Before You Begin

What is the Planned End Use? A Word About Redevelopment

It is important to consider potential redevelopment plans from the outset of any brownfields project. The redevelopment plan (or lack thereof) will govern most brownfields projects, from the identification of site investigation and cleanup standards and the ability to obtain financing to the ultimate affordability or profitability of the project.

Defining and understanding the long-term goals of the brownfields project and the decisions to be made throughout the project is a crucial element in identifying appropriate technologies for site investigation and cleanup. Technology tools, when carefully selected, will assist those responsible for the brownfields project in collecting the data necessary to support such decisions and accomplish the established goals. During the many phases of a brownfields project, it is important to keep in mind that technology options are an effective means of achieving the desired result at a site, rather than an end in themselves.

Brownfields projects may be initiated for a number of reasons. A landowner may want to sell a property to a prospective purchaser for development. A municipality may want to clean up a parcel or area that has become an eyesore, create space for business development, or create a park in a disadvantaged area. A local comprehensive plan may call for infill development of a certain type in a brownfields area. The brownfields process will be tailored to the specific end use, if that use is known. For example, if the redevelopment plan calls for the construction of a light industrial facility, it may be appropriate, depending on state and local regulatory requirements, to apply industrial investigation and cleanup standards that are less stringent than those applicable to property that is to be redeveloped for residential use. The standards required will affect every aspect of the project, from its overall cost (which is generally greater as the standards become more conservative) to the applicability of innovative characterization and cleanup technologies. Keep in mind, however, that new information about contamination or cleanup may require that reuse plans be altered; develop flexible plans so that revised cleanup needs can be incorporated into them.

If the end use is not known at the beginning of the project, the individuals involved should make every attempt at least to identify the general type of desired development, whether industrial, commercial, or residential or a mixed-use development of some sort. Absent that information, the most conservative assumptions will be made at every stage of the brownfields project, a circumstance that could increase significantly the time and expense of the project and may even make it infeasible.

Understanding Regulations and Regulatory Guidelines and Standard Industry Practices

The redevelopment of brownfields sites may be subject to a variety of federal, state, and local laws, regulations, policies, and guidelines with respect to the characterization and cleanup of the site. Such sites also may be governed by the standard practices of other government, nongovernment, and private institutions.

The applicable laws, regulations, policies, and guidelines will vary by site, depending on the regulatory authority that manages the cleanup. Therefore, it is important to research this information at the outset and to work closely with the regulatory authority throughout the cleanup process. For example, state or local regulatory authorities may manage the cleanup of brownfields sites. These agencies should be consulted to determine what, if any, site-specific requirements or permits are applicable.

Many of the standard practices are designed to help the brownfields redevelopment project obtain financing from public programs and private banks and institutions. Guidance and standards are issued by government and nongovernment organizations, such as the American Society for Testing and Materials (ASTM), the Federal Deposit Insurance Corporation (FDIC), and state and local economic development authorities, and even private lenders.

EPA also can be a valuable resource for brownfields stakeholders by providing regulatory and policy support to facilitate selection of technologies (see EPA Regional Brownfields Contacts and EPA Technical Support Contacts).

Although compliance with regulations and official policy directives issued under other federal regulatory and cleanup programs such as Superfund may not be required, some of the information gathered under such programs may be useful in the investigation and cleanup of brownfields sites. For some sites, existing information provides a basis of understanding of site activities and conditions.

Additionally, lessons learned about site characterization strategies help to refine the process. For example, in the past, a number of sampling events and field mobilizations have been required at many RCRA and Superfund sites to gather sufficient information to characterize the sites adequately. Additional sampling was necessary to assess all potential contaminants, to adequately analyze all pathways of exposure, to obtain representative samples of wastes and environmental media, and to obtain analytical results of the appropriate accuracy to enable regulatory authorities to make cleanup decisions with confidence. Streamlining the process may decrease costs and reduce the decision-making period for selecting options for site cleanups.

EPA has shown its support for the adoption of streamlined approaches to sampling, analysis, data review, and data evaluation during site assessment, characterization, and cleanup in a number of technical and guidance documents. Brownfields sites are well suited for use of the Triad approach (see Spotlight 7, The Triad Approach: Streamlining Site Investigations and Cleanup Decisions), as limited funding and plans for reuse strongly influence decisions about cleanup. Inherent in the Triad approach is the need for cooperation and collaboration among the many stakeholders in the process. The Triad approach and the Brownfields Initiative reinforce each other in their emphasis on a common-sense approach in which barriers are removed and dollars are leveraged to provide the most cost-effective and streamlined strategy for monitoring and measurement activities. Use of real-time measurement technologies as well as a rigorous planning process to understand and control sources of uncertainty is inherent to the Triad approach and helps stakeholders improve the reliability of risk-related decisions.

