Land Banking and Brownfield Redevelopment

Transcription

Land Banking and Brownfield Redevelopment
LAND BANKING AND
BROWNFIELD REDEVELOPMENT
TRACK 4 – Community Development
Presented: Wednesday, May 13, 2015, 8:30-10:15am
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Presenters
TRACK 4 – Community Development
• Charles Bartsch, Senior Advisor - Economic
Development, US Environmental Protection
Agency
• Jill Kotvis, Environmental Attorney
• Tracey Nichols, Director of Economic Development,
City of Cleveland, Ohio
• Jim Rokakis, Executive Director, Thriving
Communities Institute
• Michael Taylor, President, Vita Nuova LLC
• Robert “Bud” Sweet, Director, NDC - Moderator
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NDC ACADEMY
Land Banking & Brownfield Redevelopment
May 13, 2015
www.RethinkCleveland.org | 216.664.2406
Cleveland’s Industrial Commercial
Landbank (ICLB)
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Properties must be well-located
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Purchases Land or accepts through donation
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Remediates under Voluntary Action Plan
Perform a Site Assessment to estimate
Clean-up Cost
Purchases Environmental Insurance
City seeks State and Federal Funds, using
local funds for match
Seeks developers
www.RethinkCleveland.org | 216.664.2406
The Health Tech Corridor
University
Circle
Institutions
in the
foreground
and
Downtown
in the
background
www.RethinkCleveland.org | 216.664.2406
The Problem Statement
We have 2 Major Employment Areas that are
strong and thriving- surrounded by weaker
areas & a new transit line
• How do we connect the two areas and connect
residents to employment?
• Once we have the transit connection, how do we
EXPAND these strong areas, attracting new businesses?
• How can we keep incubated businesses in the City after
they graduate so we can capture their growth?
www.RethinkCleveland.org | 216.664.2406
The Health Tech Corridor- Before
www.RethinkCleveland.org | 216.664.2406
Acquiring Multiple Parcels
•Property Values
decreased in the
Health Tech
Corridor area from
2001 -2006 by 58%
•Property Values
increased by 325%
from 2006 - 2012
Source: Cleveland State University 2013
Acquire Land to Deter Speculators
• ICLB acquired land ahead of transit project
• Non-ICLB Land Example: A 6.2 acre used car
lot bought in 1984 for $35,000
• Transit announcement: 2005 $75,000
• Transit opens: 2008- speculator $110,000
• Developer acquires for larger project $276,000
• Land Value 2015 $174,000 per acre for clean
land per appraisal ($1.08 million)
www.RethinkCleveland.org | 216.664.2406
Developer Led Project:
Midtown Technology Center
128,000 sf post
incubator space
New home of
Jumpstart,
Cleveland Heart
Lab and
Chamberlain
School of
Nursing
85% leased
www.RethinkCleveland.org | 216.664.2406
ICLB Properties in the Health
Tech Corridor
To be sold at Council
June 2015
University Hospitals
40,000 SF Clinic
(yellow)
Even with FMV sale for $1.9m, the
City had paid $2m plus $2m in State
and Federal Grants. Payback is over
time!
Hemmingway
Development Multi
phase Med Tech
Campus (Red)
Sold at FMV $174,000
The ICLB
Property
Former Tops Grocery
Superior and Lakeview
Green City Growers
Acres
6.46
9.85
End Use
Site of Sav-A-Lot, Forman Mills,
Advance Auto
Food Production—Greenhouse
E. 61st & Chester Block
2.53
Medical Tech Campus
E. 57-59th/ChesterEuclid
Midland Steel
7.37
University Hospitals Women &
Children Clinic
Listed with Broker
Trinity Building
5.6
Ward Bakery
2.5
New 3rd District Police Station
Warner Swasey
2
Listed for Sale/Historic Bldg
Coke Plant-CVIC
54
Manufacturing
Asbestos Abatement Completed. Developer due
diligence underway
11 acres sold January 2015.
Asphalt Plant
Crescent Avenue
2.7
10.77
Marketing the Site
Support Maritime Industry
Adjacent company pursuing expansion
Working with Army Corps on wetland issue.
