5: Identify, Assess, Remediate, and Reuse Brownfields

< Chapter 4
End Uses

Is this guide missing anything you'd like to see? 

Contact us at:

Chapter 6
Funding >
One man's trash is another man's treasure. Though brownfields can be visual eyesores and create headaches for communities, the benefits of transforming brownfields into productive community assets through hard work and careful planning are overwhelming.

- Charles Grosenick, Co-Author, BRIGHT

This chapter deals with appropriate measures when confronting brownfields as part of your community revitalization project. Brownfields are “abandoned, idled, or under-used industrial and commercial facilities where expansion or redevelopment is complicated by real or perceived environmental contamination.” Common examples are dry cleaning sites, landfills, and auto mechanic shops. These brownfield sites must be remediated, or restored to their original (pre-contamination) condition by reversing or stopping environmental damage.

Key Takeaways

  • For brownfields, carefully consider the size of the site, prior use(s), property classification, prior owner(s), potential profits from the site, and potential property reuses
  • Research funding sources early
  • Recognize that brownfields can drastically vary in nature and the types of assessments and remediation they require
  • Evaluate the environmental footprint of the remediation process and try to mitigate climate impacts by reducing waste e.g. reusing construction materials


Identify Brownfields



Brownfield remediation provides a variety of benefits including economic growth and revitalization for the community, environmental protection, natural resource preservation, open space preservation, and increased resilience to climate change. Remediation also furthers equitable development and, most importantly, improves the community's public health.

Selecting an appropriate brownfield site is critical. Because the cost of brownfield remediation is so high, the Environmental Protection Agency (EPA) requires that a brownfield be included as a cornerstone of any Corridor Project. This allows the brownfield remediation cost to be factored into the for-profit development plans of any Corridor Project. Taking on too hefty of a project, both in terms of size and monetary expenditure, can lead to an unfinished project. There are many aspects to think about when selecting a site. These include:

It is helpful to hire an Environmental Consultant to perform a cursory review of the property and offer an estimate of the cleanup costs. You can then balance this information against the potential profit or usefulness of a remediated site before purchasing the site or performing an environmental assessment. As brownfield remediation is difficult, both due to its costs and legal ramifications, having professional assistance is recommended. Some pro-bono options in the Northeast include:

A surefire way to sink a Corridor Project is to purchase a brownfield site without balancing the cost of remediation with the future potential profit or usefulness. 

The video below offers a very brief overview of the Brownfield Revitalization process using a case study from East Hartford, Connecticut.

Brownfield Remediation Plan

To remediate a brownfield site, a brownfield remediation plan must be created. Most successful brownfield remediation plans have four things in common.

First, the plan must engage the community as a whole by reaching out to a wide array of community members through early and ongoing dialogue. The community members must be informed and involved in the plan. A good way to effectuate this is by using a project team with local leadership and a single manager.

Second, the plan must emphasize how the brownfield and its cleanup will beneficially impact the community. A good way to implement this is to create a goal for reuse of the brownfield property early and update the community regularly on progress. You should also listen to input from the community throughout the remediation process. Be creative when discussing potential end uses of the property.

Third, there must be transparent decision-making and progress updates. Brownfield remediation is a long process, and this should be made clear to the community at large. In addition, the risks in remediating a brownfield must be made clear prior to starting the project. These risks occur because the owner of a piece of property designated as a brownfield site may be legally responsible for its cleanup, which can run into the millions of dollars. When managing these risks, it is helpful to contract with an environmental consultant, review your own financial sources, and consider legal protections prior to buying or acquiring the property.

Once you have obtained access to the property, think about requesting disclosures from site owners regarding their use of the site and assigning cleanup costs between the buyer and the seller. For example, not allowing dry cleaning or auto repair on the site. This protects the municipality from any future litigation.

Once you have acquired the property, make sure that you follow all applicable laws, regulations, policies, etc. This is incredibly important as once you are the owner of the site, you can be liable for all applicable cleanup costs and ongoing fees related to the site. Thus, do not purchase a potential brownfield site without estimating the cost of cleanup and ongoing regulation costs.

Last, the plan must identify whether a property can be successfully remediated, determine if there are realistic funding options, and calculate a logical total cost of remediation. One way of doing this is through an adaptive approach. This is an extremely important step, as failure to identify costs of remediation can result in a municipality running out of money before the brownfield remediation is complete.

