How can EPA better leverage the Partnership for Sustainable Communities with HUD, DOT, EDA and other federal agencies to bring implementation resources to projects?
EPA’s Brownfield Program continues to look to the future by expanding the types of properties it addresses, forming new partnerships, and undertaking new initiatives to help revitalize communities across the nation. Under the Partnership for Sustainable Communities, EPA is working with the U.S. Department of Housing and Urban Development (HUD) and the U.S. Department of Transportation (DOT) to help improve access to affordable housing, more transportation options, and lower transportation costs while protecting the environment in communities nationwide.
Editor's Note: The opinions expressed in Greenversations are those of the author. They do not reflect EPA policy, endorsement, or action, and EPA does not verify the accuracy or science of the contents of the blog.
It is HUD policy, in dealing with 24 CFR 58.5(i), that “(1)… all property proposed for use in HUD programs be free of hazardous materials, contamination, toxic chemicals and gasses, and radioactive substances, where a hazard could affect the health and safety of occupants or conflict with the intended utilization of the property. (2) HUD environmental review of multifamily and non-residential properties shall include evaluation of previous uses of the site and other evidence of contamination on or near the site, to assure that occupants of proposed sites are not adversely affected by the hazards…”
Currently (it is my understanding and I may be wrong) HUD requires a Phase I ESA for “sites known or suspected to be contaminated by toxic chemicals or radioactive materials include but are not limited to sites: (i) listed on an EPA Superfund National Priorities or CERCLA List, or equivalent State list; (ii) located within 3,000 feet of a toxic or solid waste landfill site; or (iii) with an underground storage tank.”
Seems to me that there’s an opportunity for communities to expand the traditional scope of the 104(k) Assessment Grants to conduct Phase I and Phase II ESAs on HUD, USDA and EDA projects. From my experience, “Responsible Entities” using Federal HUD, USDA and EDA dollars have steered clear of sites that fail the three criteria above. This, in turn, translates into sprawl and bigger challenges with redeveloping brownfields. Most sites on the “equivalent State List” have manageable levels of contaminants that could be redeveloped but Responsible Entities steer clear because of the perceived and (in some cases) real hurdles compared to a clean piece of property. Like chlorinated solvents, Responsible Entities choose the path of least resistance when it comes to economic development.
EPA and its federal partners should consider identifying SPECIFIC Programs/requirements/tasks (like the HUD instance mentioned above) and then educating the HUD/USDA/EDA stakeholders of these potential opportunities.