional
controls (and possibly engineering controls) may
be a necessary component of the cleanup. Because
the purpose of institutional and engineering
controls (see Section 8.15) is to prevent exposure
to contaminants and protect the integrity of the
cleanup, effective management of institutional and
engineering controls is critical to ensuring that a
site can be used safely.
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Meaningful public involvement
Meaningful public involvement (see Section 3)
throughout the school siting process is of critical
importance. Tribes should ensure that their public
involvement requirements will effectively involve
the community, and plans for public involvement
should be formalized prior to initiating the
identification of potential school sites. Details of
site assessment processes, cleanup decisions (e.g.,
scope, procedures, findings), land use restrictions
(engineering and institutional controls, see
Section 8.15) and subsequent school construction
plans should be provided to the community and
subject to public notification and comment. It is
important for LEAs to develop a communications
plan to ensure effective public involvement (see
Section 3.4).
Local capacity to manage institutional and
engineering controls
Tribes should establish standards to assess the
capacity of any party for management of
institutional or engineering controls at potential
school locations. The standards should be
designed to ensure the long-term integrity of any
institutional or engineering controls put in place
at potential school sites where residual
contamination or offsite hazards to be mitigated
exist. The capacity to manage engineering and
institutional controls should consider the
following:
Availability of accurate information on the
location or extent of institutional and
engineering controls, perhaps provided on a
map;
• Establishment of, and participation in, a one-call
system (see Section 10) to protect against
human exposure to contaminated soil;
Establishment of a mandatory monitoring
program to routinely review institutional and
engineering controls to ensure their continued
effectiveness;
Establishment of enforceable institutional
controls, which require compliance;
Establishment of information on institutional
controls that effectively disseminate
information on the location of controls,
compliance status, and monitoring reports to
interested stakeholders, especially parents,
tribal and local environmental officials;
Long-term budget commitment to provide
funds for the operation and maintenance of
institutional and engineering controls, including
required training of staff responsible for
maintaining controls;
Tracking of expenditures associated with
institutional and engineering controls by the
LEA so that historical expenditures can be used
to refine planning estimates for the cost of
maintaining institutional and engineering
controls;
Using more than one institutional control (i.e.,
"layering") to improve overall reliability and
effectiveness for managing the amount,
concentrations, toxicity and other
characteristics of the residual waste or
contamination; and
Availability of a process to report malfunctions
of controls.
7.3.7. Tribal Policy Review
Tribes are encouraged to review existing laws,
policies and regulations addressing school siting
to determine whether changes are needed to
encourage improved school siting decisions. Such
a review of existing policies across tribal agencies
would help identify gaps and outdated policies
that no longer serve state goals and objectives.
Education, health, environmental, planning and
transportation agencies, as well as others, such as
Historic Preservation Offices, should work
together to consider how existing regulations,
policies and guidelines influence or affect
decisions about school renovation, remodeling or
the siting of new schools. Review of existing
guidelines or policies may focus on those related
to the following general topics:
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Recommendations for States and Tribes
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Community involvement and public
participation in school siting and renovation
decisions;
Long-range school facilities plan;
School funding of new construction or to
support existing school renovation;
Prohibitions on tribal reimbursement of land
costs that force communities toward the lowest
cost sites, regardless of potential environmental
challenges;
School size formulas or requirements for lot
size and access to recreational areas;
• Minimum school enrollment requirements;
• Environmental evaluation and associated costs;
Environmental cleanup (including cleanup
standards and long-term stewardship site
controls) and associated costs;
• Community use of schools (and joint use of
community resources such as libraries,
theaters, parks and ball fields);
Energy efficiency;
• Sustainable development; and
Emergency preparedness and sheltering plans.
Tribes may also consider developing policies,
guidelines or regulations with local health
jurisdictions to involve them in approval of school
sites, and tribes should provide local communities
with information related to tribal policies that
pertain to siting decisions.67
Public health policies should promote school sites
that do not lead to harmful environmental
exposures and that do facilitate physical activity,
healthy behaviors and healthy communities.
Schools located in the neighborhoods of the
67 For more information on existing state policies, see "50 State
Survey," conducted by Rhode Island Legal Services. Available at:
www.childproofing.org/school_siting_50_state.htm.
students they serve will have an increased
number of children who walk, bike or take public
transit to and from school and will provide
families with access to playgrounds and facilities
that encourages physical activity outside of school
time. Policies related to environmental review
should facilitate assessment of locations before an
LEA purchases or leases a property. Tribal
policies, laws and regulations can promote these
goals in a number of ways, including:
• Encourage the creation of long-range school
facilities plans (see Section 4.2.1) by LEAs,
including LEA guidance on how these plans can
involve stakeholders and community members
and complement comprehensive plans and
other planning efforts at the municipal (and
tribal) levels. One resource is California's "Guide
to Development of Long Range Facilities Plan"
(www.cde.ca.gov/ls/fa/sf/longrangeplan.asp);
Do not require minimum number of acres
for school sites. Acreage requirements can
prevent LEAs from using smaller sites within
neighborhoods and force them to build schools
on large tracts of lands on the outskirts of
communities. The Council of Educational
Facility Planners International
(www.cefpi.org/) has abolished its "minimum
acreage standards" policy but some tribes may
still have now-outdated laws based on this
policy in effect;
Encourage communities and LEAs to plan
and develop joint use agreements for
libraries, parks and ball fields for efficient use of
available land;
Do not favor larger enrollment schools,
which are challenging to build within
neighborhoods, in formulas for education
funding allocations;
Do not favor new construction over
renovation of existing schools in school
construction funding formulas (often called the
two-thirds rule or "60 percent" rule).
Renovation and modernization could help
achieve educational objectives by creating
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school environments that support improved
academic achievement by helping to alleviate
the backlog of repair and maintenance projects.
In a study conducted in the Los Angeles Unified
School District (www.edfacilities.org/pubs/
LAUSD%20Report.pdf), researchers found that
improvements in the quality of school facilities
led to an increase in student performance;68
Consider true long-term costs of a site
assessment/investigation, including land
acquisition, initial construction, long-term
busing costs and other transportation costs,
improvements to the utilities and street
network around the school, long-term site
location monitoring and maintenance costs in
policies on estimating costs for renovation
versus construction;
Encourage efficient location of schools and
judicious use of busing through school busing
reimbursement formulas and busing radius
policies;
Consider "walkability" infrastructure (e.g.,
adequate sidewalks, absence of traffic hazards,
safe routes to schools) in tribal school funding
policies;
School funding mechanisms at the tribal
level should allow time for proper analysis
and consideration of suitable sites for
construction, particularly at sites where
environmental concerns are involved;
Provide technical support to LEAs during the
environmental review. Policies of tribal health
and environmental agencies should allow for
and encourage LEAs to partner with tribal
agencies in conducting a thorough
environmental review; and
68Jack Buckley, Mark Schneider and Yi Shang, "LAUSD School
Facilities and Academic Performance," Los Angeles Unified School
District, Unpublished report prepared as part of Building Educational
Services Together initiative, 21st Century School Fund, Washington,
DC. Accessed on September 16, 2011. Available at:
www.ncef.org/pubs/LAUSD%20Report.pdf.
Encourage public involvement throughout
the siting process.
In addition to policies related to environmental
review and cleanup, relevant policies include
those that promote public health and take into
account the impact of proposed or existing offsite
sources on existing schools.
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Recommendations for States and Tribes
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8. Quick Guide to
Environmental Issues
Contents
Air Pollution (see Section 8.1)
Nearby Highways and Other Transportation
Facilities (Including Goods Movement) (see
Section 8.2)
Volatile Organic Compounds (VOCs) in Soil and
Ground Water (see Section 8.3)
Radon (see Section 8.4)
Petroleum Hydrocarbons in Soil and Ground
Water (see Section 8.5)
Lead-based Paint Hazards and Lead in Soil and
Drinking Water (see Section 8.6)
Polychlorinated biphenyls (PCBs) in Fluorescent
Light Ballasts, Window Caulking and in Soil
Associated with Older Buildings (see Section 8.7)
Asbestos Containing Material Surveys
(see Section 8.8)
Mold (see Section 8.9)
Chemicals in Schools (see Section 8.10)
Heavy Metals in Soil and Ground Water
(see Section 8.11)
Pesticides (see Section 8.12)
Securing Safe Soil and Fill (see Section 8.13)
Historic Fill (see Section 8.14)
Institutional and Engineering Controls
(see Section 8.15)
Capacity for Long-term Maintenance of
Engineering and Institutional Controls
(see Section 8.16)
This section provides general information on
some of the common environmental issues that
the local education agency (LEA), the school siting
committee (SSC) and the community may
encounter during an environmental review.
8.1. Air Pollution
The potential exposure of children to air pollution
is both a general community concern, depending
on the overall air quality in any given region, and a
very local concern, depending on what sources of
air pollution may be located in proximity to a
prospective school location. There are many
potential sources of air pollution ranging from
large scale industries to small businesses located
within neighborhoods; a variety of transportation
related activities such as roads and transportation
hubs; and area sources including agricultural
activities and a myriad of other land uses. Major
pollutants include:
Criteria pollutants (ozone, particulate
matter, carbon monoxide, nitrogen oxides,
sulfur dioxide and lead) - Exposure to these
pollutants is associated with numerous effects
on human health, including increased
respiratory symptoms, heart or lung diseases
and even premature death (www.epa.gov/air/
urbanair/); and
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• Air toxics include 187 specific pollutants that
are known or suspected to cause serious
health effects and are regulated as hazardous
air pollutants, or HAPs. Examples of toxic air
pollutants include benzene, which is found in
gasoline; perchloroethlyene, which is emitted
from some dry cleaning facilities; and
methylene chloride, which is used as a solvent
and paint stripper by a number of industries.
Examples of other listed air toxics include
dioxin, asbestos, toluene and metals such as
cadmium, mercury, chromium and lead
compounds, (www.epa.gov/air/toxicair)
In 2009/2010, EPA, state and local air pollution
control agencies conducted air monitoring at
63 schools in an effort to better understand the air
around selected schools throughout the country.
