Don't It Make Your Brownfields Green
Over the past few years, there has been a strong movement for the cleanup of brownfields sites -- areas contaminated by former industrial properties.
To help communities afford this cleanup, and to redevelop brownfields areas into aesthetically pleasing, useful properties, the Environmental Protection Agency (EPA) has established three specific funding programs.
This funding does not come easily, as cities are required to participate in an extensive, detailed application processes to receive money. For cities new to the funding application process, this money can seem unattainable.
Writing a successful grant application is not a quick or easy task. But once you begin to feel comfortable with the application, the process becomes manageable and much less intimidating.
While there is considerable homework that must be completed before you can even begin to prepare the proposal, writing your application will be a snap once all of the information is assembled on your desk.
Writing for the EPA
There are three EPA grants available to communities seeking funding for the cleanup and redevelopment of brownfields sites, each with different requirements and criteria for the distribution of funds.
Becoming familiar with the criteria is an essential first step, not only because it will help you successfully secure the funds you need, but knowledge of the intricacies of each grant's requirements will help you determine which of the EPA's grants is the best fit for your community.
To successfully win an EPA grant, you must meet two types of criteria within each of the three grants. The first type is Threshold Criteria. These pass/fail criteria can be intimidating because failure to meet even one of the criteria means that your application will be immediately dismissed, and you will not be allowed to re-submit an application for at least one year.
The second type of criteria is Ranking Criteria. In this category, you are asked to provide the who, what, why and how of your funding proposal, and each criterion is given a score. The projects receiving the highest total scores will be the ones that receive the EPA dollars.
Below are tips on how to put your best foot forward when applying for the three available brownfields grants: the Brownfields Assessment Grant Program, the Brownfields Revolving Loan Fund Program and the Cleanup Grant.
Brownfields Assessment Grant (BAG) Program
The BAG offers up to $200,000 per site, with a waiver allowing up to $350,000 per site. Applicants can also apply for up to $200,000 for hazardous material assessments and an additional $200,000 for petroleum contaminant assessments.
The first of the Threshold Criteria is Applicant Eligibility, which determines exactly that –- your eligibility to apply. Eligible agencies include local units of government, land clearance authorities and other quasi-governmental entities, and governmental entities created by state legislatures, regional councils, redevelopment agencies sanctioned by states, states or Indian tribes.
Community Notification is the second criterion you must meet. The BAG requires that you describe how your targeted community has been notified of the preparation and submission of your grant proposal and provided an opportunity to voice their opinions prior to the proposal submission.
Practical solutions for meeting this requirement are to hold an open house, host a Web site and keep copies of the proposal at the Clerk's office or library.
After completing these and other public information activities, be sure to document them so that including them in your application is simple.
A letter from the state or the tribal environmental authority is another requirement within the Threshold Criteria of the BAG. To meet this requirement, consult with your environmental representative and EPA regional office. The EPA simply hopes to determine that the state or tribal agency associated with your proposed project is aware that you are pursuing EPA funding.
Of the most significant within the Threshold Criteria category are Site Eligibility and Property Ownership Eligibility. This is where you must communicate why the EPA should invest federal money in your project even though a viable, responsible party may be connected with the site you are considering for cleanup.
It may be tempting to leave out the specifics of sites and their ownership to avoid disclosure of this responsible party. And although you are not required to list specific sites in your application, your chances of success will be compromised if you don't.
Property-specific determinations are a new element of the grant program, and they can complicate an application, bringing uncertainty into site eligibility. To avoid any complications in your application, disclose as much information as possible, and be sure to include the following:
Site history and chain of ownership
• Describe how the site's current and past uses raises questions about its environmental condition.
• Visit the county recorders office or interview local historians to determine the chain of ownership.
Site contamination and anticipated enforcement actions
• Work with the state or tribal environmental officer to prepare this section. Keep in mind that the EPA will verify the validity of the information included.
Ownership issues (if you don't own the site)
• Detail your relationship with the site's owner.