The 30th Street Industrial Corridor in Milwaukee incorporated these four factors of a successful brownfield remediation plan. The Wisconsin Department of Natural Resources (DNR) partnered with the city of Milwaukee, and the Environmental Protection Agency, to focus resources on the 30th Street Industrial Corridor, with the goal toward eventual redevelopment.

Source: 30th Street Corridor

From this partnership, the DNR was able to secure EPA brownfields assessment grants to begin the process of brownfields redevelopment. By securing EPA funding, the project was also able to leverage additional funding from several entities, including a DNR specific assessment grant, funding from the Wisconsin Economic Development Corporation, an EPA Cleanup subgrant, and funding from the HUD Economic Development Initiative.

In 2005, before the sites for redevelopment were selected for assessment, the partnership reached out to residents, community organizations, and interested stakeholders. These engagement efforts informed the community of the project and gave them an opportunity for input on which sites, within the corridor, needed assessment work. From that outreach effort, and a search of the DNR's database on contaminated sites, the project identified 50 properties for site assessments.

Throughout the project, the partnership maintained open and transparent communication with the community. In 2008, the partners held an Open House Session to share site-by-site progress, give background on the EPA grants, and offer health information about the chemicals of concern in the Corridor. Additionally, the DNR created a website for outreach opportunities and information tracking on the sites that were undergoing environmental assessments.

Ultimately, Phase I environmental site assessments were conducted on 49 of the 50 identified sites. For some of the sites, Phase 1 findings illustrated that there was a low risk of environmental contamination, meaning that the sites were ready to be marketed. However, some of the findings showed serious environmental concerns, which led the partners to decide to conduct Phase II assessments on 24 sites.

Phase II site investigations were completed at 18 sites, and these sites were then ready for cleanup and redevelopment, but 6 sites still needed additional investigation. These environmental site assessments and the breadth of funding enabled the partnership to determine potential beneficial end-uses to serve the community and demonstrate that 44 of the 50 identified sites could be successfully remediated.

This area-wide plan demonstrated a successful brownfields remediation effort using the four factors laid out in this chapter. The project continually engaged the community for their input and updated the community on the progress of the project, leading to transparent decision-making and progress updates. Further, through the assessment process, the partnership was able to study the sites for potential end-uses, such as green infrastructure, urban agriculture, residential projects, and business developments. Lastly, the partnership was able to identify that the brownfields sites could be successfully remediated.

The video below highlights the historical context of divestment and white flight in Milwaukee along with the perspectives, feelings, and hopes of 30th Street's residents.

Laid out below is a four-step overview of the brownfield remediation process.


Step One: Identify Brownfields

The first step of any successful brownfield remediation plan is to identify the brownfield. There are a number of ways this can be done. An extremely easy way to do this is by asking community members about any idle, vacant, or underproductive land. Oftentimes, community members are the best sources of knowledge. However, there are a number of other ways to obtain this information, which are laid out below:

  • Check Envirofacts.
  • Check the Agency for Toxic Substances and Disease Registry Brownfield search tool
  • Review public records from municipal, state, or federal agencies. One way to obtain records from federal agencies is through a Federal Freedom of Information Request
  • Involve municipal, state, or federal agencies in the Brownfield process. Involving agencies (such as the Environmental Protection Agency) in the brownfield remediation process will allow you to free up resources for other aspects of the community revitalization process. In addition, other agencies are often better suited for dealing with brownfield remediation as they often have more knowledge of the process. You can even apply for technical assistance from the EPA.
Part of the former Anamet factory complex in Waterbury’s South End. (Bill Shettle / Republican-American)
Source: Sample Brownfield that was part of a former factory complex

Once you obtain information on where the brownfield sites are in your community, create a map overlaying the brownfields with other existing municipal land use information. Once you complete this map, prioritize sites for further investigation and cleanup. This prioritization should cater to the vision of your Corridor Project.

For example, you may prioritize the cleanup of a large brownfield site in the middle of your Corridor Project instead of smaller sites on the periphery. You can also conduct risk screening of the sites identifying vulnerabilities to climate impacts and assess which sites need more resiliency measures. 

For high priority sites, create a resource roadmap and briefing sheet (example p. 28-33). After prioritizing the sites for further investigation, try and obtain access to any private sites. Prior to acquiring a private site, you should review your findings with an environmental consultant so that you do not find yourself legally liable for the cleanup of a brownfield site.