Data from this air monitoring initiative can be
found at www.epa.gov/schoolair.
Link to air pollution resources:
www.epa.gov/schools/siting/resources.htmlttLIN
KS_air_pollution.
8.2. Nearby Highways and
Other Transportation
Facilities (Including Goods
Movement)
Recent research has demonstrated a link between
exposures to air pollutants from traffic emissions
near large roadways and adverse human health
effects. The Health Effects Institute (HEI) recently
completed a review of a large number of health
studies, concluding that near-road exposures "are
a public health concern."69 Although the link
between adverse health effects and near-road
exposures has been made, the science has not yet
progressed to an understanding of how some key
elements affect these associations, such as the
Health Effects Institute Panel on the Health Effects of Traffic-
Related Air Pollution, "Traffic-Related Air Pollution: A Critical Review
of the Literature on Emissions, Exposure, and Health Effects," Health
Effects Institute Special Report 17 (January 2010). Available at
http://pubs.healtheffects.org/view.php7id=334.
type and size of roads of concern, the vehicle fleet
mix and activities leading to highest exposures,
and the distance from the road at which near-road
health impacts subside. Most studies on traffic and
health focus on roads with high levels of traffic
(for example, 100,000 annual average daily traffic
or higher). A few studies have reported health
effects associated with smaller traffic volumes,
with one study showing effects at volumes as low
as 10,000 annual average daily traffic in an area.
Further, while the health studies reviewed by HEI
focused on exposures to traffic emissions, other
transportation sources such as rail yards, rail
lines, airports and marine ports have similar
concerns due to similarities in the type and
characteristics of air pollution emissions.
For most transportation sources, air pollutant
concentrations are generally highest closest to the
source, with concentrations decreasing with
distance from the facility. According to the HEI
report, studies that have examined gradients in air
pollutant concentrations as a function of distance
from roadways have indicated "exposure zones
for traffic-related air pollution in the range of
50 to 1500 m" from the highways and major roads
evaluated. However, the magnitude and extent of
these increased air pollutant concentrations can
vary based on a number of factors related to
emissions from the source, meteorological and
topographic conditions affecting pollutant
transport and dispersion, and the influence of
roadway design and roadside features on
pollutant transport and dispersion.
Traffic emissions may vary depending on the total
number of vehicles using a road, the level of
congestion on the road and the number of heavy-
duty trucks present. For rail operations, the
number of trains, maintenance activities and
line/yard configuration will influence emissions
and exposures. Ports and airports will generate
emissions from the ships/planes present at the
facility, as well as support equipment and
operations at the facility. For marine ports, large
numbers of heavy-duty trucks may also be present
on local roadways to move goods from the port.
Air pollutant concentrations near transportation
118 | Quick Guide to Environmental Issues
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facilities will also be affected by wind direction,
wind speed and atmospheric stability. Changes in
local topography from natural or roadway design
features will also affect air pollutant transport and
dispersion, which can lead to varying exposures
for school occupants. Thus, air quality may vary
based on surrounding terrain and features, such
as cut sections, noise walls, vegetation or
combinations of these features.
The complexity and multitude of factors affecting
air pollutant concentrations near transportation
sources (see Exhibit 5: Factors Influencing
Exposures and Potential Risks from Nearby
Hazards) make it difficult to recommend a strict
set of guidance for safe distances from these
source types, particularly given the potential for
unintended consequences. Locations in close
proximity to major transportation facilities should
consider a range of approaches to mitigate or
avoid potential exposures. When evaluating
potential locations that may be located near a
highway or other major transportation facility,
several factors should be considered:
• Are there other locations in the community at
farther distances from the source that are also
being considered? Urban areas may be limited
in their ability to find appropriate locations
away from major roads and other
transportation sources; thus, careful
consideration should be given to near-road
and other transportation source locations
before eliminating them if the only
alternatives are to locate schools much farther
from the communities being served.
Unintended negative consequences to moving
schools away from these communities may
include increased pollutant exposures during
longer bus or personal car commutes,
increased traffic on local roads to access
schools further from their communities, and
lack of walking, biking, or other alternative
commute options to school; and
What options might be feasible for mitigating
pollutant concentrations at the site from these
offsite sources?
- Studies suggest that roads in cut sections
(i.e., road surface below existing terrain) or
that have combinations of noise barriers,
vegetation and/or buildings near the
roadside may reduce downwind air
pollution concentrations;
- School design techniques may be
employed to reduce exposures at near-
source schools, such as locating athletic
fields, playgrounds and classrooms as far
from the source as possible, and locating
air intakes in areas on the school
building(s) that are least affected by offsite
or onsite transportation air pollutant
sources;
- Installing or preserving barriers such as
trees, buildings and noise barriers may
reduce air pollutant exposures;
- Filtration devices as part of HVAC design
can be used to improve indoor air quality
as described in other sections of this
guidance; and
- Adding controls or redesigning offsite
sources to reduce school area pollutant
concentrations (e.g., replacing or
retrofitting port and rail
engines/equipment with cleaner
technologies, reducing idling at terminal
facilities, rerouting existing or projected
traffic away from school or other
populated areas (e.g., truck-only lanes),
and adoption of high density development
and transit alternatives).
The section Evaluating Impacts of Nearby Sources
of Air Pollution provides information that can
assist LEAs and environmental professionals in
evaluating potential sources of air pollution early
in the site evaluation process (see Section 6).
Links to air pollution resources:
www.epa.gov/schools/siting/resources.htmlttLIN
KS_air_pollution and
www.epa.gov/schools/siting/resources.htmlttLIN
KS_highways_and_traffic.
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8.3. Volatile Organic
Compounds (VOCs) in Soil
and Ground Water
The potential for vapor intrusion into overlying
buildings has received much attention in the past
decade. There is a heightened awareness
nationally and internationally by the general
public of the potential health concerns related to
vapor intrusion.
Vapor intrusion is generally denned as the
upward migration of volatile organic compounds
(VOCs) into overlying buildings from underground
soils and ground water. Common contaminants
that may create a vapor intrusion health concern
include, but are not limited to, gasoline
components (e.g., benzene) and dry cleaning and
degreasing solvents. Common dry cleaning and
degreasing solvents include perchloroethylene
and trichloroethylene.
The presence of these contaminants in the soil or
the ground water beneath a building does not
always present a vapor intrusion concern.
Physical factors, such as soil chemistry, ground
water conditions, subsurface features and weather
conditions, also affect whether vapor intrusion
occurs. Extremes in weather conditions can
increase extent of the vapor intrusion (e.g., in
times of drought). Likewise, excess precipitation
may cause plumes to migrate (e.g., based on water
cascading off edges or aprons of gas stations)
and/or travel farther (e.g., under nearby schools).
These weather and geophysical conditions can
result in unanticipated exposures.
Even though well-designed, well-constructed and
well-operated new buildings are generally not
susceptible to vapor intrusion, the use of
integrated foundation sub-slab venting systems
equipped with polyethylene or other vapor
barriers is becoming increasingly common in new
construction in densely-populated regions of the
country, including California, New York and New
Jersey. There are many different types of designs
for sub-slab venting systems. Most systems,
originally developed for protection against
naturally occurring radon gas accumulation,
consist of a relatively inexpensive network of
horizontal perforated Polyvinyl chloride piping
installed within an aggregate layer under a poured
concrete slab beneath the ground floor of a
building. The polyvinyl chloride pipes are
connected to a manifold collection system, and the
collected vapor is vented by vertical piping up
through the roof of the building. In some cases, a
synthetic vapor barrier is recommended, or roof-
top fans are included to operate the system in a
more active mode.
In much the same way that venting systems are
used to intercept radon gas before it enters a
home, such venting systems are effective in
preventing the accumulation of VOCs. Addressing
vapor intrusion into older buildings is more of a
challenge.
The design and installation of sub-slab venting
systems and vapor barriers built into the building
foundation are best completed by experienced
architectural and engineering firms. The proper
installation of a vapor barrier that may overlie a
sub-slab venting system is very important. Once
installed, the vapor barrier should be inspected,
tested and certified by the engineer or architect of
record that the barrier was installed correctly and
works as designed. Smoke testing is a recognized
method to assess proper installation of vapor
barriers and other synthetic liners.
The engineer and/or architect of record should
furnish a report to the LEA along with the results
of the testing, and a copy of the inspection and test
results should be included in a report to an
oversight regulatory agency.
Performance monitoring of a venting system is
equally important. If residual underground soil
and ground water contamination exists, the LEA
should retain an experienced environmental
professional to develop a long-term monitoring
plan and periodically complete testing around the
school to document that the system is operating
properly. Soil gas sampling ports are best
integrated into the building design, within a vent
120 | Quick Guide to Environmental Issues
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piping, or as close to the building as is feasible if
the structure already exists.
Link to vapor intrusion/VOC resources:
www.epa.gov/schools/siting/resources.htmWLIN
KS_vapor_intrusion_vocs.
Additional information regarding volatile organic
compounds can be found here:
www.epa.gov/iaq/voc.htmlttAdditional%20Resou
rces.
8.4. Radon
Radon is a naturally occurring, radioactive, soil
gas. Inhaling radon can lead to lung cancer. Radon
enters buildings through openings in ground
contact floors and walls. Well water may also
contain radon and contribute to the level of radon
in indoor air. Always test for radon in indoor air
before testing for radon in water. Fortunately,
simple, proven and inexpensive techniques have
been used in many schools to keep radon at
acceptable levels.
Soil testing a site for radon is not a reliable way to
determine if a school building will have high
radon levels once constructed. Instead, EPA
recommends that all schools in high radon
potential areas be built with radon prevention
techniques. Such schools should be tested upon
completion and periodically over time to ensure
the radon is at acceptable levels. EPA recommends
the following radon prevention techniques for
construction of schools: installation of active soil
depressurization systems, pressurizing the
building using the HVAC system, and sealing
major radon entry routes.
