Project Report

Look around you. We have more than 2,000 people
here today -- mayors, community activists, environmentalists,
developers, bankers, entrepreneurs, officials from all levels
of government -- and we're all working together toward a common
vision: clean, safe, healthy, thriving communities across America.

Carol M. Browner
Administrator
U.S. Environmental Protection Agency
Opening comments at Brownfields '98
Los Angeles, California
16 November 1998

"Brownfields" have been defined by the U.S. Environmental Protection Agency (EPA) as "[a]bandoned, idled, or under-used industrial and commercial facilities where expansion or redevelopment is complicated by real or perceived environmental contamination." The U. S. Conference of Mayors has characterized brownfields as "dead zones" and as "pockets of disinvestment, neglect and missed opportunities" that exist within American cities. In part, the scope of the problem can be seen by the sheer number of brownfield sites. The U.S. General Accounting Office, for example, has concluded that there may be between 130,000 and 450,000 contaminated commercial and industrial sites located within the United States. By another estimate, as many as 650,000 brownfield sites may be located throughout the country.

Brownfields exist in a wide variety of urban settings. In a recent study undertaken by the U.S. Conference of Mayors, 126 cities responding to a request for information reported a total of 16,531 brownfields sites and 122 cities reported a total of 47,384 acres of urban land consumed by brownfields. The problem arises irrespective of the size of the city. In the same study, 88 cities having populations of less than 100,000 reported 1,465 brownfields sites consuming 16,000 acres of urban land and 53 cities having populations of less than 50,000 reported 618 brownfields sites consuming 6,305 acres of urban land. To provide the proper perspective, it must be remembered that there are more than 18,000 cities and towns in the United States.

The costs associated with brownfields are significant. In terms of lost tax revenues, for example, the Conference of Mayors also conducted a survey of 33 cities within which brownfields are located. The lost tax revenues were estimated to range between $121 million and $386 million per year in these cities alone. On a national scale, local governments "could be losing billions of dollars each year in local tax receipts resulting from their failure to restore brownfields to economic viability."

It has been argued that the redevelopment of brownfields will have significant positive economic benefits by creating new employment opportunities, improving quality of life and increasing the municipal tax base once redeveloped properties are returned to the tax rolls. This is especially important if ad valorem taxation is the basis for public school funding and the provision of other municipal services. As these benefits accrue, urban neighborhoods should be revitalized.

In addition, it has been suggested that the redevelopment of brownfields could serve as a check or constraint on urban sprawl by reducing developmental pressures on greenfields. This is an issue of growing concern. According to the American Farmland Trust, between 1982 and 1992, 13,823,000 acres of land were converted to urban use. Of this total, 4,266,000 acres were either prime or unique farmland. In fact, at the present time, farmland in the United States is being lost to urbanization at a rate of approximately two acres per minute.

Unfortunately, the cost of restoring brownfields to economic viability may be beyond the capability of many state and local governments. Though remediation costs are always site-specific, total remediation costs for all of the brownfields located within the United States have been estimated to exceed $650 billion. Consequently, it is imperative that private capital be attracted to the redevelopment of brownfields.

In 1997, the U.S. Environmental Protection Agency (EPA) and The George Washington University (GWU) entered into a cooperative agreement to attempt to answer certain questions relating to the redevelopment of brownfields. The first question focused on the extent to which the redevelopment of brownfields reduced developmental pressures on undeveloped suburban or rural areas ("greenfields"). The second question concerned economic benefits that are induced by the redevelopment of brownfields. Statutes and regulations that either inhibit the redevelopment of brownfields or that encourage the development of greenfields were the focus of questions three and four. Question three addressed federal statutes and regulations while question four addressed statutes and regulations at the state and local level.

To answer these questions, a "Work Plan" was developed and submitted to EPA in December of 1997. The research described in the "Work Plan" has been completed and is summarized herein. This research sheds light on answers to two key, higher-level, questions. First, does the redevelopment of brownfields actually serve as a check or constraint on urban sprawl? Second, what are the critical factors (and the relative weights of those factors) that most influenced specific decisions to redevelop brownfields?

The methodology used to answer these questions is discussed in Chapter 3: Research Approach and Methodology. With regard to questions concerning the degree to which brownfields redevelopment may serve as a check or constraint on urban sprawl, one of the primary means of determining the relationship between the redevelopment of brownfields and the reduction of developmental pressures on greenfields was to conduct a series of in-depth interviews with both public and private sector individuals involved in the redevelopment of brownfields in selected metropolitan areas. The results of these interviews formed the principal basis for determining areal differentials ("offsets") between the redevelopment of brownfields and the development of greenfields. These interviews provided site-specific information on successful brownfields redevelopment projects. This information was utilized to calculate the minimum amount of land that the redevelopment project would have required if it had been developed in a greenfields area. The results from these calculations are presented in Chapter 5: Brownfield/Greenfield Tradeoffs. These interviews also provided information on the extent to which individuals making redevelopment decisions considered greenfield development as an alternative to the redevelopment of a brownfield (or vice versa).

With regard to critical factors most influencing specific decisions to redevelop brownfields, the interviews also formed the principal basis for determining critical factors that most influenced redevelopment decisions. These critical factors (as well as the relative weights of the factors) are summarized in Chapter 7: Impediments and Incentives to the Redevelopment of Brownfields.

Conclusions are presented in Chapter 8 with the Bibliography following. Appendix A lists all of the individuals who were interviewed during the course of the study. Detailed information on the metropolitan areas that were included in the study is presented in Appendix B. The phase one interview form and the sample tract illustrations that were used during the interview process are attached as Appendices C and D, respectively. The individuals and organizations contacted during an Internet-based survey are listed in Appendix E. Appendix F contains detailed information on the sites and the calculations that form the basis for the determination of areal differentials.

1.2 Importance of the Study

The U.S. Conference of Mayors has made the redevelopment of brownfields its highest priority. The reasons are both simple and complex.

Simply stated, it is imperative that land be recycled, not abandoned. The hundreds of thousands of acres of land that have been abandoned in metropolitan areas throughout the United States, most of which falls within the definition of brownfields, have had profoundly negative impacts on those areas. In many instances, the key to revitalizing these metropolitan areas is the redevelopment of brownfields. Such redevelopment projects may be the "seed crystal" around which urban revitalization may coalesce.