Make sure that you have the capacity to clean up the brownfield sites you identify and that they fit into your Corridor Project. An easy way to sink a Corridor Project is by pursuing and purchasing a brownfield site without a plan as to the cleanup cost and potential profit from the site after cleanup. If possible, it is optimal to perform an environmental site assessment (discussed below) prior to purchasing the site. After reviewing everything with an environmental consultant, if you still want to acquire a private site, there are a few ways to do so.

  • Purchase the property - This can be done 3 ways: Sold “as is” or without any protection for potential damage/liability; sold after an environmental consultant or other professional reviews the site and calculates a probable amount for cleanup costs; or sold after assessment and cleanup of the site by the site owner.
  • Permission from Site Owner - An owner may want to retain ownership and work with you to clean up the brownfield. Here, you would not obtain ownership of the property, but cleaning up the site may greatly increase the likelihood of success of your community revitalization plan.
  • Eminent Domain - You may be able to take private property and convert it into public use for suitable compensation. Check with a lawyer before moving forward with this step.
  • Adverse Possession - If you use a piece of property for a number of years without the permission of the owner (such as an absentee owner), it may be possible to obtain the property through adverse possession. However, this is highly unlikely and should be extensively discussed with a lawyer prior to utilization. 
  • Foreclosure - If the owner of the site has not paid rent/taxes, it may be possible to foreclose on the property. 

Some specific types of brownfields include:

  • Gas Stations/Auto Mechanics
  • Brownfields on Tribal Land (p. 19)
  • Dry Cleaners
  • Manufacturing/Chemical Plants
  • Industrial Areas
  • Military Facilities
  • Landfills

Conduct an Environmental Assessment

Remediate Brownfields


Step Three: Remediate Brownfields

Remediating a brownfield, or restoring the land to its original (pre-contamination) condition by reversing or stopping environmental damage, is a crucial step in any community revitalization plan involving a brownfield if environmental contamination is found after an environmental assessment. This remediation must be done by a professional and must comply with all state and federal regulations. There are a number of benefits when a community remediates a brownfield including: 

  • Job Training (in the field of hazardous waste clean-up)
  • New Jobs
  • Economic Growth/Businesses Benefits
  • Open Space and Natural Resource Protection
  • A Healthier Community
  • Blight Removal
  • Affordable Housing Set Asides
  • Space for Community Institutions
  • Transit-Oriented Development

Often, brownfield remediation is a costly endeavor. Thus, it is important to obtain outside sources of funding. A good guide for funding can be found here and here. Some ideas of how to obtain outside funding include:

  • Litigation through the Comprehensive Environmental Response, Compensation, and Liability Act (sue Potentially Responsible Parties under section 107)  
  • EPA Grants (to be eligible you must meet the “All Appropriate Inquiries” standard for due diligence under Phase I (see Step Two))"
  • The Community Development Block Grant - Provides an annual grant to municipalities on a formula basis and may be used for brownfields-related activities such as site assessment, cleanup, demolition, rehabilitation, and construction
  • Community Reinvestment Act
  • Industrial Development Bonds
  • Rehabilitation Tax Credits
  • Peruse old insurance for potential coverage of remediation costs. It is very helpful to have an insurance lawyer to help you review historical insurance
  • Other potential avenues for funding:  U.S. Department of Housing and Urban Development, the U.S. Department of Agriculture, the U.S. Department of Transportation, and the U.S. Department of Commerce
  • Local sources (municipal debt, taxes, loans)

In the remediation process, environmental contamination must always be contained so that it does not affect other environmental resources. For example, a leaking underground oil tank will leak oil, gas, and other contaminants into the soil. These contaminants could then reach sources of groundwater, affecting the water supply of the surrounding area. As such, when remediating such a site, the exposed soil must be removed, and sometimes more extreme measures must be taken (especially when contamination has affected the groundwater). Some ways to remediate contaminants found at a brownfield include capping the top of the brownfield, constructing a barrier between the contamination and the surrounding environment, removing/extracting the contamination, and/or treating the contamination. 

When undertaking the remediation process, evaluate the environmental footprint of the remediation process and try to reduce climate impacts by reducing waste (ex. reusing construction materials). Once the environmental remediation of your brownfield is complete, apply for No Further Action which means your brownfield will no longer need remediation or oversight by a federal or state agency. In addition, think about using institutional controls (Easements, Covenants, Zoning Restrictions, etc.) to contain future contamination or make it easier to limit exposure.

Here are some examples of brownfield remediation projects:

Reuse Brownfields