For existing structures, EPA recommends testing
all schools for radon. As part of an effective indoor
air quality management program, schools can take
simple steps to test for radon and reduce risks to
occupants if high radon levels are found. The only
way to know if elevated radon levels are present is
to test. Some states regulate radon-related
activities in schools, for example, by requiring
schools to take certain actions or licensing radon
measurement and mitigation services providers.
Link to radon resources:
www.epa.gov/schools/siting/resources.htmlttLIN
KS_radon.
8.5. Petroleum
Hydrocarbons in Soil and
Ground Water
One common environmental issue likely to be
encountered at existing and proposed school
locations is contamination from petroleum or
other fuel or heating oils attributed to petroleum
products that have been spilled during use or
leaked from old underground storage tank
systems and piping. These oil and fuel storage
tanks are commonly associated with gas stations
or fuel storage areas governed by federal and state
environmental regulations. Nonresidential
underground storage tanks (including commercial
heating oil and commercial motor fuel) can be
larger than 10,000 gallons in size. Care should be
exercised whenever older petroleum tanks are
encountered. Soil and water samples should be
obtained from around the underground tank prior
to its removal or abandonment, and appropriate
budget contingencies should be established by the
LEA to address soil and ground water remediation
costs associated with leaking petroleum tanks. If
the underground storage tank has leaked, it may
be necessary to drill monitoring wells and
regularly test the water, adding to the cost of
remediation.
Above- or underground heating oil tanks are often
regulated by the local fire marshal or health
department, depending on the size. In many parts
of the country, especially older cities, home
heating oil is commonly used as a fuel in homes.
Most buried residential underground tanks are
smaller than 1,000 gallons in size, but due to their
age, poor condition and location (commonly under
sidewalks), fuel leaks are commonly encountered.
In some instances, fuel tanks are located within
basements. These systems present less of a
concern, as they can be visually inspected.
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The LEA should retain an experienced
environmental professional to oversee the
removal of underground storage tanks and any
excavation that may be necessary to remove and
properly dispose of petroleum-impacted soil.
Issues concerning underground or aboveground
storage tanks should be identified in the
preliminary environmental assessment. As
discussed in the Environmental Review Process
section, the purpose of the preliminary
environmental assessment is to identify the
presence or the likely presence of any
environmental hazards on a property based on
historical and current site uses.
Link to underground storage tank resources:
www.epa.gov/schools/siting/resources.htmWLIN
KS_Sto r age_Tanks.
More information related to aboveground storage
tanks: www.epa.gov/oilspill/spcc.
8.6. Lead-based Paint
Hazards and Lead in Soil
and Drinking Water
Lead has been used in a wide range of industrial,
commercial and residential products from
gasoline, piping, flashing or solder as well as
pesticides and paint.
Paint and Soil: Lead was commonly used in paint
before the 1978 ban by the Consumer Products
Safety Commission on lead-based paint for
applications where consumers may be exposed.
Building exteriors may contain lead-based paint
and soils surrounding older buildings may contain
lead at levels that present an unacceptable
exposure risk. EPA has promulgated regulations
governing both the abatement, as well as the
renovation, repair and painting of, among other
things, pre-1978 child-occupied facilities, which
generally include preschools or building areas
where children under six spend a significant
amount of time. (See 40 CFR Part 745, Subparts E
and L.) For post-1978 buildings and schools in
general, representative testing for lead on building
exteriors and in surface soils is a best practice. If
lead is detected at a concentration in soil that
poses a risk to children, the best practice is to
have an experienced and licensed hazardous
waste professional properly remove and dispose
of impacted soils. If lead-based paint hazards exist
on the exteriors of post-1978 school buildings, the
best practice is to have an EPA or state certified
renovator perform renovation, repair and painting
work in accordance with EPA's lead-safe work
practice requirements for child-occupied facilities
found at 40 CFR Part 745 or cap the soils to reduce
exposures.
Drinking Water: The LEA should engage an
experienced environmental professional to
investigate the drinking water quality within
existing buildings/structures if the school is
served by a municipality. For schools that are to
be renovated or expanded, the sampling and
analysis of water from taps and fountains where
people may be drinking and cooking within the
building(s) is a best practice to determine the
presence and concentration of lead. This work is
best done by an environmental professional
experienced in water quality testing. If lead is
detected above the EPA action level, the
environmental professional should furnish a
report to the LEA that identifies the locations of
concern and provides options on how best to
address the situation. The school should stop
using that tap or water fountain until the
recommendations from the environmental
professional can be enacted.
If a school is a public water system and supplies
its own water with a well, it is subject to state and
federal Safe Drinking Water Act regulations and
should be aware of any lead levels that exceed the
EPA action level. LEAs can contact their local
drinking water program for assistance.
Link to lead resources:
www.epa.gov/schools/siting/resources.htmWLIN
KSJead.
Additional information regarding sampling
drinking water in schools can be found here:
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http://water.epa.gov/drink/info/lead/
testing, cfm and
http://water.epa.gov/infrastructure/drinkingwat
er/schools/guidance.cfm.
8.7. Polychlorinated
biphenyls (PCBs) in
Fluorescent Light Ballasts,
Window Caulking and Soil
Associated with Older
Buildings
Polychlorinated biphenyls (PCBs) were widely
used in electrical and manufacturing processes
before they were banned 30 years ago. If an older
building is being considered as a possible location
or exists on a site proposed for a school, the LEA
should engage an experienced environmental
professional to investigate existing
buildings/structures to determine the presence of
PCB-containing equipment/fixtures and building
materials. PCBs can be found in light fixtures,
electrical equipment (transformers), older paint
formulations and older window caulk products. If
elevated concentrations of PCBs are found, an
environmental professional should furnish a
report to the LEA that documents their occurrence
and remediation options and costs. The
environmental professional should also identify
and follow the federal and state regulatory
requirements for handling, storage and marking of
PCB-containing items.
Ballasts: Many schools in the United States built
before 1979 have light ballasts containing PCBs.
The PCBs are contained within the light ballast
capacitors and in the ballast potting material. Until
the late 1970s, PCBs were commonly used as
insulators in electrical equipment because they
have high tolerance to heat, do not burn easily and
are nonexplosive.
Congress banned the manufacture of PCBs in the
United States in 1977 because of their toxic
effects. In 1979, EPA banned the processing or use
of PCBs, except in totally enclosed equipment.
However, a large number of fluorescent light
ballasts that were installed prior to these bans
may contain PCBs and may still be in use in
schools.
Intact, operational ballasts where PCBs remain in
the ballasts and potting material may not pose a
health risk or an environmental hazard. However,
as they age, the ballasts degrade. Depending on
the number of operating hours, the typical life
expectancy of a magnetic fluorescent light ballast
is between 10 and 15 years. The failure rate prior
to the end of the useful life of ballasts is about 10
percent. After this typical life expectancy, ballast
failure rates increase significantly. All of the pre-
1979 ballasts in lighting fixtures that are still in
use are now far beyond this life expectancy,
increasing the risk of leaks or even fires, which
would pose a health and environmental hazard. A
PCB containing ballast may also be lacking in
thermal overload protection, increasing the
possibility of fires or leaks. The hazard can be
worsened by mishandling by personnel who are
unaware of the presence of PCBs in the lighting
ballasts. A ballast that has been damaged or
mishandled can increase exposure of students and
school personnel to PCBs.
Caulk and Soil: Recent studies conducted by EPA
have identified a potential exposure risk to PCBs
because they were used in the past for certain
window caulk and rubberized paint formulations
to make them more flexible and durable. As a
result, PCBs may be found in soil that surrounds
older buildings. Representative testing of surface
soils and deteriorated window caulk for PCBs in
buildings that were built or renovated between
1950 and 1978 is a best practice. If PCBs are found
in deteriorated window caulking, the best practice
is to have an experienced and licensed contractor
properly remove and dispose of the caulking.
Similarly, if PCBs are detected in soils, the best
practice is to have an experienced and licensed
contractor properly remove and dispose of
impacted soils.
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Links to PCBs resources:
www.epa.gov/schools/siting/resources.htmWLIN
KS_pcbs and
www.epa.gov/pcbsincaulk/guide/guide-sect4.
8.8. Asbestos-Containing
Material Surveys
Asbestos is a naturally occurring mineral fiber
that has been used in a wide variety of products as
an insulator and fire-retardant. The Asbestos
Hazard Emergency Response Act (AHERA), a
provision of the Toxic Substances Control Act,
became law in 1986. AHERA requires local
education agencies (LEAs) to inspect their schools
for asbestos-containing building material and
prepare management plans to prevent or reduce
asbestos hazards.
If an older building is being considered for a
possible school location, the LEA should engage an
experienced environmental professional to
determine the presence of asbestos-containing
materials and its condition using recognized
testing methods. Asbestos-containing materials
may be found on interior and exterior pipe/duct
insulations, equipment and boiler insulations, fire
brick, HVAC units, plaster materials, floor and
ceiling tiles, mastics/glues, roofing materials,
window glazing caulks, wire wrap, between old
wooden flooring (for noise reduction) and
fireproofing materials. Asbestos may also be found
in vermiculite insulation. The environmental
professional should furnish a report to the LEA
that includes the test results, an itemized
inventory of all suspected asbestos-containing
materials, and a corresponding cost estimate to
abate such conditions (including management in
place, where appropriate) and conduct the
appropriate testing in accordance with all
applicable regulatory agency and code
requirements.
Links to asbestos resources:
www.epa.gov/schools/siting/resources.htmWLIN
KS asbestos.
A list of EPA regional asbestos contacts is
available at:
www.epa.gov/asbestos/pubs/regioncontact.
Additional guidance on asbestos programs for
schools can be found at EPA's asbestos website:
www.epa.gov/asbestos.
8.9. Mold
Leaks, condensation and high humidity can result
in significant mold contamination of structures.
Buildings that are intended for reuse should be
evaluated for evidence of prior moisture problems
and potential for future moisture and mold issues.
In buildings where mold issues are identified,
proper assessment and remediation of both the
underlying moisture problems and cleanup of
existing mold should be completed prior to
occupancy. Potential health effects and symptoms
associated with mold exposures include allergic
reactions, asthma and other respiratory
complaints.
