Mar 4, 2024

Targeted Brownfields Assessments 101

A Targeted Brownfield Assessment (TBA) is often the best first step a community can take in redeveloping a brownfield — any property where reuse might be complicated by environmental contamination. CCLR sat down with EPA Region 9 to learn more about this free service:

What is a TBA?

We have technical assistance that is easy to access through a simple application to help with assessing a property that may be suitable for redevelopment.

It’s free, it’s easy. We do the hard part. [Applicants] can have limited involvement and we can provide them with high quality assessment work that can lead to the next phase in a brownfields cleanup and redevelopment.

Who can apply?

TBAs are intended for the same types of entities that are eligible for other brownfields support, including units of government, 501(C)(3) nonprofits, and tribes. We are also emphasizing underserved and disadvantaged communities.

One additional thing about TBAs is that it’s possible for one of those eligible entities to sponsor an application. So for example, if there’s a property that’s owned by a private owner, and there’s a community benefit that may result from the future redevelopment, a local government or nonprofit can apply for a targeted brownfields assessment.

What kinds of projects do TBAs usually support?

[TBA is] intended for smaller projects. It’s really great for folks that aren’t experienced in the brownfields program, it’s a good way to become familiar with the program and it’s an easy way to get support without having to manage a grant. So it’s also really well suited for communities that don’t have a lot of capacity to manage grants.

But the one key thing that it doesn’t do, though, is provide a really quick turnaround. TBAs are free, and high quality, but not as fast as hiring a consultant yourself to do assessment work. That makes the free part really important.

What projects does TBA not support?

We’re restricted to doing assessment work. A TBA cannot clean up a site and each TBA assesses one site. Communities can apply to the EPA or state programs for community-wide assessments or cleanup grants. The information provided by a TBA can be used to determine the cost and scope of cleanup as well.

What should I have prepared if I want to apply for a TBA?

We basically want to know where the site is, how large the site is, and any available information about the history. And the key thing is, what the reuse is going to be. A good project for a targeted brownfields assessment [will have] some sort of near term redevelopment plan […] And then the other key thing is we need to have access consent signed by the property owner. The TBA applicant does not have to own the site, but you will need site access so the EPA contractor can conduct the assessment.

What’s the difference between TBA and an assessment grant?

The main difference is, when you are awarded a grant, there are certain administrative tasks that you have to complete. You have to create quarterly progress reports, you have to do all the financial tracking, you have to hire your own contractors or sub recipients to actually carry out the work, you have to monitor all of that stuff throughout the life of the grant, which can be three, four or five years.

Whereas for the targeted brownfields assessment, you submit the application, then an EPA contractor conducts the work and gets the answers you need in order to move to the next step. TBAs can be used to: identify a site’s historical use, determine the scale and scope of contamination, and/or to develop Analysis of Brownfield Cleanup Alternatives (ABCA).

So it’s really just focused on specific decision points within the targeted brownfields assessment. But the major difference, of course, is that TBA is focused on specific sites and specific activities. Assessment grants offer more flexibility but with added responsibility.

What happens if my property is contaminated?

TBA is really focused on completing phase one assessments to figure out the history of the site and conducting phase two assessments which involve performing environmental sampling to collect new data to evaluate whether there’s contamination present that would present a concern for future redevelopment.

And then, [an EPA contractor is] able to prepare an ABCA using the results of the phase two assessment, which is an evaluation of potential cleanup alternatives based on cost and effectiveness. An ABCA is something that you would need in order to submit a cleanup grant application. So ideally, we would do that TBA, complete the phase one Phase II assessment and the ABCA. Then whoever applied for the TBA could submit a competitive cleanup grant application.

We occasionally run into a concern that EPA might suddenly take regulatory action towards [property owners] if contamination is found. We do not. We’re a voluntary program.

How can TBA fit in with other grants, state programs and funding sources I might have access to?

Our TBA program is a great first step. Whether it’s because a community doesn’t have the capacity, or doesn’t want to deal with a lot of the strings that federal funding through a grant requires. It’s a great first step to get a property or site moving along towards reuse.

A TBA could also plug some holes. An applicant might actually have an existing grant, but that site is not eligible to be assessed under the grant, but it can be assessed under our TBA Program.

Also, you have options for where you apply for cleanup funding. We’ve had California applicants have assessments done through our TBA program, who then have used that to apply to the DTSC ECRG program. In Nevada, the state has a program specifically for hazardous building material abatement, an ABCA can be used to apply for this funding as well. Whatever process other states have for applicants to tap their brownfields resources, TBA could help them potentially access those resources.

Where should I look for more information?

And, reference this helpful side-by-side comparison if you’re choosing between a TBA and an Assessment Grant:

*This interview has been condensed and edited for clarity