Recognizing that rigorous planning is important, the approach should remain flexible and dynamic and should allow for adjustments in the field in light of actual site conditions observed and sample analytical results. Such a dynamic approach usually requires a well-rounded technical team that has a broad range of technical expertise and use of field analytical technologies, including an on-site mobile laboratory, to provide quick-turnaround analyses.

Seeking and Procuring External Professional Support

Most decision-makers for brownfields sites will require technical and legal assistance to fully understand the complexities of investigating and cleaning up contaminated sites. Depending upon the complexity of a particular site, decision-makers may request the assistance of environmental consultants, cleanup contractors, technology vendors, or analytical laboratories in performing the many activities required to investigate and clean up the site. The inclusion of these professionals and other experts as members of the brownfields team is recommended.

Some states may require the participation of certified or licensed professionals to help guide the site investigation and cleanup process. To obtain the services of such professionals (individuals or a firm), a request for proposal (RFP) is often used as the procurement mechanism. The RFP addresses the approach, qualifications, and cost estimate for the services requested and includes specifications that encourage prospective bidders to think “outside the box” and consider nontraditional approaches. Selection criteria outlined in the RFP should include the demonstrated experience of the individuals or firm in developing valid options for using streamlined strategies and innovative technologies at brownfields sites and in successfully implementing the selected options.

To ensure that those individuals or firms responding to an RFP propose approaches that are valid for the site, the RFP also should include, or make readily available, all studies and reports that provide site-specific information that can be used as the basis for making technology decisions. Individuals preparing RFPs may wish to be proactive and provide suggestions for the use of specific strategies and technologies that appear to be valid for the particular site. When reviewing proposals and interviewing firms, the evaluation team must be prepared to ask pointed, detailed questions about the selection and use of technologies to be assured that the individual or firm chosen to perform the work is qualified to complete the project successfully. Described in this Road Map are many excellent resources that will assist brownfields decision-makers in preparing specifications to be included in RFPs, selecting the criteria for evaluating proposals, and developing questions for interviews of those responding to the RFP. For example, see EPA’s Brownfields Technology Primer: Requesting and Evaluating Proposals That Encourage Innovative Technologies for Investigation and Cleanup for more information.

Community Involvement

It is important that brownfields decision-makers encourage acceptance of redevelopment plans and cleanup alternatives by involving members of the community early in the decision-making process through community meetings, newsletters, or other outreach activities. For an individual site, the community should be informed about how the use of a proposed technology might affect redevelopment plans or the adjacent neighborhood. For example, the planting of trees for the use of phytoremediation may create aesthetic or visual improvements; on the other hand, the use of phytoremediation may bring about issues related to site security or long-term maintenance that could affect access to the site.

EPA can assist members of the brownfields community by directing its members to appropriate resources and providing opportunities to network and participate in the sharing of information. A number of Internet sites, databases, newsletters, and reports provide opportunities for brownfields stakeholders to network with other stakeholders to identify information about cleanup and technology options. As noted in the preceding section, EPA’s Brownfields and Land Revitalization Technology Support Center is a valuable resource for brownfields decision-makers.

Comparing Innovative Technologies to Other Characterization and Cleanup Options

In addition to innovative site characterization and cleanup technologies, the use of established treatment and containment technologies also should be considered. Examples of established treatment technologies include solidification/stabilization, soil vapor extraction, thermal desorption, incineration, and pump-and-treat. (For a complete list and description of the technologies, see the Treatment Technologies for Site Cleanup: Annual Status Report (Eleventh Edition). Examples of containment include containing contaminated soil on site using a cap and limiting migration of contaminants using a vertical engineering barrier such as a slurry wall. In either case, containment does not involve actively treating the waste to recover or degrade contaminants. When deciding between innovative and established technologies or between treatment and containment technologies, or other options, brownfields decision-makers should consider the specific needs of the individual site and stakeholders. It also is important that brownfields decision-makers consider both the current effects of the selected technology approach and its future effects on potential development of the site.

	A Quick Look
Focus on the decisions that support site goals
Build consensus
Understand the technology
Allow flexibility

Selecting and Accepting Technologies

The successful cleanup of a brownfields site depends on the selection and acceptance of a specific technology or technology approach. Identified in the box are the key elements to ensure that a proposed technology will be accepted by all stakeholders, whether site owners, potential buyers, financial service providers, investors, regulators, or affected citizens. Spotlight 6, Keys to Technology Selection and Acceptance describes in detail these key elements.

Information Centers, Training, and Other Resources

Described below are some of the resources available to brownfields projects from government and nongovernment institutions, including the various EPA hotlines for statutory and regulatory programs that may affect brownfields projects. The resources provide more general information than the technology resources identified in the chapters that follow. Training courses and programs provided by EPA, as well as other organizations, also are identified. Information about state and local resources can be obtained from the contact for each state found in State Brownfields Contacts, EPA Regional Brownfields Contacts and EPA Technical Support Contacts.