Link to mold resources:
www.epa.gov/schools/siting/resources.htmlttLIN
KSjnold.
Additional guidance regarding mold remediation
in schools can be found here:
www.epa.gov/mold/mold_remediation.
8.10. Chemicals in Schools
Existing buildings may contain improperly stored,
hazardous and outdated chemicals, which can
pose a risk to students, staff and other school
occupants. From elementary school maintenance
closets to high school chemistry labs, schools use a
variety of chemicals. When they are mismanaged,
these chemicals can put students and school
personnel at risk from spills, fires and other
accidental exposures. The Schools Chemical
Cleanout Campaign website gives K-12 schools
information and tools to responsibly manage
chemicals. To view the Schools Chemical
Cleanout Campaign website, visit
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www.epa.gov/schools/programs and click on
Schools Chemical Cleanout Campaign.
Link to chemicals in schools resources:
www.epa.gov/schools/siting/resources.htmWLIN
KS_chemicals_in_schools.
8.11. Heavy Metals in Soil
and Ground Water
In addition to lead, metals such as arsenic,
cadmium, mercury and chromium can be found in
paint pigments and older pesticide formulations.
Metals may also have been released to the
environment from commercial or industrial
operations. Metals do not degrade in the
environment, and as a result, can be found in soil
and ground water in many areas. Although low
background levels of metals may not represent a
health concern, elevated levels of metals in soil are
frequently encountered across the country.
Metals are also found in older masonry products. A
standard of care needs to be undertaken if masonry
materials from older buildings are to be crushed and
recycled as fill material. This issue has only recently
surfaced in environmental assessments of older
building slated for demolition. Older masonry
materials may contain elevated levels of metals, such
as beryllium and cadmium that may not be suitable
for onsite recycling. This is especially true if masonry
materials are painted. Representative samples of the
masonry should be obtained by an experienced
environmental professional to determine whether
the masonry is suitable for onsite recycling.
Links to resources on specific metals:
www.epa.gov/schools/siting/resources.htmWLIN
KSJead,
www.epa.gov/schools/siting/resources.htmWLIN
KS_arsenic and
www.epa.gov/schools/siting/resources.htmWLIN
KS_mercury.
The following links provide information regarding
laws and regulations and technical approaches
related to ground water and soil.
Ground Water: www.epa.gov/lawsregs/topics/
water.htmWground,
http://water.epa.gov/type/ground
water/index.cfm and
www.epa.gov/schools/siting/resources.htmWLIN
KS_drinking_ water.
Soil: www.epa.gov/gateway/science/land and
www.epa.gov/superfund/index.
8.12. Pesticides
Pesticides may be encountered on existing and
proposed school sites. If a proposed school was
historically used for residential or agricultural
purposes, surface and subsurface soils should be
tested for pesticides such as chlordane, dieldrin,
lead arsenate and dichlorodiphenyltrichloro-
ethane as well as other pesticides associated with
the crops or agricultural activities at that site. If
there is a well on the property, the water should
also be tested if it is likely to be used for consump-
tion. Pesticides used for termite protection at
schools were routinely sprayed adjacent to
building foundations. If a school building is
proposed for demolition or expansion, soils
should be tested for pesticides in areas proposed
for disturbance. Proper health and safety
precautions should be employed by workers that
may come in contact with pesticides. Excavation
and offsite disposal of soil found to contain
pesticides may be required prior to or during
school construction.
Pesticides in ground water generally occur as a
result of leaching from soil into ground water as
well as injection of soil fumigant pesticides into
the ground. The potential presence of pesticides in
ground water should also be considered if an
onsite source of drinking water is required.
Aerial- as well as ground-based applications of
pesticides can result in unintended spread of
pesticides from the intended target location to
other locations due to equipment, application
techniques, applicator error or weather or other
application conditions. The drift of spray and dust
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from pesticide applications can expose people,
wildlife and the environment to pesticide residues
that can cause health and environmental effects
and property damage.
While large scale aerial spraying of agricultural
operations has resulted in poisoning of farm
workers, children and others, spray drift can occur
during any pesticide application, including in
suburban or urban environments. Drift can even
occur during indoor use of pesticides.
Potential pesticide usage near prospective school
sites in rural, suburban as well as urban locations
should be considered and evaluated for potential
to expose children or staff to pesticides. Where
such potential exists, steps to mitigate potential
exposures should be considered and
implemented. Potential mitigation approaches
include:
Oversight and strict enforcement of product
label use directions and drift restrictions;
Use of drift reducing application technologies
and best management practices; and
Buffer zones based on case- and site-specific
considerations.
Links to pesticide resources:
http://www.epa.gov/schools/siting/resources.ht
ml#LINKS_pesticides.
8.13. Securing Safe Soil
and Fill
Soil and fill materials should not always be
assumed to be free of contaminants. Depending on
the source of soil and fill materials to be imported
to a school site, the soil and fill may contain
contaminants as well as construction and
demolition debris. Not only does fill material
imported to a school site need to be suitable from
an engineering perspective, the soil may need to
meet environmental quality standards. It is
recommended that material be tested and the
architect or engineer of record approves the
placement of fill material on school sites before it
is delivered to the site. Contract documents should
clearly state that imported fill materials need to
meet established environmental quality
specifications.
Contract documents should clearly state that fill
and topsoil imported to a proposed school site be
suitable for the intended future use of the
property as a school, from both an engineering
and environmental quality perspective, and that
the quality of the imported fill and topsoil shall
not change the environmental classification of the
property from an unrestricted to a restricted use.
Similarly, the exportation of excess fill and topsoil
that originates from a proposed school site should
not be assumed to be free of contaminants. Low
levels of contaminants are commonly found,
especially in urban and former agricultural areas.
The LEA and its environmental professional are
responsible for ensuring that the exportation of
fill material is suitable for property to which it is
delivered.
When testing is necessary to document fill and soil
quality, representative samples of the fill and soil
should be tested for such contaminants as
pesticides, PCBs, metals and polycyclic aromatic
hydrocarbons.
Additional information regarding legacy land use
or contamination can be found here:
www.epa.gov/superfund/health/index.
8.14. Historic Fill
Historic fill is generally defined as nonindigenous
material that was imported to a site to raise the
topographic elevation. Examples of historic fill
may include: construction debris, dredge spoils,
incinerator residue, demolition debris, fly ash or
nonhazardous solid waste.
Prior to the turn of the past century, it was a
common practice in certain areas of the United
States to fill low-lying areas to reduce mosquito
breeding grounds and expand urban land on
which to build. In many instances, this historic fill
material originated from an offsite location, and
its environmental quality was never determined.
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Most historic fill contains low levels of pollutants,
but some historic fill can have poorer quality.
In some instances there can be economic and
impracticability issues associated with removal of
such large quantities of historic fill materials,
which in some areas of the northeastern United
States can be 20 feet thick. In these instances,
construction of various impervious and
engineering controls is currently an accepted
practice.
Additional information regarding legacy land use
or contamination can be found here:
www.epa.gov/superfund/health/index.
8.15. Institutional and
Engineering Controls
Institutional controls are legal and
administrative controls used to prevent human
exposure to residual contamination and protect
the integrity of the remedy. Examples of
institutional controls include zoning, notices and
warnings, easements, restrictive covenants, other
land or resource use restrictions,
permits/governmental controls and
administrative orders.
Engineering controls: Examples of engineering
controls include the placement of two feet (or
more) of clean soil/fill material (suitable for
residential uses) and turf grass on playgrounds
and athletic fields, impervious engineered surface
parking lots and building slabs, landfill soil caps,
impermeable liners, other containment covers,
underground slurry walls, fences, air filtration
devices and physical and planted vegetation
barriers.
Best construction and performance management
practices should be used when an engineering
control in the form of a clean soil cover is
necessary to eliminate direct contact exposure to
soil found to contain pollutants. The most
common practice is to isolate the underlying soil
using geotextile and visual barrier materials (such
as polyethylene orange construction/snow
fencing material). Two feet of clean fill and soil is
placed over the geotextile and visual barrier. The
visual barrier serves as a "marker layer" to warn
anyone who might dig into the soil that soil below
this marker contains pollutants in soil that should
not be disturbed. However, sites that contain an
area of contaminated soil/fill may require
additional engineering controls to encapsulate the
contaminated layer of soil/fill. For example, a
layer of crushed stone underneath the clean fill
layer will provide a "capillary break" that limits
the upward and downward movement of water or
leachate. This layer will also prevent burrowing
animals and worms from transporting
contaminated soil into the clean fill and
potentially to the surface. LEAs should review
EPA's requirements for encapsulating
contaminated soils.
Underground utilities are best installed within
clean soil zones to mitigate exposure should
future repairs, alterations, improvements or
disturbances be necessary. Such "clean utility
corridors" are recommended when an engineering
control is necessary for a particular property to
eliminate a potential direct contact exposure to
pre-existing soils that may contain residual
contamination. A clean utility corridor is defined
as a linear trench that is excavated to support the
installation of underground utilities; the trench is
restored to grade, after the installation of utilities,
using clean soil or fill materials. Clean utility
corridors reduce the potential for damage to an
existing engineering control when future utility
repairs, alterations or improvements are
necessary.
Planting trees with extensive root systems should
be avoided if a site is constructed with a
multilayered engineering control barrier. When an
engineering control, in the form of a clean
landscaped soil cover of sufficient thickness, is
employed, trees and shrubs should be planted in
clean soil zones specifically excavated to
accommodate their root systems. Trees and
shrubs should be kept away from water wells and
septic fields. This often requires excavation to a
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depth of four to six feet to accommodate the root
ball of the tree or shrub.
Link to cleanup regulations and processes:
www.epa.gov/schools/siting/resources.htmWLIN
KS_cleanup_regulations_and_processes.
Additional information regarding cleanup
programs and standards can be found here:
www.epa.gov/oswer/cleanup/index and
www.epa.gov/oswer/cleanup/programs.
Additional information regarding risk assessment
processes can be found here:
www.epa.gov/oswer/riskassessment.