In addition, there are other (and more complex) reasons for removing barriers to the redevelopment of brownfields and for providing incentives to encourage such development. One reason is environmental justice. Suburban areas have continued to grow, aided in large measure by "white flight" from the cities. This population shift has left many cities with fewer citizens. Of those citizens who remain, an increasing percentage consists of low income or members of minority groups, or both. Within this context can be seen a pattern of private industry abandoning urban lands when the continued use or redevelopment of those lands is no longer convenient or economically justifiable. As a result, abandoned lands disappear from the tax roles and make it progressively more difficult for cities to maintain urban services because of the loss of tax revenues. The resulting decline in the quality of life is imposed on the residents remaining in the cities, not on the individuals or companies who chose to abandon their properties and leave the cities.

A better understanding of the critical factors that influence brownfield redevelopment decisions and of the areal differentials that exist between brownfield redevelopment and greenfield development will have benefits to the local community, to the metropolitan area within which the community is located, to the nation and to the world.

Facilitating the redevelopment of brownfields will have profound effects on the local community. Redeveloping such properties should return them to the tax roles and allow the local community to benefit from ad valorem taxation. This, in turn, would increase available funding for the full range of public services including such essential functions as education and health care. Redevelopment projects should provide new employment opportunities. Such projects also reduce urban crime and facilitate law enforcement by removing abandoned buildings and restoring private security functions. Perhaps most importantly, brownfield redevelopment projects renew the spirit of a community and revitalize the residents of that community. In many instances, redevelopment projects involve the restoration of historic properties, restoration of which provides "a sense of place" and improves the quality of urban life significantly.

Many of the benefits described above are also regional benefits. A reduction in crime rates, for example, benefits the entire metropolitan area within which the community is located, not just the community in which crime rates have been reduced. Redeveloping brownfields should have the effect over time of reducing the amount of financial assistance that many cities need in order to provide essential public services. As need for financial assistance declines, so would the obligation of governmental entities at all levels to provide such assistance. The economic benefits resulting from the redevelopment of brownfields will be felt throughout the metropolitan area within which the community is located. These benefits are not limited to the community itself. Brownfield redevelopment projects that provide employment opportunities near areas where community residents live have the effect of reducing commuting needs. This produces positive benefits both from an air quality perspective and as a means of reducing vehicular congestion. As discussed herein, redevelopment of brownfields also acts as a check on urban sprawl by reducing development pressures on greenfields.

In one form or another, much of the financial assistance received by many communities comes from the federal government. The redevelopment of brownfields could reduce the need for such financial assistance. In many ways, the benefits to nation are similar to the benefits to the metropolitan area: Reduction in crime, increase in employment, economic growth with concomitant increases in tax revenues and reduction in demands for assistance. Related to these benefits is assistance in achieving the goals of a number of federal environmental protection statutes, including attainment of the National Ambient Air Quality Standards of the Clean Air Act. The revitalization of specific communities also could assist in achieving national environmental justice goals.

The problem of abandoned urban properties is not unique to the United States. As the world of the present becomes a "post-industrial" world, the problem of abandoned properties (particularly abandoned industrial properties) has become one of global dimension. The ways in which such properties are redeveloped in the United States could provide a model that would be applicable in many areas of the world. This is particularly true with regard to alternative means of financing redevelopment projects. The public-private partnership approach that has been utilized in many communities could be implemented in urban areas throughout the world. The likelihood of this occurring has been enhanced by the increasing presence of multinational corporations.

To improve understanding of the role that brownfields redevelopment may play as a check or constraint on urban sprawl and to facilitate the redevelopment of brownfields by helping to eliminate barriers and provide incentives for such redevelopment.

This problem may be resolved through the investigation and solution of the subproblems identified in the following section.

In order to accomplish the purposes of this study, the following subproblems must be resolved:

Subproblem 1: To determine the extent to which the redevelopment of brownfield sites
reduces developmental pressures on undeveloped or rural areas ("greenfields.")

Subproblem 2: To identify benefits induced by the redevelopment of brownfield sites and to utilize benefit information to help prioritize brownfield site redevelopment efforts.

Subproblem 3: To identify federal statutes, regulations and policies that either inhibit the
redevelopment of brownfield sites or that encourage the development of greenfield sites and to determine the critical factors that influence decisions to redevelop brownfield sites and the relative weights for those factors.

Subproblem 4: To identify state and local statutes, regulations and policies that either inhibit the redevelopment of brownfield sites or that encourage the development of greenfield sites and to determine the critical factors that influence decisions to redevelop brownfield sites and the relative weights for those factors.

In addressing Subproblem 1, the principal research approach involves the determination of the areal differentials that exist between the amount of land that would be required for the development of specific projects utilizing brownfields as compared to the amount of land that would be required if development occurred on greenfields.

Three component questions must be answered to successfully resolve the first subproblem. First, what are the areal differentials? Second, to what extent can these areal differentials be confirmed utilizing secondary or tertiary sources of information? Third, in the context of specific development or redevelopment decisions, to what extent did individual decision makers consider greenfield development as an alternative to the redevelopment of a brownfield (or vice versa)?

In terms of resolving subproblem one and its component questions, it is essential to determine the minimum amount of land that a brownfield redevelopment project would have required if it had been located in a greenfield area. It would be helpful if these differentials could be validated utilizing secondary or tertiary sources of information. Finally, in order to facilitate the redevelopment of brownfields, it is important to understand the extent to which individual decision makers considered the redevelopment of brownfields as an alternative to the development of greenfields (and vice versa).

Key component questions in addressing Subproblems 3 and 4 involve the determination of critical factors that influence decisions to redevelop brownfields and the relative weights of those factors. Four component questions must be answered to successfully resolve these subproblems. First, what are the critical factors (and the relative weights of these factors) that most influence decisions regarding the redevelopment of brownfields? Second, do federal or state statutes or regulations impose barriers to the redevelopment of brownfields? Third, of those federal or state statutes or regulations that provide incentives for the redevelopment of brownfields, which have been successful? Fourth, of those federal or state statutes or regulations that provide incentives for the redevelopment of brownfields, which have not been successful?