22.0
125.78
City of Cleveland Kennel Site
Status
SOLD August 2011
OUTLOT Sold—October 2012
Assembled & Remediated 2010 -2011
SOLD December 2011
To Council for Sale 6/2015
To Council for Sale 6/2015
OEPA Covenant Not-to-Sue 2012
OEPA Covenant Not-to-Sue 2013-Completion
2016
Site Under Development- Completion 9/2015
45.31 acres sold/under development
www.RethinkCleveland.org | 216.664.2406
Cuyahoga Valley
Industrial Center
54 acre site
Tracey Nichols
Director
Dept. of Economic
Development
(216) 664-3611
tnichols2@city.cleveland.oh.us
www.Rethinkcleveland.org
www.RethinkCleveland.org | 216.664.2406
Repositioning + Revitalization:
Taking on Tough Projects
Michael B. Taylor
WWW.VITANUOVA.NET
President | Vita Nuova
MTaylor@VitaNuova.net
(888) 308-1750 ext. 103
Regional Transit Station
Consolidation Plan
5 KEY INITIATIVES
 Reuse Planning
 Neighborhood Improvements
 Job Preparation & Job Training
 Safety
 Youth Engagement
PARTNERS
U.S. EPA Region 5 | City of Toledo | Cherry Street Legacy Project –
St. Vincent’s Hospital | Toledo Design Center | Toledo Community
Foundation | Funder’s Network for Smart Growth | Toledo Port
Authority | Old West End Neighborhood Initiative | NeighborWorks
Toledo | Toledo Land Bank | Lucas County Department of Planning
and Development
www.TOLEDOAWP.com
Brownfield Redevelopment:
Key issues, best practices to
promote Opportunities for
Contaminated Site Transactions
Charlie Bartsch
Senior Program Advisor for Economic
Development
US Environmental Protection Agency
NDC Academy
May 13th, 2015
Bartsch.charlie@epa.gov
What this discussion will cover…
• Brownfields and the environmental context for
economic redevelopment
• Emerging federal policies linking environmental/
brownfields and economic development
• Financing tools that can support brownfields
reuse as part of an economic
development strategy
• Examples along the way…
Current context for brownfield
opportunities – re-development again
makes sense, often in a greener market
context
• Growing demand for sustainable end-uses
– “Green” = reduced O&M = market appeal; fits well
with smart growth, redevelopment strategies
• Decline in traditional infill/reuse = search for new uses
– i.e., health centers, public facilities, renewable energy
• Public sector incentives poised to play an even more
important role as catalyst, gap funder, partnership foundation
– Traditional programs can be better adapted to new
situations – and they are evolving
– New opportunities may be emerging – bond financing
– Alternative packaging strategies more important
Environmental overlay on the economic
development process….
• Promoting brownfield reuse is consistent with goals related
to sustainability, community development, smart growth
– Makes the most sense to promote new economic activity
in areas that have hosted it before
– Infrastructure, workforce, core community amenities/
advantages adjacent – and paid for!
• Reusing sites and facilities almost always triggers an
assessment to determine what residue from past uses might
remain, how it can be minimized to address future
liabilities
Environmental overlay on the economic
development process….
• Developers, investors, lenders will not consider previously
used properties unless they are comfortable that any risk
can be defined and managed – and this includes
environmental risk
• Federal/state/local financial tools, regulatory procedures,
technical assistance, and revitalization strategies can
enhance the local economic advantage
• Addressing this overlay is “Step 1”
in the economic redevelopment
process – for all
previously used sites
Legal stuff you should know up front…
New re-development reuse of formerly used properties
may be influenced by several federal environmental
statutes – and there is often confusion about what
might apply:
• RCRA – Resource Conservation and Recovery Act
– Governs disposal of solid waste and hazardous
materials
– “Cradle to grave” regulatory, tracking requirements
• LUST/UST – Leaking Underground Storage Tanks
– Practical reuse options brought under brownfields
umbrella in 2002 law
Legal stuff (continued)
• CERCLA – Comprehensive Environmental Response,
Compensation, and Liability Act
– Strict/joint/several liability
– Absent action: everyone in chain of title liable for full
amount of cleanup, forever
– Sites on National Priorities List (NPL)
• Brownfields – Defined in law 2002 – sites with “real or
perceived contamination” impeding redevelopment
– Delegates regulatory sign-off to states in most cases, via
VCPs
• Prevents federal “second guessing”
– Authorizes process to achieve liability relief (AAI)
– BF-specific assessment/cleanup funding authorized
And the practical redevelopment impact of all
this legal stuff …
• No commercial real estate transactions
without environmental due diligence
– Site assessments/investigations –
Phase 1, Phase 2, legal opinions, AAI
• “Buyer beware” – uncertainties over
closure, transfer
• Investor/lender nervousness –
unwillingness to finance cleanup
– Private lenders risk concerns, “fear
of the unknown”
– Federal agencies, local governments
conservative in approach to
participation in housing, economic
development, supportive projects
Emerging policies – New “3 Rs” for old brownfield
sites
Reuse/Redevelop/Reposition
• Most interesting and (in most areas) most common strategy involves
creative reuse of former brownfield sites – renovations or demolition
and reconstruction
• Advantages – unique architecture,
historic, prime location to take advantage
of new land use patterns
• Common types of reuses –
– Restaurants
– Office/commercial/industrial
– Major retail/small retail
– Health/other services
transportation access
– Technology incubators
– Private residences
– Community centers/recreational
facilities/open space
Carrying out these policies in
practice – what is being
done now?