8.16. Capacity for Long-
term Maintenance of
Engineering and
Institutional Controls
The use of institutional and engineering controls
can be an effective method for eliminating direct
contact exposure. Where there is concern about
an LEA's capacity and ability to manage sites with
institutional and engineering controls (see
Sections 7.2.6 and 7.3.6, under "Local capacity to
manage institutional and engineering controls"),
LEAs are encouraged to enroll prospective sites in
their state or tribal voluntary cleanup/
brownfields response program to ensure
oversight of assessment and cleanup efforts and to
identify a process for an LEA, working with their
regulatory partners, to oversee continued safe site
management If an institutional or an engineering
control is necessary to eliminate direct contact
exposure, the LEA should adequately budget for
periodic inspections, maintenance and
repair/replacement of the controls.
An institutional control, in the form of a notice to
the property deed, can specify certain actions to
be completed by the property owner and will
identify the various reporting requirements to
document that the engineering control remains
intact. This "deed notice" typically:
• Informs the owner (and future owners) of the
property to maintain the engineering controls
and to notify the regulatory agency prior to
any alterations, improvements or
disturbances in the area (i.e., the restricted
area);
Sets forth the schedule to conduct periodic
inspections of the area; and
Specifies any particular certification
requirements that the engineering control
remains intact.
Long-term stewardship resources:
www.epa.gov/schools/siting/resources.htmlttLIN
KS_longterm_stewardship.
Additional information regarding cleanup
programs and standards can be found here:
www.epa.gov/oswer/cleanup/indexand
www.epa.gov/oswer/cleanup/programs.
Additional information regarding risk assessment
processes can be found here:
www.epa.gov/oswer/riskassessment.
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9. Frequent
Questions
Contents
Public Involvement
How do the guidelines address community
involvement in the school siting process?
(see Section 9.1)
Existing Schools
Do the guidelines apply retroactively to
previous siting decisions? (see Section 9.2)
Do the guidelines address the retention
and renovation of existing schools?
(see Section 9.3)
- Will EPA School Siting Guidelines prevent
pollution generating facilities from being
built near existing schools?
(see Section 9.4)
What can I do to protect my child right
now from environmental hazards at their
current school? (see Section 9.5)
Environmental Hazards
Shouldn't schools be built as far away from
major pollution generating sources as
possible? (see Section 9.6)
Isn't an uncontaminated site always the
best location for a new school?
(see Section 9.7)
Can schools be safely built on sites with
residual soil or ground water
contamination? (see Section 9.8)
In cases where the best available location
for a school relies on engineering and/or
institutional controls to prevent potential
exposures, how can the community work
with the LEA and other responsible
entities to ensure that those controls are
effective for the life of the school?
(see Section 9.9)
- What cleanup or remediation of
contamination at a school site should be
completed before the school is occupied?
(see Section 9.10)
To what cleanup standard should school
sites be remediated? (see Section 9.11)
Distances for Evaluating Environmental
Hazards
- Does EPA recommend buffer or exclusion
zones (also sometimes called distance
criteria or separation distances) to make
sure schools aren't built close to major
sources of pollution? (see Section 9.12)
What is the difference between "screening
perimeters," which are included in the
guidelines, and "buffer" or "exclusion" zones?
(see Section 9.13)
States and Tribes
The School Siting Guidelines place a lot of
emphasis on state and tribal involvement
in evaluating and approving siting
decisions where environmental
contamination is present. At a time of
shrinking state and tribal budgets, how are
states and tribes to meet the anticipated
demand for more involvement?
(see Section 9.14)
Other Child-Occupied Facilities
Do the guidelines apply to child care
centers or other facilities where children
spend time? (see Section 9.15)
9.1. How do the guidelines
address community involvement
in the school siting process?
The guidelines emphasize the importance of
meaningful public involvement (see Section 3)
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throughout the school siting process. The
guidelines recommend that at the beginning of the
school siting process, the local education agency
(LEA) (see Section 10) should create a public
involvement plan and formalize the role of the
public, including reviewing potential locations,
environmental reports, cleanup plans and long-
term stewardship plans. EPA recommends
forming a school siting committee (SSC) (see
Section 3.3) that includes representatives from the
community to make recommendations to the LEA
throughout the siting process.
9.2. Do the guidelines apply
retroactively to previous siting
decisions?
No. The School Siting Guidelines are not designed
for retroactive application to existing school
locations or previous school siting decisions, but
rather to inform and improve future school siting
decision-making processes. However, irrespective
of these guidelines, EPA recommends that districts
periodically inspect existing schools for potential
environmental health and safety risks. These
inspections should use tools designed for that
purpose, such as EPA's Healthy School
Environments Assessment Tool (HealthySEAT;
www.epa.gov/schools/healthyseat/) or the NIOSH
Safety Checklist Program for Schools.
(www.cdc.gov/niosh/docs/2004-101/) Where
deficiencies are found, EPA recommends steps to
reduce student and staff exposure to potential
hazards be identified and implemented, to the
maximum extent practical (see Section 9.5).
9.3. Do the guidelines address
the retention and renovation of
existing schools?
Yes. The siting decision often starts with
evaluating existing schools and their suitability to
be updated to meet the future needs of the LEA.
The guidelines recommend that communities
consider renovation, repair and/or expansion
options (see Section 4.2.2) before deciding to
build a new school. Many existing schools can be
retrofitted with new technologies to expand their
useful life, possibly at a lower cost and with fewer
environmental impacts (e.g., energy savings, less
impact on open space) than new construction.
Renovating existing neighborhood school facilities
can provide an impetus for community
revitalization, have an impact on neighboring
property values, encourage investment in schools
by community members and preserve
irreplaceable community assets.
EPA recommends that districts periodically
inspect existing schools for potential
environmental health and safety risks. These
inspections should use tools designed for that
purpose, such as EPA's Healthy School
Environments Assessment Tool (HealthySEAT;
www.epa.gov/schools/healthyseat/) or the
NIOSH Safety Checklist Program for Schools
(www.cdc.gov/niosh/docs/2004-101/). Where
deficiencies are found, EPA recommends steps to
reduce student and staff exposure to potential
hazards be identified and implemented, to the
maximum extent practical (see Section 9.5).
9.4. Will EPA's School Siting
Guidelines prevent pollution
generating facilities from being
built near existing schools?
Land use decisions are generally made at the local
level, subject to the local jurisdiction's zoning and
other land use policies. While many types of
industries, commercial operations and
transportation infrastructure projects are subject
to state, tribal and/or federal environmental or
other regulations, the requirements vary.
However, the recommendations in these
guidelines can be used by planning and
environmental agencies in land use and
permitting issues to the extent applicable.
EPA recommends that states, tribes and
communities evaluate siting and permitting
processes that influence where potential sources
of environmental pollution (see source categories
identified in Exhibit 6) may be allowed to locate
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with respect to schools. While these land use
decisions are highly complex and beyond the
scope of these guidelines, states, tribes and
communities should seek to avoid situations in
which new nearby sources of potentially harmful
pollutants are sited in such close proximity to
schools that they may pose a potential hazard to
the school occupants.
9.5. What can I do to protect
my child right now from
environmental hazards at their
current school?
There are many steps that parents can take to help
promote healthy school environments. EPA has
resources (see below) for parents in a number of
programs that are designed to help schools and
communities take action to protect children's
health in one of the most important places—
where children learn. EPA also encourages
parents to partner with schools and local
community planners to make school walking and
biking routes safer for children. This encourages
more active transportation choices which results
in fewer vehicles on the road.
EPA Schools Web Portal—The Web portal
provides links to EPA and other programs
addressing environmental health issues in
schools, from air pollution and asbestos to
chemical management, pesticides, water
conservation and more. Visit:
www.epa.gov/schools.
Healthy School Environments Assessment Tool
(HealthySEAT)—HealthySEATis a free software
tool to help school districts assess and manage all
of their environmental health and safety risks.
Visit: www.epa.gov/schools/healthyseat.
Reduce engine idling around schools, clean up
old school buses and reduce other diesel
emission sources in the community—School
buses are a safe way for children to get to school.
However, pollution from older diesel vehicles has
health implications for everyone, especially
children. The goals of the Clean School Bus USA
Campaign are to reduce children's exposure to
diesel exhaust and the amount of air pollution
created by diesel school buses. Schools can also
encourage the reduction of personal vehicle idling
and overall use on campus.
For tips on how to reduce engine idling and diesel
emissions around schools and in the community,
visit: www.epa.gov/cleanschoolbus/
whatyoucando.
Protect indoor air quality at schools—Improving
and protecting indoor air quality at schools is
important to children's health. Indoor levels of air
pollutants can be two to five times higher than
outdoor levels. Sources of poor indoor air quality
in schools range from inadequate ventilation
systems to fumes from pesticides and cleaning
agents. Many of the nation's schools are
implementing indoor air quality management
programs, most of which are based on EPA's
voluntary Indoor Air Quality Tools for Schools
Program, which helps schools identify, resolve and
prevent indoor air quality problems using mostly
low- and no-cost measures.
For EPA's guidance on preventing and resolving
indoor air quality problems in schools, visit
www.epa.gov/iaq/schools.
Use integrated pest management (IPM)—IPM
provides safe and usually less costly options for
effective pest management. Visit: www.epa.gov/
pesticides/ipm/.
Ensure drinking water quality—Consuming
enough fluids on a daily basis is important for
children's health and water is a healthy choice.
Ensuring that children receive safe drinking water
at their schools and child care centers is important
because that's where children spend part of their
day, and they are likely to drink water while they
are there. Schools and child care centers can find
on EPA's website information about lead in
drinking water, source water protection, water
conservation, cross-contamination, and other best
management practices to assist schools and child
care centers in providing safe drinking water to
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students and staff. Visit: www.epa.gov/safewater/
schools/.
Manage chemicals safely—From elementary
school maintenance closets to high school
chemistry labs, schools use a variety of chemicals.