The specific need is to determine and weigh those factors that most influence private decisions to invest in brownfield redevelopment projects. Information is needed regarding the factors that lead to decisions to redevelop brownfield sites rather than to develop greenfields. In essence, it is necessary to ascertain the key variables that influence both public and private land use decisions regarding the redevelopment of brownfields. It is also necessary to determine the extent to which federal or state statutes and regulations are either encouraging or inhibiting the redevelopment of brownfields.

In order to address the problem, subproblems and component questions identified in the preceding chapter, the first step was to undertake a comprehensive review of relevant literature. The primary purpose of the literature review was to determine key variables that were presented as either inhibiting or enhancing the redevelopment of brownfields. The results of this literature review are presented in Chapter 4.

In order to understand the relationship between the redevelopment of brownfields and the development of greenfields, it was necessary to determine which of the key variables identified during the literature review were, in fact, critical factors affecting individual decisions. To make this determination, two series of interviews were conducted with public and private sector individuals involved either in the redevelopment of brownfields or the development of greenfields in selected metropolitan areas.

Two groups of study areas were selected. The first group, which was intended to lead to an understanding of both the key variables that influence public and private land use decisions and the relationship between the redevelopment of brownfields and the development of greenfields, included six metropolitan areas meeting the following three criteria: First, the population of the core city within the metropolitan area either was declining or had remained relatively stable. Second, the total population of the metropolitan area was increasing. Third, the study area had to include an EPA Pilot Program city.

In terms of fulfilling the requirements of these criteria, population changes in Pilot Program cities were compared to population changes in adjoining or nearby areas using Bureau of the Census population data. This comparison produced a differential that was a representation of the population changes in the two areas. These differentials were then ranked and the six areas with the greatest differentials were selected for inclusion in the study.

A similar selection procedure was utilized to select the second group of metropolitan areas. These additional areas were included in order to make the results of the study as robust as possible for brownfield redevelopment projects in a variety of metropolitan areas.

As noted above, the Pilot Program cities and the metropolitan areas within which they are located were ranked according to the population differentials previously discussed. Once this ranking had been completed, six study areas were identified as follows: Two study areas were selected from that third of the continuum having the greatest population differentials, two study areas were selected from that third of the continuum having the lowest population differentials and two study areas were selected from the middle third of the continuum. Because the third of the continuum having the greatest population differentials overlaps with the criteria that were utilized for the selection of the first six study areas, a total of ten study areas were selected.

The assumption upon which selection of the study areas was based is that brownfields are more likely to have been redeveloped in cities where the differential is lowest (where population changes in the city and the surrounding area have been relatively equal) than in cities where the differential is greatest (where the surrounding area has continued to grow but the city has not). The selection of these study areas was subject to EPA approval. Concern was expressed that certain areas of the United States were not represented by the study areas that had been selected initially. As a result, utilizing the same selection criteria and population differentials noted above, the selections were adjusted slightly to be more representative. The two groups of study areas are depicted in the following two tables.

Study Areas Selected to Assist in the Determination of Key Variables Influencing the Relationship Between Brownfields Redevelopment and Greenfields Development and to Provide Project-Specific Data as Needed to Calculate Brownfields/Greenfields Offsets

Additional Study Areas Selected to Assist in the Determination
of Key Variables Influencing the Relationship Between
Brownfields Redevelopment and Greenfields Development

Materials were compiled on brownfields redevelopment activities in each of the study areas. These materials included summaries of brownfields redevelopment activities within each study area, summaries of state initiatives and programs for the state in which the study area is located, case studies of brownfields redevelopment projects and other materials such as articles and reports that related to specific brownfield redevelopment activities. These materials were reviewed in anticipation of interviews in each of the study areas.

In addition to the compilation of materials, lists were prepared of appropriate individuals to interview in each of the study areas. Included on the lists were the EPA brownfield coordinators for the specific regions within which the study areas were located, appropriate state and local governmental representatives, representatives of the business and economic development communities and representatives of other stakeholder groups (e.g., environmental justice advocates).

After these lists had been compiled, specific individuals within each of the study areas were contacted and, if possible, an interview was scheduled. The scheduling of these interviews was then confirmed through a telefax sent to each of the individuals to be interviewed. In addition to confirming the time and location of the interview, this telefax explained the background of the research project and indicated in general terms the questions that would be asked during the interview.

3.4.1 Phase One Interviews

The phase one interviews were conducted primarily with public sector individuals involved in the redevelopment of brownfields in the study areas. These interviews had two primary purposes.

The first purpose was to identify specific individuals who had been involved in successful brownfield redevelopment projects. These individuals, who would become the focus of the phase two interviews, were identified only for the six study areas having the greatest population differentials.

The second purpose was to identify key variables that most influenced decisions either to redevelop brownfields or to develop greenfields. As discussed previously, these interviews were conducted with individuals representing all ten of the study areas. The additional areas were included in order to make the results of the phase one interviews as robust as possible regarding brownfield redevelopment projects in a variety of metropolitan areas.

The phase one interviews were conducted either in the study area or in Los Angeles at Brownfields '98. At the beginning of each interview, the person being interviewed was asked to review and sign an "Informed Consent Form: Research Project on Brownfields Redevelopment." This procedure allowed the interviewer to explain the background of the research project and to set the context for the interview. The "Informed Consent Forms" were seen by many of the participants as being quite humorous. This had the unintended effect of "breaking the ice" and, indirectly, facilitated the interview process.

All of the phase two interviews were conducted in the six study areas during two or three visits to each metropolitan area. These interviews, which began shortly after analysis of the phase one interviews had been completed, were conducted through August 2000.

As noted above, specific brownfield redevelopment decisions were of primary concern during the phase two interviews. These interviews focused on key variables that most influenced individual redevelopment decisions. In order to provide a basis for the brownfield/greenfield offsets discussed in Chapter 5, as much information as possible regarding specific brownfield redevelopment projects was obtained during the phase two interviews.

Each of the interviews conducted during the first phase of interviews utilized a standard interview form focusing on issues that were of concern or interest to individuals representing different public sector entities. The issues identified in the interview form were derived from the literature review discussed in Chapter 4. In addition to the identification of issues, prior to development of the interview form, numerous previously utilized survey research tools (and the results of recent research utilizing such tools) were reviewed. Of particular note was the methodology used by the Center for Transportation and the Environment (CTE) at North Carolina State University. Recent CTE research, which focused on environmental compliance costs for highways, utilized a methodology that provided a model that was utilized (with appropriate modifications) in the development of the standard interview form.