Defining a context for brownfield site reuse
• Approach brownfield reuse as an economic
development issue with an environmental twist, rather
than as only a contamination problem
• View brownfield projects as real estate deals that
further community development goals
• Enlighten private parties about VCPs and liability relief
• Transform environmental issues at brownfield sites into
an approach that creates value, attracts investment,
generates jobs, and gathers support
What is being done now
involving brownfields – across
agencies?
• Investing in Manufacturing Communities Partnership
(IMCP) – White House driven/DOC led
– Goal: re-shoring, promote new manufacturing
investment, support industrial legacy communities
• Strong Cities/Strong Communities (SC2) and Promise
Zones – both established by Executive Order/led by HUD
– Goal: increasing local capacity to restructure distressed
economies, increase capacity and competitive advantage
• In all 3 initiatives – EPA/brownfields playing a key role –
providing expertise and technical assistance, integrating
smart growth, area-wide planning, sustainability practices
into investment strategies
What EPA is doing now – priorities,
partnerships, new initiatives
• Administrator’s key priorities framed in a
context of sustainable development linked to environmental
protection, stakeholder involvement
• 50 communities identified
• AA’s priorities within this objective – promoting
new/enhanced inter-agency, public-private working
partnerships aimed at revitalization results
– Defining, addressing environmental issues/concerns as
part of the economic/community development continuum
– De-mystifying environmental component of reuse process
– Identifying common program missions – promoting
financing leveraging/linkages across agencies
EPA Priority in Practice –
Brownfield Area-Wide Planning
• Rationale – to better integrate brownfields with
community economic development strategies
• Objective – to explore broader, community wide
redevelopment strategies in disadvantaged areas,
integrate site cleanup and reuse into coordinated
community development/revitalization strategies
• Goal – implementing improvements in brownfieldimpacted areas according to a community vision –
based on inter-agency, public-private partnerships to be
strengthened, developed during the planning process
Public Tools Can Be Leveraged in Various Ways
to Promote Brownfield Redevelopment
 To provide resources directly
 Grants; forgivable/performance loans
But also to…
 Reduce lender’s risk
 loan guarantees; companion loans
 Reduce borrower’s costs
• interest-rate reductions/subsidies; due diligence assistance
 Improve the borrower’s financial situation
• re-payment grace periods; tax abatements and incentives;
technical assistance help
 Provide comfort to lenders or investors
• performance data, risk management/corroboration
Which Federal Financing Programs/Tools Are
Well Suited to Support Redevelopment on
Brownfield Sites?
EPA/environmental programs
• EPA brownfields – grants for site assessment, cleanup, RLFs
HUD/community development programs
• CDBG – Grants, locally-determined loans for
economic/community development, planning
• Section 108 – Loan guarantees for site prep/infrastructure
USDA/rural development, utility programs
• Business/industry development, rural utilities services
EDA/Public works, planning, economic adjustment
• Finances business-based, job promoting projects, supports
necessary redevelopment infrastructure
DOT/transportation
• Road/transit system enhancement, construction, improvement
Making the “Fit” -- How Have Federal Programs
Been Used to Support Brownfield Redevelopment
Projects?