When they are mismanaged, these chemicals can
put students and school personnel at risk from
spills, fires and other accidental exposures. EPA's
school chemical cleanout campaign website gives
K-12 schools information and tools to responsibly
manage chemicals. Visit www.epa.gov/schools/
programs (click on Schools Chemical Cleanout
Campaign).
Protect students and staff from the sun—Too
much sun can lead to heat stress and unhealthy
exposure to UV radiation. EPA's SunWise program
provides information and materials to schools,
educators and parents to help them prevent
cancer and blindness caused by U V exposure.
Visit: www.epa.gov/sunwise/.
Check the Air Quality Index—Children are one of
the sensitive groups at risk for health effects from
air pollution, in part because their lungs are still
developing. The Air Quality Index (AQI)
(www.airnow.gov) lets you know when air quality
in your area is unhealthy and how you, your
family and your community can protect your
health. The AQI uses a color-coded scale and maps
to provide daily air quality information. The AQI is
available at www.airnow.gov and it is reported in
many local newspapers and on television and
radio stations.
For tips on how you can reduce air pollution in
and around your community, visit:
www.airnow.gov/index.cfm?action=jump.jump^yo
ucando.
To teach students about air quality, use EPA's
toolkit: www.airnow.gov/index.cfm?
action=learning.workshop_for_teachers.
Create Safe Routes to Schools—The U.S.
Department of Transportation's Safe Routes to
School program encourages schools and
communities to improve infrastructures and
educational programs to encourage more children
to safely bike or walk to and from school. Visit:
http://safety.fhwa.dot.gov/saferoutes/.
Examples of EPA-funded projects in
communities:
Community Action for a Renewed Environment
(CARE) grant program—EPA's CARE is a
competitive grant program that offers an
innovative way for a community to organize and
take action to reduce toxic pollution in its local
environment. Through CARE, a community creates
a partnership that implements solutions to reduce
releases of toxic pollutants and minimize people's
exposure to them. To learn more about
community efforts that are being supported by
EPA's CARE program, visit: www.epa.gov/care/
communitybyregion.
Community-Based Air Toxics Projects—EPA
supports air toxics projects in about 30
communities across the nation to help inform and
empower citizens to make local decisions
concerning the health of their communities.
(http://yosemite.epa.gov/oar/CommunityAssess
ment.nsf/Welcome?OpenForm)
Make simple choices on the road—Doing your
part to improve air quality and reduce traffic
congestion around schools and in your community
is easy. Incorporating even a few of the simple
steps offered here can help clean the air and
reduce traffic congestion. For easy tips, visit: www
.italladdsup.gov/resources/what_can_i_do.asp.
9.6. Shouldn't schools be built
as far away from major pollution
generating sources as possible?
When acceptable alternative sites exist within the
neighborhood(s) being served by the new school,
the guidelines recommend that the LEA and SSC
seek to avoid sites that are either on or in close
proximity to land uses that may not be compatible
with schools during the initial screen of candidate
sites. These include locations that have onsite
contamination that has not been addressed, major
132 | Frequent Questions
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pollution sources, clusters of industrial facilities or
other potential hazards (see Siting Criteria,
Exhibit 6: Screening Potential Environmental,
Public Health and Safety Hazards). If no
acceptable alternative sites exist, it is critically
important for the LEA and SSC to fully explain the
absence of alternatives in a transparent manner
and fully engage the public in identifying and
implementing both site-specific and community-
wide exposure and risk reduction strategies.
High traffic roads can be a major pollution source
that require careful consideration and evaluation
by the LEA and SSC because these sources are
common and there is typically a direct
relationship between the transportation system
and the accessibility of the school for staff and
students. The guidelines recommend that when
practicable, a chosen school site should be as far
from high traffic roads as feasible. High traffic
roads may include highways, local roads
experiencing heavy congestion, local roads with
significant stop and go activities, and roads with
large numbers of trucks. Since high traffic roads
are very common, especially in urban areas, it may
be difficult to find locations away from these roads
yet still be located within the community being
served by the new school. Under these
circumstances, the LEA and the SSC should
consider a number of factors in making the best
choice for student health, safety and accessibility.
These factors can include: 1) if the school site and
design provide an opportunity to place
classrooms, playgrounds, athletic fields and air
intakes as far from the road as possible; 2)
whether barriers (e.g., noise barriers, nonsensitive
buildings) or natural features (e.g., vegetation,
berms) are or can be located between the school
and road to reduce air quality impacts; and 3)
whether certain sites allow students to walk/bike
to school compared with alternatives that require
bus and personal vehicle travel. Because of all of
these factors and the difficulty in comprehensively
assessing the advantages and disadvantages of
particular sites under these conditions, an
environmental professional should be consulted
to provide assistance. More information is
provided in the Quick Guide for Environmental
Issues (see Section 8).
9.7. Isn't an uncontaminated
site always the best location for
a new school?
The best school location will be one that provides
a healthy and safe learning environment for
children, while also meeting a diverse array of
other community goals. For example, integrating
community centered schools into existing
residential neighborhoods often allows for better
environmental, community, economic, educational
and public health outcomes. The voluntary School
Siting Guidelines are intended to help
communities appropriately consider
environmental health and safety in the context of
this complex decision-making process.
Of course, if uncontaminated structures or sites
are readily available in the community the school
is intended to serve, and meet the community's
other important educational, economic and
community criteria, selecting an uncontaminated
location would be the ideal choice. However, such
locations are rare in many urban communities,
and often the LEA is faced with choosing among
locations that have some level of contamination
from prior uses or are close to potential sources of
contamination. Building schools on the
undeveloped outer edges of communities—often
called greenfields—creates other problems such
as increased transportation risks, longer
transportation times and increased traffic-related
air pollution, while reducing opportunities for
students, parents and staff to walk or bike to
school in their community.
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9.8. Can schools be safely built
on sites with residual soil or
ground water contamination?
Schools can be safely located on sites where all
waste and contaminated media have been
removed, as well as those with residual
contamination, provided that the location is
carefully managed over time to ensure that no
exposure to the contamination can occur. In cases
where complete removal of contamination is not
feasible, exposures can be prevented through the
use of engineering controls and/or institutional
controls (see Section 8.15). For example, vapor
intrusion from soil or ground water contaminated
with certain chemicals can pose a risk to the
people who use buildings that are located above
the contamination. Engineering controls can be
used to alter the flow of contaminated air or
restrict land use in a specific area so that
contaminated air does not enter the building's
indoor air. The use of engineering and
institutional controls can prevent exposures, but
only if effective systems are in place to maintain
and enforce them, such as periodic monitoring to
ensure their continued protectiveness and safe
operation. Nationwide, brownfields and other
formerly contaminated lands, including those with
residual contamination, now safely support
housing, schools, clinics, hospitals and other
reuses that meet community needs.
Criteria for establishing the degree of cleanup
needed should be based on state or tribal cleanup
rules or guidance, where they exist. The
environmental standards used for determining the
appropriate level of cleanup should be based on
either 1) standards developed for schools or
residential use, or 2) risk-based levels set for
residential use. If the site will have residual
contamination at concentrations above these
levels after the cleanup has been completed,
engineering and/or institutional controls will be
needed to ensure no exposure occurs (see Section
8.15). As part of their review of the cleanup plan,
state, tribal and local regulatory agencies should
consider the ability of the LEA and other
governmental bodies to effectively maintain those
controls. In the event that there is concern that
these controls cannot be effectively and reliably
managed, then the LEA may need to clean the site
to residential levels, or select another location.
9.9. In cases where the best
available location for a school
relies on engineering and/or
institutional controls to prevent
potential exposures, how can
the community work with the
LEA and other responsible
entities to ensure that those
controls are effective for the life
of the school?
Communities have an important role to play in
ensuring that engineering and institutional controls
remain in place and are effective in preventing
potential exposures (see Section 8.15). Through the
community involvement and planning process, the
community can become familiar with the nature of
residual contamination, engineering and
institutional controls and any restrictions on how
the land can be used. They can assist LEAs and help
them meet their obligations by reporting actions in
conflict with those land use restrictions to LEA
management and state environmental regulatory
authorities. The LEA and the SSC can also continue
to play a role in updating the community about
inspection, monitoring and maintenance over time,
with the assistance of state technical oversight, as
appropriate.
9.10. What cleanup or
remediation of contamination at
a school site should be
completed before the school is
occupied?
Before a school or portion of a school is occupied,
all contamination that could pose a risk of harmful
exposure to students and staff should be removed
134 | Frequent Questions
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or controlled. In cases where there is residual
contamination, any necessary engineering and
institutional controls should be in place and the
site certified by the state or tribal regulatory
agency as suitable for occupancy (see Section
8.15). For example, occupation of a school above a
ground water plume that is undergoing
remediation to clean the ground water should not
pose a threat to students, faculty, staff or others
unless there is a threat of vapor intrusion from the
ground water. If the contaminated ground water
poses a threat of vapor intrusion, any institutional
or engineering controls should be in place at least
for any portion of the school where there is a
potential for exposure.
9.11. To what cleanup standard
should school sites be
remediated?
Criteria for establishing the degree of cleanup
needed should be based on state or tribal cleanup
rules or guidance, where they exist. The
environmental standards used for determining the
appropriate level of cleanup should be based on
either 1) standards developed for schools or
residential use, or 2) risk-based levels set for
residential use. If the site will have residual
contamination at concentrations above these
levels after the cleanup has been completed,
engineering and/or institutional controls will be
needed to ensure no exposure occurs (see Section
8.15). As part of their review of the cleanup plan,
state, tribal and local regulatory agencies should
consider the ability of the LEA and other
governmental bodies to effectively maintain those
controls. In the event that there is concern that
these controls cannot be effectively and reliably
managed, then the LEA may need to clean the site
to residential levels, or select another location.
9.12. Does EPA recommend
buffer or exclusion zones (also
sometimes called distance criteria
or separation distances) to make
sure schools aren't built close to
major sources of pollution?