Essentially all of the questions asked of the individuals being interviewed were leading questions. A different interview protocol was utilized during the second phase of interviews. Unlike the first phase of interviews, the second phase did not utilize a standard interview form and only open ended questions were asked.

The utilization of two different types of questions was based on the belief that critical factors identified in both the first and second interview phases are in actuality the critical factors affecting the redevelopment of brownfields. As a result of using open ended questions, however, the range and number of issues addressed during the phase two interviews were considerably narrower than during the phase one interviews.

Also unlike the first phase, the second phase of interviews utilized illustrations of sample brownfield and greenfield tracts. This illustration was used to determine whether the individual being interviewed had considered greenfield development as an alternative to the redevelopment of a brownfield (or vice versa). It was anticipated that the use of illustrations of alternative tracts would provide information on the specific factors that influenced the selection of a specific tract. For situations where the redevelopment of a brownfield was considered and rejected, information was needed regarding the critical factors responsible for the decision, changes in the critical factors that could have affected the decision to the extent that brownfield redevelopment would have been the selected alternative and the nature and characteristics of the brownfield sites that would have been redeveloped if desired conditions on the critical factors had been provided. For situations where the redevelopment of a brownfield was the selected alternative, information was needed regarding the nature and characteristics of the brownfield site as well as identification of alternative greenfield sites that would have been selected had the brownfield site not been selected or had conditions leading to selection of the brownfield site not been adequate to support the selection decision.

When the "Work Plan" discussed in Chapter 1 was being developed, it was thought that the results of the interview process would be subject to confirmation utilizing a national survey research instrument. During the interview process, however, a significant number of the individuals interviewed, when informed of the pending use of such an instrument, argued that a national survey would not be worth the time and expense that it would require. One individual involved in the redevelopment of brownfields, for example, noted that he had received "over thirty" brownfield-related surveys in the previous month and that he had ignored all of them.

The alternative that was developed to confirm the results of the interview process (particularly the areal differentials discussed in Chapter 5) was an Internet-based survey. This survey focused on individuals and organizations involved with urban redevelopment and "smart growth" issues. These organizations were identified utilizing both personal information and commonly available Internet search engines. In most instances, specific individuals within such organizations also were identified. A standard email message was then sent to both the individuals and the organizations. The message was also posted to those Internet newsgroups that focused on land use and related issues. This message (reproduced in part below) posed the following hypothetical:

3.6 Summary of Data Sources
In essence, as depicted in Figure 1, the first phase of interviews focused on secondary data sources that served to identify and confirm the primary sources of information. The second phase of interviews focused on primary sources of information regarding the critical factors (and the relative weights of those factors) that influenced specific brownfield redevelopment decisions. The Internet-based survey, which was intended to confirm both the primary and secondary source results, focused on tertiary sources of information.

Tertiary Data Sources

Organizations with policy-level experience with brownfields redevelopment:

Federal agencies:

Environmental Protection Agency
Department of Housing and Urban Development

Research institutes:

Urban Land Institute
Institute for Responsible Management

Initially, with regard to federal and state statutes and regulations, it must be noted that many of the impediments and incentives identified in the literature are only indirectly related to statutory and regulatory requirements. Many impediments and incentives are posed by private sector financial considerations.

A literature review was undertaken in order to identify federal and state statutes and regulations that either inhibit the redevelopment of brownfields or that encourage the development of greenfields. Based on this review, it appears that impediments and incentives fall into five general categories: Information Issues, Site Acquisition Issues, Financing Issues, Permitting Issues and Site Development Issues. A sixth category (Miscellaneous Issues) includes impediments and incentives that do not fall readily into any of the five general categories.

Absence of information regarding available properties has been identified as an impediment to the redevelopment of brownfields. In essence, what brownfields are available for redevelopment? Related to this question is the absence of site-specific information. Preliminary environmental assessments are not available for many brownfield sites. The absence of such information, it has been argued, inhibits private sector decisions to redevelop brownfields.

With regard to the acquisition of a brownfield site, the literature indicates that a significant impediment is valuing the property or agreeing on a price for the property. Typically, it appears that the seller seeks a sale price that does not reflect the brownfield status of the property while the buyer seeks exactly the opposite.
The literature also indicates that the potential for seller liability under federal law for conditions that may exist at the brownfields site has created a liability "ambiguity" that discourages the sale of brownfields. Rather than confront such liability directly, it has been argued that many owners of brownfield sites may prefer not to sell their property. Such a preference, of course, would forestall any subsequent redevelopment of the property.

The issue of potential lender liability has arisen consistently in the literature. Because of the liability "ambiguity" discussed in the preceding section, it has been asserted that many lending institutions refuse to finance the redevelopment of brownfields. Related to this issue is uncertainty regarding state limits on lender liability.

A second financing issue that has been identified in the literature is the inability of entities involved in brownfields redevelopment to obtain insurance on the redevelopment project. Absent such insurance, it has been argued, the redeveloper of a brownfield site must bear the entire risk of the redevelopment project. The entire scope of this risk, which may be unknown when a redevelopment project is initiated, may have the effect of inhibiting the redevelopment of brownfields.

Tax incentives to encourage the redevelopment of brownfields have been suggested as a needed incentive. One suggestion has been to allow for the full deductibility of environmental remediation costs in the year in which the costs were incurred. In addition, other tax incentives (such as investment tax credits, property tax deferrals and other "tax relief" forms of financial assistance) have been suggested.

An issue that has arisen consistently in the literature is uncertainty regarding permit requirements. In essence, what permits are required and from whom? Related to this appears to be uncertainty regarding the possibility that site remediation requirements might be incorporated into different permits.

Inconsistent federal, state and local permitting requirements have been identified as an impediment to the redevelopment of brownfields. In addition to this inconsistency, the simple fact that there are requirements for multiple federal, state and local permits may also discourage brownfields redevelopment.

Another issue that has been identified in the literature as constituting an impediment to the redevelopment of brownfields is "entrenched attitudes" among regulators. It has been argued that there is need for regulatory flexibility in order to respond to site-specific requirements.

