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On September 19, 2017, the Environmental Protection Agency (EPA) released the 2018 guidelines for brownfield grant applicants to apply for a portion of the $50 million available for 2018 grant funding. Brownfields are defined as “a property, the expansion, redevelopment, or reuse of which may be complicated by the presence or potential presence of a hazardous substance, pollutant, or contaminant.” EPA provides brownfields funding for three types of grants: Brownfields Assessment Grants, Brownfields Revolving Loan Fund (RLF) Grants, and Brownfields Cleanup Grants. The closing date for receipt for these RFPs is November 16, 2017. EPA anticipates awarding an estimated 198 grants among all three grant types.
There are several advantages to brownfields projects. Brownfields usually have infrastructure in place so the building and infrastructure costs are typically less than new construction costs. Local and state authorities often offer tax incentives for brownfield development. When a brownfield is redeveloped, the value of surrounding real estate often increases, and new businesses may follow. The result is increased tax revenues for the area where development would not otherwise have occurred. Disadvantages are that contaminated properties can require costly remediation or management which may affect the purchaser ability to obtain financing. The process is often slow and may take considerable time to complete.
Tips for successful applications can be found in the 2017 Toolbox for Community Redevelopment from the Division for Compliance Assistance.
A link to and summary of the Request for Proposals (RFP) of each grant category is provided below.
FY2018 Guidelines for Brownfield Assessment Grant (RFP NO: EPA-OLEM-OBLR-17-07)
Provides funds to inventory, characterize, assess, and conduct planning (including cleanup planning) and community involvement related to brownfield sites. Assessment grant funds may not be used to conduct cleanups. Individual applicants may apply for a community-wide and/or a site-specific assessment grant, or apply as part of an assessment coalition. EPA anticipates awarding an estimated 145 Assessment Grants for an estimated $33.5 million.
FY 2018 Guidelines for Brownfields Revolving Loan Fund Grants (RFP NO: EPA-OLEM-OBLR-17-08)
Provides funding to a grant recipient to capitalize on Revolving Loan Fund Program (RLF). RLF programs provide loans and subgrants to eligible entities to carry out cleanup activities at brownfield sites contaminated with hazardous substances and/or petroleum. An RLF grant recipient must use 50% or more of the awarded funds for loans. Subgrants are limited to $200,000 per site. Those receiving RLF subgrants must own the site for which the sub grants are to be used. Under the RLF Grants RFP, EPA provides funds to capitalize a revolving fund and to make loans and provide subgrants to carry out cleanup activities at brownfield sites.
FY 2018 Guidelines for Brownfields Cleanup Grants (RFP NO: EPA-OLEM-OBLR-17-09)
Cleanup Grants provide funding to carry out cleanup activities on brownfield sites owned by the applicant. New for FY 2018, Brownfields cleanup grants applicants may request funding to address either a single brownfield site or multiple brownfield sites within each proposal; may request up to $200,000 in each proposal; and can submit up to three cleanup proposals.
Applicants must provide a 20 percent cost share for Cleanup Grants. For example, a $200,000 cleanup grant will require a $40,000 cost share. The cost share, which may be a contribution of money, labor, material, or services, must be for eligible and allowable costs under the grant and cannot include administrative costs. Applicants may request a waiver of the 20 percent cost share requirement based on hardship. EPA will consider hardship waiver requests on a case-by-case basis and will approve such requests on a limited basis. EPA anticipates awarding an estimated 38 Cleanup Grants for an estimated $7.5 million.
Applications and supporting materials are provided on the Kentucky Division of Compliance Assistance EPA Brownfield Grant Writing Resources website .
If you are interested in submitting a grant application or want to learn more about how to use brownfield grants for contaminated properties in your community, contact email@example.com or firstname.lastname@example.org for more information.
Ken Kirk is a Professional Geologist at Smith Management Group. Ken can be reached at email@example.com.
New Facility Permitting
A large alcoholic beverage company was planning to construct a distillery along a lake in Kentucky and use the fresh limestone water for bourbon production. The proposed site was a former farm with historic activities dating back to the 1880s. A water intake structure was required in the lake and along the adjacent shoreline which was owned by others. Several ephemeral and intermittent streams would be impacted by the construction. The client needed a US Army Corps of Engineers (USACE) Clean Water Act (CWA) Section 404 Permit, a Kentucky Division of Water 401 Water Quality Certification, a water withdrawal permit, a permit for construction in and along a stream, and a construction stormwater permit. Additionally, an air permit was required prior to construction for the aging warehouses, distillery equipment, and other emission units. Evaluation for cultural and historic resources and endangered species evaluations were required under the National Environmental Policy Act (NEPA) and Endangered Species Act (ESA).
As the construction proceeded and operations began, a number of operating permits and environmental and hazardous materials compliance plans were required. The project required coordination with the nearby city for drinking water use and industrial wastewater pretreatment and discharge. Recordkeeping and reporting were needed prior to facility personnel being mobilized to the site. Set up and management of environmental systems during the transition to full operations was needed.
During the planning and initial construction phases, SMG managed the environmental permitting and environmental compliance for the site. The process involved application preparation and coordination with multiple regulatory agencies including the USACE, Kentucky Division of Water, Kentucky Division of Air Quality, US Fish and Wildlife Services, Kentucky Department of Fish and Wildlife Resources, Kentucky Heritage Council, and local agencies. Permits included stream mitigation, cultural and historic resources investigation, coordination with state and federal Fish and Wildlife agencies, and State 401 water quality certification, and the Section 404 permit, which required wetland and stream delineation. SMG coordinated with the client’s project team to minimize stream impacts and to adhere to the schedule by expediting the permit processing. State stream construction, water withdrawal, and air permits were also obtained. SMG provided onsite observation to assess contractor compliance with the stormwater permit and managed environmental permit reporting.
During the later construction phase, SMG managed the environmental permitting and compliance for the new distillery. The initial environmental and hazardous material compliance plans (GPP, HMPC, and SWPPP) were prepared and applications for operating permits, such as industrial wastewater pretreatment and discharge and industrial stormwater discharge, were readied and submitted. SMG provided training to the initial employees regarding hazardous material management and groundwater/stormwater protection. SMG worked with the new Risk Manager for the site to transition responsibility for environmental and hazardous material compliance.
SMG’s management of the environmental planning and permitting for the facility, successfully supported the construction schedule and managed environmental compliance for the initial site operations. SMG continued to work with the owner to obtain remaining operational permits and to transition environmental compliance responsibilities to the new facility staff to support startup and initial operations. The facility was completed on schedule and provides a significant economic benefit to the surrounding community.