Audit, Compliance and Risk Blog

EPA’s Climate Smart Brownfields Manual

Posted by Jon Elliott on Fri, Sep 22, 2023

pexels-chris-leboutillier-929382-1Several national laws empower the US Environmental Protection Agency (EPA) to set standards for the cleanup of contamination that resulted from accidental or deliberate releases of chemicals and other materials onto land or into water. EPA’s actions include direct requirements for cleanup by responsible parties, and also inform other parties’ evaluations of if and how to prepare contaminated areas for reuse – often referred to as “brownfields” since they’re assumed to be dirtier than never-used “greenfields.” The remainder of this note discusses EPA’s 73 page “Climate Smart Brownfields Manual,” issued by the agency in 2021

What goals are the manual intended to support?

EPA summarizes its goals as “This manual will help communities think about climate mitigation, adaptation, and resilience in the context of brownfield cleanup and redevelopment. This includes consideration of projected climate change and potential impact on vulnerable populations when performing brownfield site assessments, evaluating cleanup alternatives, and planning for redevelopment.” Five chapters present EPA’s guidance, and the manual includes extensive cross-references within its discussions as well as an additional Resource Guide, Citations, and exemplary “Snapshots.”

  • Chapter 1: Planning for a Resilient Brownfield Revitalization

In this chapter, EPA’s encouragement to planning starts with the recognition that many greenhouse gas (GHG) emissions result from human activities within the “built environment.” Accordingly, EPA advises that the planning phase should include explicit consideration of activities that do – or will – emit GHGs, as well as planning for known and projected impacts (e.g., flooding, drought, sea level rise) that require adaptive responses to climate change. EPA provides discussion (with citations and references) of a variety of relevant initiatives:

  • [Importance of] Public Participation
  • Community-wide Planning Perspective
  • Improving Resiliency through Local Leadership
  • Municipal and City Leadership
  • Infrastructure Development and Building Codes
  • Tax Credits, Rebates, and Discounts
  • Zoning
  • Chapter 2: Assessing Brownfields and the Surrounding Area with a Changing Climate in Mind

Once a brownfield site is chosen for redevelopment, EPA notes that environmental site assessments (ESAs; Phase I and if appropriate follow-up Phase II) are conducted to determine the extent of any contamination, and to assess potential public health and environmental risks. Following ESAs, potential cleanup options are considered relating to the intended site use and redevelopment. In this chapter, EPA discusses:

  • Phase 1 Environmental Site Assessment
  • Phase 2 Environmental Site Assessment
  • Analysis of Brownfield Cleanup Alternatives
  • Chapter 3: Reducing Climate Impacts through Greener Demolition

This chapter discusses ways in which the site-based demolition and deconstruction can be designed and then implemented to improve sustainability and reduce environmental impacts. It discusses four basic steps in deconstruction projects:

  • Create an inventory of materials that can be reused or recycled.
  • Identify local reuse partners to enhance the reuse potential.
  • Identify ways to reuse deconstructed materials in the redevelopment.
  • Deconstruct where possible.
  • Chapter 4: Implementing Greener Cleanups

This chapter describes ways to incorporate climate change resiliency strategies into remediation plans and cleanup operations. These include efforts to reduce emissions and wastes from cleanups, and to enhance the site’s post-cleanup resilience in the face of climate change. Subchapter discussions address:

  • Green Remediation: What It Is and Why It Is Important
  • Implementing Greener Cleanups
  • Practical Application
  • Reduce Energy Use
  • Reduce Water Use and Impacts to Water Sources
  • Materials Management and Waste Reduction
  • Land Management
  • Bioremediation and Phytoremediation: Lesser-Used Technologies on Brownfield Cleanups
  • Onsite Remediation
  • Chapter 5: Redeveloping Brownfields for Climate Resiliency

This chapter discusses the redevelopment phases of brownfield site projects, focusing on ways to enhance the sites’ resiliency to anticipated climate change effects. Subchapter discussions consist of:

  • Green Infrastructure
  • Renewable Energy
  • Green-Building Techniques and the Built Environment
  • Community Amenities and Social Structures

What happens next?

This Manual compiles extensive EPA guidance to help plan and implement brownfield redevelopment projects in ways that minimize additional hazards and enhance climate change resiliency. The manual provides no requirements, but organizations contemplating brownfield site redevelopment projects should consider its many insights and references.

Self-evaluation checklist

Is the organization involved in the evaluation and potential redevelopment of any “brownfield” sites where existing or previous uses may have created contamination?

- If so, has the organization conducted environmental assessment(s) to identify and characterize contamination?

- If so, has the organization evaluated alternative remediation and reuse activities at the site(s)?

Where can I go for more information?

About the Author

jon_f_elliottJon Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 30 years. 

Mr. Elliott has a diverse educational background. In addition to his Juris Doctor (University of California, Boalt Hall School of Law, 1981), he holds a Master of Public Policy (Goldman School of Public Policy [GSPP], UC Berkeley, 1980), and a Bachelor of Science in Mechanical Engineering (Princeton University, 1977).

Mr. Elliott is active in professional and community organizations. In addition, he is a past chairman of the Board of Directors of the GSPP Alumni Association, and past member of the Executive Committee of the State Bar of California's Environmental Law Section (including past chair of its Legislative Committee).

You may contact Mr. Elliott directly at:

Tags: Health & Safety, EPA, chemical safety, Hazardous Waste, Environment