4.5 Site Redevelopment Issues

Two primary issues relating to site redevelopment that have been identified in the literature. The first is a lack of available expertise (e.g., consultants, laboratories, contractors, etc.). The second, inadequate or antiquated infrastructure, may be a more significant impediment because it impacts the redevelopment of specific sites more directly.

There are a number of additional issues that have been identified in the literature which have the effect either of discouraging the redevelopment of brownfields or of encouraging the development of greenfields. A major issue is urban crime. It appears that interest in the redevelopment of a specific brownfield and the crime rate for the area in which the brownfield is located are inversely proportionate.

There have been a number of instances in which the redevelopment of brownfields has been inhibited by public opposition to redevelopment projects. This opposition appears to be based on the simple fact that the interests of entities involved in the redevelopment of brownfield sites and the interests of the communities within which such sites are located do not always coincide.

The lack of a trained workforce in redevelopment areas has been identified as another impediment to brownfields redevelopment as has a limited public demand for redeveloped properties. Additional impediments include inadequate housing for employees as well as unacceptable health care and educational facilities.

As discussed previously, it has been suggested that the redevelopment of brownfields will have the effect of reducing developmental pressures on greenfields. An important consideration in determining such relationships is the fact that similar development projects may require significantly more land if constructed in a greenfields area than if constructed in a brownfields area. Such "areal differentials" are addressed in this section.

The essential question is whether similar development projects require more land if located in a greenfield area than if located in a brownfield area. There are a number of reasons why development of a greenfield could require more land. Land use requirements in effect in many greenfield jurisdictions include such land-consuming provisions as setback requirements, parking requirements, floor area ratios, lot coverage or density limitations and minimum lot sizes.

Consider the following example: A brownfield redevelopment project involving the restoration and continued use of a commercial building located in an urban area. The exterior dimensions of the building are 150' by 200' for a total of 30,000 square feet. The building sits on one city block with sidewalks along three sides and an alley along the back of the building. Because the city allowed the original developer to build to the property lines, the total amount of land occupied by the building is also approximately 30,000 square feet, or 0.68 acres.

5.1.1 Greenfield Area One

In greenfield area one, land use regulations applicable to commercial developments require setbacks of 50' from any main road, 25' from any side road and 10' from any alley. These setback requirements would increase the amount of land required for the project from 30,000 square feet to 52,500 square feet, or 1.2 acres. This would yield a normalized brownfield/greenfield offset ratio of 1:1.76.

Greenfield area two has the same setback requirements as greenfield area one. The critical difference is that unlike area one, greenfield area two does not permit parking facilities to be constructed in the setback areas. The land use regulations in effect in area two require commercial facilities to have one parking place for every 100 square feet of floor area. A 30,000 square foot facility, therefore, would be required to have 300 parking places, each of which is required to be a minimum of 10' by 18' (or 180 square feet). Fulfilling these regulatory requirements would require an additional 54,000 square feet of land. In addition, commercial facilities are required to have a minimum of one loading zone (measuring 20' by 30' or 600 square feet) for every 10,000 square feet of floor area. The loading zone requirement would add an additional 1,800 square feet to the amount of land required. The result is that the minimum amount of land needed to construct the same project in greenfield area two would increase to 108,300 square feet, or 2.48 acres. This would yield a normalized brownfield/greenfield offset ratio of 1:3.64.

5.1.3 Greenfield Area Three

Greenfield area three does not have setback requirements. Instead, the political leadership of area three has enacted lot coverage limitations. The regulations provide that commercial facilities located in the greenfield area may not cover more than 40% of any given tract of land. The regulations define "lot coverage" to include all buildings and parking facilities. The regulations also impose the same parking requirements as greenfield area two. The amount of land that would be covered by the building and the parking facilities is 85,800 square feet. Imposing a 40% lot coverage limitation would increase the total amount of land needed for the project to 214,500 square feet, or 4.92 acres. This would yield a normalized brownfield/greenfield offset ratio of 1:7.23.

The approach taken by greenfield area four differs from the approach taken by the other three areas. In order to preserve open space, the political leadership of greenfield area four has enacted regulations mandating minimum lot sizes for different types of development projects. For commercial projects, the minimum lot size is ten acres. This would yield a normalized brownfield/greenfield offset ratio of 1:14.7.

The amount of land required for the brownfield redevelopment project was 0.68 acres. Because of the land use requirements in effect in the four different jurisdictions, had the same project been constructed in one of the four greenfield areas, the minimum amount of land required would have ranged between 1.2 acres and ten acres. The normalized brownfield/greenfield offset ratios would range from 1:1.76 to 1:14.7. In essence, this means that every acre of brownfields redeveloped for commercial purposes would have required a minimum of 1.76 acres in greenfield area one, 3.64 acres in greenfield area two, 7.23 acres in greenfield area three and 14.7 acres in greenfield area four.

In order to convert the theoretical areal differentials illustrated in the example into actual brownfields/greenfields offsets, specific information about successful brownfield redevelopment projects was required. This information was gathered during the phase two interviews. Specific information included such variables as the nature of the redevelopment project, lot dimensions, total square footage, outside dimensions, number of floors, number of residents, number of employees, etc.

The phase two interviews were conducted in each of the six study cities previously discussed. During these site visits, the land use regulations for a minimum of three proximate greenfield areas were obtained for each of the metropolitan study areas. The greenfield areas identified as proximate to the study cities in these metropolitan areas are noted in the following table.

Study City	Metropolitan Area	Proximate Greenfields
St. Louis, Missouri(See Appendix B-10)	St. Louis MetropolitanStatistical Area	Franklin CountySt. Charles County
Lowell, Massachusetts(See Appendix B-7)	Boston-Worcester-Lawrence-Lowell-Brockton New EnglandCounty Metropolitan Area	Town of ChelmsfordTown of DracutTown of Tewksbury
Burlington, Vermont(See Appendix B-2)	Burlington New England County Metropolitan Area	Town of ColchesterTown of MiltonTown of Williston
Baltimore, Maryland(See Appendix B-1)	Baltimore Primary MetropolitanStatistical Area	Baltimore CountyCarroll CountyFrederick County
Richmond, Virginia(See Appendix B-8)	Richmond-PetersburgMetropolitan Statistical Area	Goochland CountyHanover CountyHenrico County
Sacramento, California(See Appendix B-9)	Sacramento PrimaryMetropolitan Statistical Area	Placer CountySacramento CountyYolo County

Once these land use regulations and information regarding the characteristics of specific brownfield redevelopment projects had been obtained, it was possible to calculate the minimum amount of land that specific projects would have required if constructed in any of the proximate greenfield areas. Three values (based on the land use regulations in effect in the three proximate greenfield areas) were calculated for each of the successful brownfield redevelopment projects. The calculation of three sets of land use requirements for each redevelopment project enhanced the statistical significance of the data by reducing the effect of anomalous values. As noted previously, the calculated areal requirements were normalized and expressed as a 1:x offset ratio.