No, the guidelines do not include distance-based
buffer or exclusion zones for potential school
locations. EPA's approach to the School Siting
Guidelines is to encourage and promote an
integrated and holistic evaluation of a wide range
of community and location-specific criteria in
selecting the best location for a new school. The
distance between a school location and a major
source of pollution is only one of many complex
factors that influence whether that source poses
risks of concern to students and staff (see Exhibit
). These factors can only be effectively evaluated
on a case- and location-specific basis and require
consideration of the extent to which a specific
source raises a concern for a potential school
location, as well as the degree to which any risk
can be reduced or eliminated. Some states and
local governments have developed distance-based
requirements or guidance for schools and other
locations that may have sensitive receptors, and
while EPA does not believe that establishment of
buffer or exclusion zones at a national level is
appropriate, this should not be construed as a
criticism of those jurisdictions that have adopted
or are applying buffer or exclusion zones as a
useful tool.70
70 Examples include:
"Air Quality and Land Use Handbook: A Community Health
Perspective," California Environmental Protection Agency, California
Air Resources Board (April 2005). Available at:
http://www.arb.ca.gov/ch/handbook.pdf; Rhode Island Department of
Elementary and Secondary Education School Construction
Regulations. (May 24, 2007). Available at:
www.ride.ri.gov/regents/Docs/RegentsRegulations/Regents%20Schoo
l%20Constructions%20Regulations.pdf.
California Department of Education, "School Site Selection and
Approval Guide," Prepared by School Facilities Planning Division. Last
modified March 10, 2011. Available at:
www.cde.ca.gov/ls/fa/sf/schoolsiteguide.asp;
Links to additional state and local regulations and guidance are
available in the Resource section of the guidelines website.
(www.epa.gov/schools/siting/resources)
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EPA believes that establishing national distance
criteria is likely to result in a variety of negative
unintended consequences. For example, use of
national distance criteria as the basis for selecting
locations that are farther away from the children
they serve, without careful consideration of
location-specific factors, could create less healthy
environments for students and staff through
increased transportation risks, reduced
opportunities for walking and biking and
increased traffic-related air pollution.
EPA recommends that sound technical
assessments of both onsite and nearby potential
hazards be undertaken to determine whether
such potential hazards might pose a threat to
students or school staff (see Exhibit 6). Locations
should be excluded from further consideration if
nearby or onsite hazards pose unacceptable risks
that cannot be eliminated or reduced to an
acceptable level.
9.13. What is the difference
between "screening perimeters,"
which are included in the
guidelines, and "buffer" or
"exclusion" zones?
EPA has included some distance-based screening
recommendations in the Environmental Siting
Criteria Considerations section of these
guidelines under Exhibit 6: Screening Potential
Environmental and Safety Hazards (see Section
4). The screening perimeter distances are
approximate distances for use in the initial
screening process. During this initial screening
process, an environmental professional (see
Section 10), the LEA (see Section 10) and the SSC
should identify all potential hazards that are
within this distance of a prospective school
location and determine those that need further
evaluation. The screening distances included in
the guidelines are based primarily on existing
state or local rules, laws, ordinances, policies or
guidance and are intended as general rules of
thumb. Potentially important sources that may
be outside the recommended screening
perimeters may also be appropriate for further
evaluation.
Screening distances, alone, may not be predictive
of the actual potential for elevated exposures and
risks from that source. Exposure to contaminants
from a source could be nonexistent, or could be
significant. To determine the potential for
exposure, an assessment should be performed as
part of the school siting screening and evaluation
process. In contrast, buffer or exclusion zones
are based on a presumption that there is a high
potential for significant exposures from a source
located within that zone. LEAs should work with
the appropriate state response or tribal
regulatory program in assessing school locations
within the screening perimeter to determine if
facilities pose a risk sufficient to influence siting
location decisions or require alternative site
selection. In the event that a facility poses a
potential risk to students, staff, parents or others,
the resolution of any unacceptable risk
associated with that facility should be addressed
before the decision to site a school.
9.14. The School Siting
Guidelines place a lot of
emphasis on state and tribal
involvement in evaluating and
approving siting decisions
where environmental
contamination is present. At a
time of shrinking state and
tribal budgets, how are states
and tribes to meet the
anticipated demand for more
involvement?
EPA recognizes that elements of the
recommended environmental review process may
be beyond the current capacity of some LEAs and
other participants in the process to fully
implement with existing authorities, expertise and
resources (see Section 5). All state and most tribal
environmental regulatory agencies have programs
136 | Frequent Questions
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in place to evaluate and approve cleanup plans for
specific types of sites or projects (see Section 7).
EPA encourages LEAs, states, tribes, communities
and other interested organizations to work
collaboratively and with EPA to identify
opportunities to leverage these and other existing
resources as well as to identify and work toward
fulfilling needs for improving local and state
capacity to conduct as rigorous a process of site
evaluation as possible. EPA recommends that
LEAs work directly with the state and tribal
environmental response program regarding the
needed evaluation and approval of cleanup plans.
EPA also recommends that LEAs seek advice from
state and tribal environmental response programs
to ensure that long-term stewardship
responsibilities are effectively met. The Resources
page of the guidelines website contains potentially
helpful funding and capacity building resources.
(www.epa.gov/schools/siting/resources.htmWLI
NKS_Technical_Assistance)
9.15. Do the guidelines apply to
child care centers or other
facilities where children spend
time?
While the guidelines are primarily intended to be
used by LEAs in evaluating and selecting locations
for K-12 schools, EPA believes that the
recommendations in the guidelines represent a
set of best practices that may inform and improve
the evaluation and selection of locations for a wide
range of settings where children spend time.
However, EPA recognizes that there are many
differences across the types of child-occupied
facilities. For example most K-12 schools generally
have a clearly identifiable central authority and
significant (though not necessarily plentiful)
resources, while many child care centers are small
businesses with extremely limited resources and
subject primarily to state licensing authorities.
Nevertheless, the siting criteria considerations
(see Section 4), environmental review process
(see Section 5) and public involvement (see
Section 3) practices recommended within the
School Siting Guidelines may be applied, with
appropriate adaptation, to a wide range of school-
related institutions.
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10. Glossary
Terms not defined herein should have their
ordinary meaning within the context of their
use. Ordinary meaning is as denned in, for
example: "Webster's Collegiate Dictionary," see
the online version at www.m-w.com/.
A|B|C|D|E|F|G|H|I|J|K|L|M|N|0|
P|Q|R|S|T|U|V|W|X|Y|Z
All Appropriate Inquiries: The process of
evaluating a property's environmental conditions
and assessing potential liability for any
contamination. See All Appropriate Inquiries
Standard 40 CFR Part 312 (http://ecfr.gpoaccess.
gov/cgi/t/text/text-idx?c=ecfr&sid=c712de4f
bdbfd669e790daa37865a02e&rgn=div5&view=te
xt&node=40:27.0.1.1.9&idno=40), EPA Fact Sheet:
All Appropriate Inquiries Rule: Definition Of
Environmental Professional (www.epa.gov/
brownfields/aai/ep_deffactsheet.pdf), and ASTM
E1527-05 Standard Practice for Environmental
Site Assessments: Phase I Environmental Site
Assessment Process. (www.astm.org/Standards
/E1527)
Brownfield: A property, the expansion,
redevelopment or reuse of which may be
complicated by the presence or potential presence
of a hazardous substance, pollutant or
contaminant.
Capacity: The institutional, organizational,
technical and financial ability to address issues.
Used in the context of these guidelines as the
capacity of education agencies or local
governments to have the organization, staff,
technical and financial resources to safely operate
school facility risk reduction measures such as
lead encapsulation and to inspect, maintain and
ensure long-term stewardship of any institutional
or engineering controls designed to protect people
from residual site contamination following a
cleanup (see Section 8.15).
CERCLA: The Comprehensive Environmental
Response, Compensation, and Liability Act—
otherwise known as CERCLA or Superfund—
provides a federal "Superfund" to clean up
uncontrolled or abandoned hazardous waste sites
as well as accidents, spills and other emergency
releases of pollutants and contaminants into the
environment. Through CERCLA, EPA was given
power to seek out those parties responsible for
any release and ensure their cooperation in the
cleanup.
Comprehensive environmental review: A stage
in the environmental review process (see Section
5) that involves gathering and analyzing data on
environmental hazards and impacts identified in
the initial or preliminary environmental review
(see Section 5.6) and evaluating the risks posed to
children's health, public health and the
environment based on the contamination or
impacts found. The comprehensive environmental
review (see Section 5.7) also includes developing
preliminary plans and cost estimates for
mitigation/remediation measures.
Concentrated animal feeding operations
(CAFOs) or animal feeding operations (AFOs):
Agricultural operations where animals are kept
and raised in confined situations. AFOs generally
congregate animals, feed, manure, dead animals
and production operations on a small land area.
Feed is brought to the animals rather than the
animals grazing or otherwise seeking feed in
pastures. Animal waste and wastewater can enter
water bodies from spills or breaks of waste
storage structures (due to accidents or excessive
rain) and from nonagricultural application of
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manure to crop land. An AFO is a lot or facility
(other than an aquatic animal production facility)
where the following conditions are met:
• Animals have been, are or will be stabled or
confined and fed or maintained for a total of
45 days or more in any 12-month period; and
Crops, vegetation, forage growth or post-
harvest residues are not sustained in the
normal growing season over any portion of the
lot or facility. AFOs that meet the regulatory
definition of a CAFO may be regulated under the
National Pollutant Discharge Elimination
System (NPDES) permitting program. For
Regulatory Definitions of Large CAFOs, Medium
CAFOs, and Small CAFOs, see:
www.epa.gov/npdes/pubs/sector_table.pdf.
Criteria pollutants: The Clean Air Act requires
EPA to set National Ambient Air Quality Standards
for six common air pollutants. These common air
pollutants are found all over the United States.
They are particle pollution (often referred to as
particulate matter), ground-level ozone, carbon
monoxide, sulfur oxides, nitrogen oxides and lead.
These pollutants can harm human health and the
environment, and cause property damage. Of the
six pollutants, particle pollution and ground-level
ozone are the most widespread health threats.
EPA calls these pollutants "criteria" air pollutants
because it regulates them by developing human
health-based and/or environmentally-based
criteria (science-based guidelines) for setting
permissible levels. The set of limits based on
human health is called primary standards.