• Describe the owner's role in the work to be performed.
• Explain how access to the site will be gained.
Ownership issues (if you own the site)
• Tax foreclosure and eminent domain can provide some protection from liability.
• Consider that if you purchased or accepted the site through a charitable donation without meeting the "all appropriate inquiry" test, you may be considered the responsible party and be deemed ineligible for public funding.
The first of these criteria is Budget, and it is worth five points. If you are applying for both hazardous and petroleum funding, it will be necessary to provide two separate budgets.
Be sure to include all elements that are associated with the effort (e.g., preparation of a QAPP, sampling plans, conduct Phase I and II ESAs, public outreach, etc.). Keep in mind that up to 10 percent of the budget can be used to monitor the health of populations exposed to one or more substances.
Another criterion is Community Need, and it is one of three criteria worth 15 points. It's important to fully explain how cleanup of the targeted site will benefit the economy, residents and environment in your community.
This is also a good opportunity to point out any environmental justice issues that may exist. Successful applicants typically provide some perspective by explaining how pervasive brownfields are in their communities and why the areas they are proposing for cleanup are worthy of the most immediate attention.
Site Selection Process, worth 10 points, requires you to describe your process for prioritizing sites. Criteria for prioritization typically found in successful proposals include proximity to municipal wells or residential areas, visibility of the site and tax delinquency. Use the criteria to bridge the gap between conducting ESAs and your vision for redevelopment.
Next is Sustainable Reuse of Brownfields/Development Potential, worth 10 points. Here, you must outline the planning, public outreach and strategic partnerships that will play a role in your overall strategy for cleanup of the site.
Your chances of impressing the grant decision makers will greatly increase if you can discuss how your community ordinances or in-fill and brownfield development practices dovetail with the EPA's priorities (e.g., green building design, smart growth, etc.).
Creation and/or Preservation of Greenspace/Open Space or Nonprofit Purpose is a criterion worth five points. Here you must outline how existing parks, trail alignments or nonprofit entities, such as a youth center or redevelopment agency, will play a role in the brownfields project.
If you are pursing funding for a site that already includes a built environment, your opportunity to shine is in the Reuse of Existing Infrastructure section, worth five points. Be sure to include as many details as possible about the existing infrastructure, such as access to public utilities and transit services.
Applicants who can demonstrate this type of commitment to revitalizing an urban core versus growing an outlying area give the perception that their community is a sustainable one, worthy of public investment.
Similar to the Community Notification section within Threshold Criteria, a Community Involvement section, worth 15 points, needs to be completed within the Ranking Criteria category.
In this section, you'll need to further outline your strategy for engaging the public in the project. Be sure that the people included on your list of community-based organizations are all familiar with and involved in the project, as the EPA may contact them.
The 10-point Reduction of Threats to Human Health and the Environment criterion asks you to explain how you plan to use up to 10 percent of the grant to identify health and environment threats.
Local and regional health departments are excellent resources for preparing your strategy. Ask these experts for studies related to health concerns in your area. If possible, outline your cleanup plan in detail and discuss the operation and maintenance plan. It's important that the state or tribal environmental authority are aware of and involved in your plans.
Applicants can demonstrate their community's acceptance of and enthusiasm for the project if they are able to show plans for non-EPA funds that will be allocated to the clean-up effort.
Your opportunity to showcase this commitment comes in the next criterion, Leveraging of Additional Resources, worth 15 points. This is your opportunity to provide a basis for why funding is necessary and what role you will take in securing additional money for the project. Identify where and how non-EPA funds will be committed to this project, and be sure to distinguish which of these funds are from local sources.
Your past experience with grant management is an important part of the application. Your chance to demonstrate your resume of past grant management and budget stewardship experience comes in the final criterion, Ability to Manage Grants, worth 10 points.