It is important to understand that the calculation of areal differentials was intended to approximate the minimum amount of land that a brownfield redevelopment project would have required had it been constructed in a greenfield area. Consequently, when it was necessary to make an assumption in order to calculate areal requirements, the assumption that minimized the amount of land required was the assumption used, as indicated below.

Several greenfield jurisdictions had setback requirements that varied in terms of adjacent land uses. For example, if the adjoining land use was commercial, the setback requirement might be twenty-five feet. If the adjoining land use was residential, however, the setback requirement might increase to fifty feet. The applicable setback requirement was always assumed to be the minimum requirement.

All of the land use regulations in effect in the greenfield jurisdictions included mandatory parking requirements. As with the example previously discussed, these requirements were based on such variables as total square footage (for commercial), total number of employees (for manufacturing or industrial) or total residential units (for multifamily residential).

The area calculated as needed to meet the parking requirements was assumed to be the total area needed for parking. As a result, the calculated parking area will always be less than the actual amount of land needed for parking because aisles and access ways between the parking places have not been included. To include the amount of land needed for aisles and access ways would not have been the most conservative assumption as the location and characteristics of such aisles and access ways could only be determined in the context of a specific development project. In addition, when calculating parking requirements, 90º parking was assumed in all cases because such a configuration requires less land than angled parking places. Again, this assumption was made because it was the most conservative assumption.

A further assumption was that all parking would be constructed at ground level. The assumption was based on the differential costs of parking structures. Average costs for ground level parking range between $2,500 and $3,000 per space. Construction of a parking structure, which would have reduced the amount of land needed for parking, would also have increased costs significantly. The cost to construct a parking structure ranges between $6,000 and $8,000 per parking space. The cost per space increases to between $12,000 and $15,000 per space for construction of an underground parking structure.

The land use regulations applicable in several of the greenfield jurisdictions allowed the same development to be constructed in different zoning categories having different density requirements. For example, construction of a single family home development project might be authorized in three different residential zoning categories: R-2 (a maximum density of two residences per acre), R-4 (maximum density of four residences per acre) or R-10 (maximum density of ten residences per acre). If a choice among such zoning categories was presented, the category allowing the highest density development was selected.

A number of the brownfield redevelopment projects involved either the construction or renovation of relatively tall buildings. Limitations in many of the greenfield areas, however, precluded construction of buildings beyond a certain height. In such situations, absent any other means by which the brownfield/greenfield offset might be calculated, the amount of land needed for the brownfield redevelopment project was determined by reducing the height and increasing the width (or length) of the building. With regard to reducing building height, for example, the minimum amount of land required for a 300' high rise hotel in a greenfield jurisdiction having a 150' height limitation would be calculated as though two 150' towers were constructed.

With regard to increasing the width (or length) of structures, the assumption was made that the shortest appropriate structure would be constructed. For example, consider the need to calculate the minimum land requirements for an eight story brownfield redevelopment project. In a greenfield jurisdiction having a three story height limitation, the redevelopment project could be constructed either as a longer (or wider) two story buildings or as a smaller building containing two and three story sections. Construction of a longer (or wider) two story building was the selected alternative in most instances as this would minimize building costs. Beyond a height of two stories, construction costs per square foot increase substantially. This increase in cost is attributable to a number of factors including increased foundation costs and additional expenditures on safety related issues. Because the price of land in many greenfield jurisdictions is less than the incremental costs of constructing a larger structure, it was assumed (when confronting an applicable height limitation) that a larger, shorter building would be constructed.

Most of the land use regulations applicable in greenfield areas include requirements for such things as buffer zones and landscaping. The location and areal extent of such buffer zones and landscaping can only be determined in the context of a specific development project. Consequently, the amount of land needed to fulfill these requirements was not included in the calculations.

The successful brownfield redevelopment projects were divided into three groups: (1) primarily industrial developments, (2) primarily commercial developments and (3) primarily residential developments. The normalized offset ratios for each of the three categories are presented in the following table.

TABLE 4:

Normalized Brownfield/Greenfield Offset Ratios
for Industrial and Manufacturing Development,
Commercial Development and Residential Development

The data contained in Table 2 indicate that the brownfield/greenfield offset ratio may be significant:

Land use decisions are inherently site-specific. This is reflected in the data contained in Table 4 in terms of the wide range of values between the smallest and the largest offset ratios. It is also reflected in the relative large standard deviations and the 95% confidence intervals.

In general, metropolitan areas of the United States have experienced economic decline throughout the second half of the twentieth century. Both shifts in economic activity from urban areas to suburban locations and inter-regional migration from the Northeast and Midwest to the South and West have contributed to this decline. These demographic shifts, along with the overall trend away from heavy industry and other types of manufacturing, have left many older industrial areas idle, underutilized or completely abandoned. Dramatic increases in crime and welfare dependence are apparent in many of these areas.

In an effort to remedy some of the problems associated with economic decline of cities, federal, state and local governments are examining policies affecting urban areas. As a part of these comprehensive efforts, they are examining barriers to and incentives for redevelopment of brownfield sites and developing strategies to address identified impediments. Information on the costs and benefits of redeveloping brownfield sites is needed to set priorities and develop effective strategies that will ensure the success of brownfield redevelopment projects.

The purpose of this component of the present research project was to provide additional insights into the nature of benefits that are induced by the redevelopment of brownfield properties. While a number of researchers have examined economic benefits of brownfields redevelopment, social and environmental benefits induced by brownfield redevelopment have not been as thoroughly examined.