Another set of limits intended to prevent
environmental and property damage is called
secondary standards.
Engineering controls: For purposes of this
guidance, the engineered physical barriers or
structures designed to control or limit exposure to
residual onsite contamination. Engineering
controls are distinct from institutional controls.
Certain engineered cleanups routinely involve
ongoing operation and maintenance (O&M),
monitoring, reporting and evaluation.
Environmental justice: For the purposes of this
guidance, the fair treatment and meaningful
involvement of all people, regardless of race, color,
national origin or income with respect to the
development, implementation and enforcement of
environmental laws, regulations and policies.
Environmental professional: The qualifications
of an environmental professional needed to
conduct Environmental Site Assessments are
defined in ASTM International Standard El527-
05. (www.astm.org/Standards/E1527) Also see
EPA Fact Sheet: All Appropriate Inquiries Rule:
Definition Of Environmental Professional.
(www.epa.gov/brownfields/aai/
ep_deffactsheet.pdf)
Environmental review process: A series of steps
taken to determine whether a project will be
impacted by potential hazards. In the case of
school siting, the environmental review evaluates
potential environmental hazards and exposures to
children, staff and visitors before a decision is
made to site a school in a particular location.
Further action: Denotes step(s) during the
environmental review process that trigger
additional review, evaluation, remediation,
referral or other appropriate activity.
Greenfields: Locations, typically outside of cities,
that have not previously been developed.
Green schools: See term healthy high
performance schools in the glossary.
HAPs: Toxic air pollutants, also known as
hazardous air pollutants (HAPs), are those
pollutants that are known or suspected to cause
cancer or other serious health effects, such as
reproductive effects or birth defects, or adverse
environmental effects.
Health impact assessment (HIA): Most often
defined as "a combination of procedures, methods
and tools by which a policy, program or project
may be judged as to its potential effects on the
health of a population, and the distribution of
those effects within the population" (World Health
Organization, 1999). This broad definition from
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the World Health Organization European Center
for Health Policy, as presented in the Gothenburg
Consensus paper on HIA, (www.euro.who.int/
document/pae/gothenburgpaper.pdf) reflects the
many variants of HIA. A somewhat more precise
definition is that HIA is "a multidisciplinary
process within which a range of evidence about
the health effects of a proposal is considered in a
structured framework."
Healthy high performance schools: Facilities
that integrate all aspects of the design process
starting with selection of the design team and the
school location to design schools that meet
multiple educational, environmental and
community goals. The environmental goals of such
facilities include energy and water efficiency,
healthy indoor air, safer materials selection
(including life-cycle cost consideration) and
reduced environmental impact from the school.
The technologies and practices used to achieve
these goals are often integrated into the
curriculum and other student learning
opportunities.
High traffic roads: May include highways, local
roads experiencing heavy congestion, local roads
with significant stop-and-go activities and roads
with large numbers of trucks.
Institutional controls: Nonengineered
instruments, such as administrative and/or legal
controls, that help to minimize the potential for
human exposure to contamination and/or protect
the integrity of a remedy. See: EPA Citizen's Guide
to Understanding Institutional Controls (www.
epa.gov/fedfac/pdf/ic_ctzns_guide.pdf) and All
Appropriate Inquiries Standard 40 CFR Part 312.
(http://ecfr.gpoaccess.gov/cgi/t/text/text-
idx?c=ecfr&tpl=/ecfrbrowse/Title40/40cfr312_m
ain_02.tpl)
Joint use: The use of school district controlled,
owned or utilized facilities by a nondistrict entity
or the use of nonschool owned property, such as a
library or park or athletic facility, by a school.
There are five types of entities that constitute joint
users:
Individuals: Persons, generally residents of a
community, who have access to exterior spaces,
such as play equipment, athletic fields or courts,
and open space for personal use.
Civic Groups: Individuals, groups or
organizations who seek occasional use of school
buildings and grounds for activities or events
such as polling stations, community meetings
and special events.
Other Public Agencies: A public agency that is
not part of the school district that may offer
programs, need to lease space and offer no
program connection to the school and/or may
seek joint development with ongoing joint
programming.
Private Nonprofit Organizations: The use of
school buildings and/or grounds by a nonprofit
organization such as after-school programs,
health clinics or adult education classes.
Private Far-Profit Corporations: The use of
school building and/or grounds by a private for-
profit corporation, either for education-related
work like a private testing service or unrelated
work like private offices.
Joint use agreement (JUA): A formal agreement
between two separate government entities, often
a school and a city or county, setting forth the
terms and conditions for shared use of public
property or facilities. See: www.nplanonline.
org/nplan/joint-use.
Local education agency (LEA): Any entity,
whether public or private, including its staff and
its governing or voting body (e.g., a school board
or a tribal board) with responsibility for decision-
making with respect to school buildings and
operations.
Local community: General term referring to all
members of a local area with an interest in school
environmental health and safety issues, including
but not limited to local governments, local
education agencies (see term local education
agency in the glossary), nongovernmental
organizations and individuals.
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Location-specific remediation/mitigation:
Appropriate response measures, as prescribed in
a remedial action workplan, that are tailored to
the particular characteristics of the location in
question.
Long-range school facilities plan: A way for
local education agencies (LEAs) to identify
important projections of long-term school and
community needs such as student enrollment,
operational costs and infrastructure to use in
making school siting decisions.
Long-term stewardship: Long-term management
of contaminated environmental media to protect
human health and the environment, generally
through the use of engineering or institutional
controls (see Section 8.15).
LTSP: Long-term stewardship plan.
Meaningful public involvement: Fully engaging
stakeholder groups throughout the review and
decision-making process, including opportunities
to share opinions and review relevant documents.
Nearby hazard: A potential risk or hazard located
outside of the site property boundary.
Determining what is nearby depends on many
factors and will vary with type of potential hazard.
See Exhibit 5: Factors Influencing Risks from
Nearby Hazards and Exhibit 6: Screening Potential
Environmental, Public Health and Safety for more
information.
O&M: Operation and maintenance.
One call system: Centralized and integrated
phone-based system for obtaining information
from a single phone call on underground utilities
or other hazards prior to digging or excavation
(e.g., "Miss Utility").
PAH: Polycyclic aromatic hydrocarbons.
PCBs: Polychlorinated biphenyls (PCBs) belong to
a broad family of human-made organic chemicals
known as chlorinated hydrocarbons. PCBs were
domestically manufactured from 1929 until their
manufacture was banned in 1979. They have a
range of toxicity and vary in consistency from thin,
light-colored liquids to yellow or black waxy
solids. Due to their nonflammability, chemical
stability, high boiling point and electrical
insulating properties, PCBs were used in hundreds
of industrial and commercial applications
including electrical, heat transfer and hydraulic
equipment; as plasticizers in paints, plastics and
rubber products; in pigments, dyes and carbonless
copy paper; and many other industrial
applications.
Petroleum hydrocarbons or total petroleum
hydrocarbons (TPH): A large family of several
hundred chemical compounds that are derived
from crude oil. Some chemicals that may be found
in TPH are hexane, jet fuels, mineral oils, benzene,
toluene, xylenes, naphthalene and fluorene, as
well as other petroleum products and gasoline
components.
Phytoremediation: Describes the treatment of
environmental problems (bioremediation)
through the use of plants that mitigate the
environmental problem without the need to
excavate the contaminant material and dispose of
it elsewhere. See EPA Citizen's Guide to
Phytoremediation. (www.epa.gov/tio/
download/citizens/ci tphyto.pdf)
Preliminary environmental assessment: Initial
screening and review stage for candidate sites to
identify potential environmental issues related to
the suitability of a candidate school site, if any,
that should to be assessed in detail if the LEA
decides to pursue the site for use as a school
location.
Public involvement: See term meaningful public
involvement in the glossary.
Remedial action workplan: Detailed plan for
remediation of onsite contamination, including
cleanup methods, long-term maintenance
requirements and long-term stewardship
obligations.
School siting committee (SSC): Committee
established to make recommendations to the
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LEA's governing body on sites for building new
schools, leasing space for new schools and/or
renovating or expanding existing schools. The
committee includes representatives of the LEA's
governing body (such as elected school board
members, facility, health and safety staff), local
government or tribal staff (such as city planners,
government environmental health specialist,
county auditor) and representatives from
stakeholder groups (such as parents of children
likely to attend the new school, teachers, public
health organizations, community members,
environmental advocacy and environmental
justice groups, age-appropriate students, local
trade/building associations).
Screening perimeter: Screening distances
intended to identify potential land uses near
candidate school locations that warrant further
consideration rather than to identify land uses
that may be incompatible with the location of
schools. Screening distances, alone, may not be
predictive of the actual potential for a source
located within that distance to present an
environmental or health hazard. Potential hazards
associated with candidate school locations should
be evaluated as part of the site screening and
evaluation process.
SVOC: Semi-volatile organic compound.
TPH: Total petroleum hydrocarbon.
Transparent: Readily accessible and
understandable by all community members (e.g.,
decision-making criteria and procedures should
be transparent).
Vapor intrusion: Migration of volatile chemicals
from contaminated ground water or soil into an
overlying building. For more information, see the
discussion on this topic in the Quick Guide to
Environmental Issues, see Section 8.
VOCs: Volatile organic compounds (VOCs) are
emitted as gases from certain solids or liquids.
VOCs include a variety of chemicals, some of
which may have short- and long-term adverse
health effects. Concentrations of many VOCs are
consistently higher indoors (up to 10 times
higher) than outdoors. VOCs are emitted by a wide
array of products numbering in the thousands.
Examples include: paints and lacquers, paint
strippers, cleaning supplies, pesticides, building
materials and furnishings, office equipment such
as copiers and printers, correction fluids and
carbonless copy paper, graphics and craft
materials including glues and adhesives,
permanent markers and photographic solutions.
Zoning and land uses: Zoning codes are
developed to regulate the location and type of
development in a given area. Zoning can
determine the land use of a particular location,
such as residential, commercial or industrial.
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