Brownfields: Potential for Urban Revitalization
Brownfields: Potential for Urban Revitalization
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EXECUTIVE SUMMARY
PURPOSE
To help the nation address environmental concerns associated with idled, underutilized or abandoned urban
industrial and commercial properties, EPA announced the Brownfields Economic Redevelopment Initiative
(Initiative). The overall purpose of the Initiative is to help put urban Brownfield facilities back to sustainable
and beneficial reuse.
Using information gathered in the survey phase of this audit, along with input from the Outreach and Special
Projects Staff (OSPS), and a written request from the Acting Assistant Administrator for Solid Waste and
Emergency Response, we developed the following audit objectives: 1) determine whether pilot funds were used
for activities authorized under CERCLA §104; 2) determine whether pilot funds have impacted Brownfields
redevelopment;
3) determine whether EPA quality assurance requirements were adhered to; and 4) determine whether the terms
and conditions governing the revolving loan fund will permit its effective use.
| RESULTS IN BRIEF
Overall, the Initiative has generated considerable attention from cities, states, tribes, other federal agencies, and
congressional leaders. EPA has awarded 121 site assessment and 24 revolving loan fund grants to cities and
states. EPA has been instrumental in bringing together numerous federal agencies to work cooperatively toward
removing barriers to the redevelopment of Brownfields. Our review also showed that cities have been able to
leverage millions in private Brownfields investment. The number of Brownfield assessment demonstration
pilots as well as the Initiative's budget has grown steadily. Within the next three years, EPA plans to fund a total
of 300 assessment demonstration projects. The Agency has accomplished a great deal in a relatively short time.
Our report identifies actions the Agency can take to strengthen the Initiative and continue to move the program
forward.
A Better Focus Could Lead to More Successful Pilot Projects
The five cities that we visited were using EPA funds to conduct site assessments, develop inventories, conduct
community involvement activities, and develop Brownfield work groups and forums. While these activities are
authorized under CERCLA §104, we found that some have had relatively little impact on actual redevelopment.
We believe there is a need for the Agency to improve the focus of future pilots as well as a need to assist cities
in developing technical expertise to continue the Brownfields program after pilot funds have been expended.
Maintaining the Brownfields momentum and leveraging private Brownfield investments require successful
redevelopments. Because success breeds success, EPA should encourage cities to focus their efforts on those
activities which have the greatest potential for promoting rapid site redevelopment. This could be achieved by
revising EPA's evaluation criteria used for the selection of pilot projects to focus on those activities designed to
bring about timely redevelopment.

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Quality Assurance at Brownfield Sites
Because the underlying goal of the Brownfields Initiative is to see facilities put back to sustainable and
beneficial reuse, cleanup must be sufficient to protect the health and safety of those that will be occupying the
former industrial property. To ensure that environmental data collected as part of a site assessment is of a
known quality and that decisions made as a result of the data collected are defendable, EPA developed a
planning tool known as the Quality Assurance Project Plan (QAPP). Two cities in our sample did not develop
site-specific QAPPs as required by the National Contingency Plan and Agency policy. Uncertainties as to the
amount of quality assurance needed for Brownfield sites led the Agency to form a work group to address this
issue. The work group has drafted a Quality Assurance (QA) guidance document for Brownfield site
assessments and plans on finalizing it during fiscal year 1998.
Brownfields Cleanup Revolving Loan Fund
City officials indicated that many of the sites that have the greatest potential for redevelopment may not be
redeveloped due to the restrictions placed on the use of the funds by CERCLA and the requirements of the
National Contingency Plan. Most notably, recipients pointed to the restrictions CERCLA places on using funds
to cleanup asbestos, lead based paint, and petroleum. These restrictions, rather than the administrative terms and
conditions of EPA's grants, may limit the usefulness of the revolving loan funds.
We recommend that the Acting Assistant Administrator for Solid Waste and Emergency Response:
•	Revise EPA's proposal evaluation and ranking criteria to give credit and higher ranking to those cities
whose work plan: identifies sites; proposes to conduct site assessments; contains the largest number of
components of a successful redevelopment effort; contains specific objectives and milestones; and
contains in-house technical expertise or a commitment from the city to obtain or develop technical
expertise.
•	Remind project officers and assistance recipients of the need for EPA-approved QAPPs prior to
beginning field work.
•	Issue the Brownfields QA guidance to the regional offices and provide copies of the guidance to current
and future pilot recipients.
•	Explore legislative and regulatory alternatives to help cities address the restrictions and requirements
placed on the Revolving Loan Fund by CERCLA and the National Contingency Plan.
Agency Response & OIG Evaluation:
The Office of Solid Waste and Emergency Response agreed with each of the recommendations in the draft
report and provided planned corrective actions as well as milestone dates for completion. The specific
corrective actions planned are included after each chapters's recommendations and the response is included in
its entirety as Appendix A.
We believe the corrective actions underway and planned by the Agency address the report's recommendations,
therefore, we are closing this report upon issuance. No further response by the Agency is necessary.

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