Initially, a literature review was performed to obtain information related to the determination of community benefits of brownfields redevelopment efforts. The results of this review indicated that much of the existing literature focuses on general impediments to urban redevelopment opportunities and concerns of communities and developers regarding brownfield site redevelopment, rather than focusing on determinations of benefits to be received from such redevelopments. While many articles address liability considerations or other impediments to brownfields redevelopment, comparatively little has been written about measurement of benefits induced by brownfields redevelopment efforts. The literature that does exist on brownfields redevelopment-induced benefit analysis tends to focus on three basic areas of community benefits: human health risk reduction, property value increases and provision of services and open spaces. The research reported herein, however, found that brownfields redevelopment may provide a much broader spectrum of benefits.

In addition to the literature review mentioned above, the present research also included a series of telephone interviews with experts in the area of economic redevelopment cost/benefit analysis. These experts pointed out many potential benefits of brownfields redevelopment. Brownfield projects are viewed by many as providing major opportunities for revitalizing urban communities. Redevelopment of brownfield sites may reduce health risks, create jobs, provide services, increase local tax revenues and improve the overall livability of urban neighborhoods. Brownfield site redevelopments tend to affect communities in different ways, depending upon the nature of the land use (e.g., industrial, commercial, residential) and the needs of the community. Left undeveloped, however, brownfield areas remain unproductive, generate little or no economic benefits and are environmentally and socially detrimental to the surrounding communities. On the other hand, if impediments to redevelopment can be reduced, then the realization a wide array of social, economic and human health benefits is likely to occur. Such benefits may accrue both to the immediate community and adjacent areas as brownfield sites are remediated and returned to productive use.

As an example, a case study of brownfield site redevelopment in Trenton, New Jersey , indicated that a variety of social, environmental and economic benefits are accruing from the Trenton, New Jersey Brownfields Demonstration Pilot Program. Interviewees emphasized that, in addition to benefits commonly associated with brownfields redevelopment, such as urban sprawl reduction, traffic congestion curtailment and reduction of air quality problems and other forms of environmental degradation, less tangible social benefits also occur. These types of benefits include a higher level of citizen awareness and sensitivity about individual and community conditions, a sense of control and empowerment from being part of the decision making process, reduced crime and restored safety and security, a sense of hope and a sense of pride.

In other case studies reviewed, the benefit of brownfields redevelopment that was most frequently reported was that of job creation. In Louisville, interviewees explained that job creation will benefit the community only if the jobs are provided specifically to residents occupying the neighboring community. This may require job training programs targeted at community residents. The creation of neighborhood-based businesses could shorten commuting times for residents, making it easier for them to hold down jobs and reducing child care burdens.

Reversal of neighborhood deterioration was the second most frequently mentioned neighborhood benefit. Improvements in the area, including reduced crime, surface cleanups, increased property values and increased local tax revenues were mentioned as potential benefits of brownfields redevelopment. These benefits enhance the ability of local governmental entities to provide better schools, roads and libraries. One respondent pointed out that tax revenues may be most beneficial to the community if they are specifically earmarked for such purposes.

Interestingly, only a small fraction of interviewees mentioned improved environmental quality and the associated reductions in health risks or environmental justice as major benefits of brownfields redevelopment. Perhaps these issues were not emphasized because they are such obvious benefits. On the other hand, residents may be more concerned with other, more visible and immediate concerns such as crime, heavy traffic and noise, than with the longer-term health effects of environmental contamination. In addition, some interviewees indicated that the types of sites that are being targeted for brownfield redevelopment in are not highly contaminated and therefore do not pose high health risks that would be significantly reduced if the sites were cleaned up.

Another output of the literature review and interviews conducted as part of the research project summarized herein, in addition to the identification of benefits induced by brownfield redevelopment efforts, was the articulation of a framework for prioritizing brownfield site redevelopment efforts based on benefits projected to be accrued. As shown in Figure 2, the framework is intended to integrate economic, environmental and social factors in a manner that may be helpful to guiding brownfield redevelopment strategies in a way that achieves the multiple objectives of generating investment in urban areas which ultimately provides increased tax revenues and jobs, reducing human health and environmental risk and benefiting low income and minority populations by revitalizing their neighborhoods.

Social Factors

Those associated with benefiting low income & minority population

Priorities for Targeting Successful Brownfield Redevelopment

Environmental Factors

Those related to human health & environmental benefits

Economic Factors

Those affecting the generation of business, tax revenues & jobs

This simple framework may be helpful in precluding a failure to see "the forests for the trees" when sifting through large numbers of urban properties to identify those which have the greatest redevelopment potential and the greatest economic, environmental and social benefits. As such, the framework may be a useful tool in setting priorities for redevelopment projects, targeting economic development incentives and programs and developing strategies for brownfield site redevelopment. An important purpose for determining benefits induced by brownfields redevelopment is to use such information to set priorities among the large numbers of brownfield redevelopment opportunities that exist in most large urban jurisdictions. Information on induced benefits can be applied usefully to EPA's six-step process for identifying and evaluating brownfield sites that can be successfully redeveloped, as illustrated in Table 5, below.

I. Target Geographic Areas

A. Mixed use areas with highly exposed, low income, minority populations.

B. Commercial/Industrial areas with large land tracts & significant job creation potential.

C. Waterfront/downtown areas that are attractive to businesses

II. Identify Brownfield Sites in Each Area

A. Use local knowledge & land use surveys
B. Contact local economic development offices
C. Coordinate with city urban planning activities
D. Use federal & state environmental databases
E. Use GIS to incorporate a variety of data sources

III. Characterize Brownfield Sites Based on Marketability

A. Low Marketability; public funding necessary. [Public sector takes the lead]	B. Marketable for specialized developers; could make use of alternative funding sources. [Public-private partnerships]	C. Highly Marketable; traditional sources of funding. [Private sector takes the lead]

IV. Screen Sites for High Potential Community Benefits [Discussed in following sections]

V. Evaluate Potential Impacts of Redevelopment Alternatives [Discussed in following sections]

VI. Develop Strategy for Brownfield Redevelopment Activities

A. Partnerships with multi-stakeholder groups to establish priorities for public funding efforts & an action plan.

B. Partnerships with multi-stakeholder groups to establish priorities for development projects.

C. Coordinate with development & environmental agencies to market sites, streamline development process & manage community involvement.