Use this section to summarize all relevant experience in grant management, and the provisions you have taken to ensure that the work is managed properly. The results of your most recent audit can easily address OMB Circular A-133 and A-102 concerns. If you are a current or past EPA grant recipient, provide current financial and accomplishment data on the status of your project.
Brownfields Revolving Loan Fund (RLF) Program
This program offers an initial grant of up to $1 million, and allows for a 5-year program. However, there are several requirements and restrictions that apply to this type of funding.
For example, a RLF grant recipient cannot make a cleanup subgrant exceeding $200,000 per site, and 20 percent of the cost-share requirement must include the contribution of money, services, material or labor. The match cannot be used to offset administrative costs such as salaries, benefits, contractual costs, supplies and data processing charges.
The criteria for the RLF are the same as those required by the Brownfields Assessment Grant, with the addition of a few criteria:
Cleanup Authority and Oversight Structure
This criterion asks who will provide clean-up oversight. Be as exhaustive and detailed as possible. At a minimum, you must detail whether or not enrollment in a VCP is part of your strategy; how you will ensure that the cleanup will provide protection for the environment and human health; and what legal authority you have to access and secure sites in the event of an emergency.
You will be asked to outline all eligible forms of cost sharing for your project. Remember that you must meet the 20 percent minimum. Eligible forms of cost sharing include fees from borrowers, interest on loans and other forms of program income; or contributions of money, labor, material or services from a non-federal source.
Legal Authority to Manage an RLF
A simple letter from your legal counsel will be sufficient to prove this authority.
Ranking criteria for the RLF are very similar to the BAG. Therefore, you will find the tips outlined above helpful for both grant applications.
However, there are some differences in how the EPA evaluates the budget criterion in the RLF proposals, and there is an additional criterion, the Description of Target Market and Business Plan that will require your attention.
Budget (10 points): Your preliminary budget should show that tasks for loans make up 60 percent of the funds requested and subgrants constitute up to 40 percent of the budget. But keep in mind that the subgrants cannot exceed $200,000 for each site.
For each proposed subgrant, be sure that you are including the tasks that the recipients of these funds will be responsible for completing. Up to 10 percent of the budget should be allocated for the monitoring of environment or health threats.
Don't forget to allocate some of the funds to the most obvious tasks, such as establishing the RLF, promoting the program, and making and servicing loans.
Description of Target Market and Business Plan for RLF Loans and Subgrants (20 points): Clearly define your target markets, whether that be an inner-city neighborhood, an industrial area impacting a residential neighborhood, or an abandoned industrial or commercial site. Once the market is clearly defined, your next step is to prove that you have a distinct plan of action for involving as many people and organizations
in this project as possible. These people may include neighborhood association members or public officials, such as fire marshals, building inspectors and health department officials.
The Cleanup Grant provides up to $200,000 per site, for no more than five sites per applicant, and a separate application must be prepared for each site.
To receive a Cleanup Grant, you must own the site by the time the grant is awarded. Also, a minimum of a Phase I ESA is required prior to submitting a proposal.
Both the Threshold and Ranking Criteria for the Cleanup Grant are the same as those required by the RLF application. The only difference is that you will not be required to prove that you have legal authority to manage the grant.
These three grants were designed to further stimulate the cleanup movement that is sweeping the country, and the EPA awards them to those applicants who are best at communicating why their projects deserve investment.
Therefore, don't be afraid to show your passion for the project in the application. Let the EPA know what this revitalization will mean for your community and the example it will set for surrounding cities.
The EPA grant process can be intimidating, and many cities look to consultants for help wading through the process. Partnering with these experts can give you the right combination of thorough research, smart strategy and concise writing to turn you into one of the successful professionals who are reshaping this country, one brownfields project at a time.
Jim Halverson is a senior project manager and grant writer for Howard R. Green Company (HRG). One of HRG's most successful grant writers, Halverson has won funding on every grant he has authored for HRG clients. He recently presented a workshop on how to compete for these coveted EPA Brownfields grants at the EPA Brownfields 2004 Conference in St. Louis.