The benefit-based approach to priority setting was developed using information obtained from literature reviews and interviews with a variety of people involved in brownfields redevelopment activities. As illustrated in Table 6, the screening and impact evaluation processes envisioned in Steps IV and V, as well as site and neighborhood characteristics and attributes of the redevelopment plan itself, are factors to be considered in evaluating potential benefits.

TABLE 6:

Factors to Consider in Evaluating Potential
Benefits of Redevelopment Alternatives

Type of Benefit	Discussion
Environmental Benefits
1. Reduced health risks	Evaluation of existing risks, based on contamination and exposures and reductions in those risks resulting from remediation and redevelopment.
2.Environmental Justice	Socio-demographic evaluation of the beneficiaries of redevelopment.
3. Prevention/Reduction of air pollution	Due to curbing urban sprawl; most significant as commercial and industrial redevelopment occurs, providing jobs for city residents.
4. Creation of green spaces	Applies to parks, open spaces and community gardens development.
Economic Benefits
1. Job creation and potential for higher incomes	Jobs created by the redevelopment may not benefit the local community if residents do not have the necessary education or training to fill these jobs.
2. Improve labor market efficiency	Increasing urban fill may provide more job opportunities to city residents, thereby reducing job search costs, labor market search costs and relocation costs.
3. Increased tax revenues	Due to returning property to productive use and increasing property values.
4. Spill-over economic effects	Redevelopment has the potential to improve neighborhood quality and overall business conditions in the area.
5. Reduced congestion, accidents and highway costs	Due to reduction in urban sprawl and commuting.
6. Prevent housing abandonment	Increasing the desirability to live in the city may result from urban fill. Commensurate benefits include avoiding expenses of new construction, preventing crime that often occurs in and around abandoned buildings and improving the aesthetics in the area.
Social Benefits
1. Increase in easily accessible services	Applies to commercial development; many inner city neighborhoods do not have easy access to grocery stores or other necessities.
2. Affordable Housing	For residential development only.
3. Restored sense of control and neighborhood empowerment; renewed sense of hope and pride	These types of benefits are most likely to result when there is a high degree of community involvement in brownfield site cleanup and redevelopment planning.
4. Improved city services	Increase in tax revenues generated by redevelopment may enable the city to provide better public services (e.g., schools, transportation, recreation).
5. Aesthetics	Improved appearance and overall neighborhood quality may result from all types of redevelopment projects, especially parks, open spaces and community gardens.

While this list is more detailed than the screening criteria applied in previous steps, it would be applied only to a subset of higher priority sites. Comparing potential impacts of alternative site redevelopment projects will allow cities to identify those sites likely to provide the greatest economic, environmental and social benefits. Evaluating potential brownfield sites on the basis of the ability to provide community benefits provides a sound basis for establishing priorities and tailoring assistance so that brownfield site redevelopment efforts can proceed.

Chapter 7

Subproblems 3 and 4: Impediments and
Incentives to the Redevelopment of Brownfields

The results of the phase one and phase two interviews were analyzed to isolate key variables having the greatest influence on both public and private sector decisions to redevelop brownfields. As noted earlier, the underlying assumption was that specific factors identified during both phases of the interview process were, in fact, key variables most influencing brownfield redevelopment decisions.

Initially, it must be noted that land use decisions are inherently site-specific. As a result, factors affecting decisions regarding the development or redevelopment of any specific site may (or may not) arise with regard to the development or redevelopment of any other site.

It must also be remembered that issues relating to the redevelopment of brownfields are a subset of a larger set of issues relating to economic development. According to one of the interviewees, brownfields are "a part of a piece of a puzzle." With regard to urban redevelopment, another interviewee noted that brownfields are "the tail wagging the dog." In essence, there was general agreement that the real issue was urban economic development and that the redevelopment of brownfields was but one component of that development.

7.1 Issues of Special Concern

City Core Area	1990-94 Population Change	Metropolitan Area	1990-95 PopulationChange	Differential
St. Louis,Missouri(See Appendix B-10)	-7.2%	St. Louis MetropolitanStatistical Area	+2.2%	9.4
Lowell,Massachusetts(See Appendix B-7)	-7.1%	Boston-Worcester-Lawrence-Lowell-Brockton New England County Metropolitan Area	+1.5%	8.6
Burlington,Vermont(See Appendix B-2)	-2.1%	Burlington New England County Metropolitan Area	+6.3%	8.4
Baltimore,Maryland(See Appendix B-1)	-4.5%	Baltimore Primary MetropolitanStatistical Area	+3.7%	8.2
Richmond,Virginia(See Appendix B-8)	-0.8%	Richmond-PetersburgMetropolitan Statistical Area	+7.1%	7.9
Sacramento,California(See Appendix B-9)	+1.2%	Sacramento PrimaryMetropolitan Statistical Area	+8.7%	7.5

City Core Area	1990-94 Population Change	Metropolitan Area	1990-95 PopulationChange	Differential
St. Louis,Missouri(See Appendix B-10)	-7.2%	St. Louis MetropolitanStatistical Area	+2.2%	9.4
Lowell,Massachusetts(See Appendix B-7)	-7.1%	Boston-Worcester-Lawrence-Lowell-Brockton New England County Metropolitan Area	+1.5%	8.6
Houston,Texas(See Appendix B-6)	+4.4%	Houston Primary MetropolitanStatistical Area	+11.7%	7.3
Detroit,Michigan(See Appendix B-5)	-3.5%	Detroit Primary MetropolitanStatistical Area	+1.3%	4.8
Cleveland,Ohio(See Appendix B-4)	-2.5%	Cleveland, Lorain, ElyriaPrimary MetropolitanStatistical Area	+1.0%	3.5
Charlotte,North Carolina(See Appendix B-3)	+10.6%	Charlotte-Gastonia-Rock Hill MetropolitanStatistical Area	+10.9%	0.3

Measurement	Industrial Development	Commercial Development	Residential Development
Mean:	1:6.24	1:2.40	1:5.57
Median:	1.33	1.74	2.15
Mode:	1.04	0.74	0.94
Range:	1:0.53 to 1:60.52	1:0.48 to 1:12.50	1:0.44 to 1:45.77
Confidence interval (95%):	± 5.38	± 0.59	± 2.54
Standard deviation:	14.79	2.18	10.03
Number of sites:	10	18	20
Number of samples:	29	53	60