Eligible program activities can include:
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Planning for redevelopment/reuse
Site acquisition
Environmental site assessment
Removal, remediation, capping of
contamination from sites or structures
• Site clearance
• Demolition and removal of buildings and debris
• Construction of infrastructure/related
improvements/amenities that enhance site value
Federal programs – Funding
wrinkles & reality check
CDBG
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Projects are locally determined; significant
competition for local funds
Brownfield activities must be incorporated
into CDBG Consolidated Plan and annual action plan
Low-mod benefit is primary HUD objective (minimum
use of 70% of CDBG funds)
USDA
• Applications are made to state USDA state offices on
a rolling basis; these offices have significant
influence on project funding decisions
• Population a key determining factor
• Private entities eligible for B&I assistance
Federal programs – Funding
wrinkles & reality check
EDA
•
•
Limited funding, significant competition
Applications accepted quarterly
– Pre-approval at regional office level
• Unemployment key eligibility/selection factor
• Projects driven by $/job requirements, job potential
• Often, a focus on small towns, rural areas
DOT
•
•
•
State MPOs, transportation agencies key decision makers
Historic preservation/rehabilitation/operation of historic
transportation buildings or facilities eligible
Long lead time for planning, project integration
CDBG: Chevy Place – Rochester , NY
• 2.2 acre downtown auto dealership,
gas station, and service garage site
• Key concern -- UST and other
contamination deterred developers
• Role of CDBG – Critical gap
financing; used for site assessment,
partial 1st phase cleanup (including
tank removal)
• Developer funded 2nd phase of
cleanup
• City $2.35 million redevelopment
loan from CDBG-capitalized pool
• Brownfield result – 77 new
residential units; coffee house with
20 jobs
USDA: Potosi Brewery, Potosi, WI
• Brewery built 1852 in Potosi
(pop. 700), abandoned 1972
• Key concern – owner/developer
unclear about reuse process
• Role of USDA – $3.3 million
B&I guaranteed loan key to securing
additional $4.2 million in financing
• EPA, state site assessment,
cleanup grants
• Transformed Potosi’s main street;
community involvement key
• Brownfield result – Refurbished site
transformed into micro-brewery,
brewing museum and library
• 50 new jobs, 4 new beers
EDA: Bates Mill – Lewiston, ME
• Textile mill, shut down in 1993,
redeveloped in stages as small business
incubator
• Key concern – retrofitting, positioning
contaminated mill site for new small
business use
• Role of EDA – $1 million in public
works funding supported site cleanup and
infrastructure upgrading activities, part of
$41 million financing package
• EPA assessment grant assistance
• Brownfield result – Less than 100
employees in 1993; 1,000 today
– Mill generated $160,000 in taxes in
1993; today, $543,000 per year – even
with tax incentives in place
DOT: Former Conoco Tower –
Shamrock, TX
• Opened in 1936 to serve the new Route 66 cutting
thru the city; combined gas station and “U-Drop
Inn Café”
• Closed in mid-1990s
• Purchased by First National Bank of Shamrock in
1997 and donated to city
• Restored by city of Shamrock for use as Chamber
of Commerce
• $1.7 million DOT enhancement grant paid for
most of the station restoration, supplemented by
local fundraising
• Café is being restored as a revenue-generating
enterprise to help cover maintenance costs
• Fun fact: inspired “Ramone’s Body Shop” in
Disney movie “Cars”
EPA: housing project – Taunton MA
• 6.5 acre, century-old former
Robertson yarn mill; vacant 10
years
• $52,000 EPA cleanup grant to
non-profit Weir Corporation
– Key first steps in cleanup, to
demonstrate viability of local
interest in redevelopment
• Set the stage for preparation of
site for LIHTC-supported
development
– 64 housing units
– 18,000 sq. ft. commercial space
• Leverage -- $15 million
local/state/private investment
Three key federal tax incentives that can
be linked to brownfield revitalization
transactions – all at little or no cost to the
project….
• New Markets Tax Credits
• Rehabilitation tax credits
• Low-income Housing Tax
Credits
New Markets Tax Credits
• Gives investors federal tax credits (39% over 7
years) for equity investments in designated
Community Development Entities (CDEs), for use
in low-income communities
• CDEs use their allocations to make loans or investments
in “qualified businesses” and development activities –
 Historically, most common investments -- in forprofit, non-profit businesses and real estate
 Other eligible activities include -- charter schools,
homeownership projects, community facilities
 All investments at preferential rates/terms
 Brownfield cleanup and site preparation can be
factored into NMTC project
New Markets Tax Credits -- highlights of 2013
funding round (announced 6/5/14)
 $3.42 billion authorized to 87 CDEs in 32 states
 Allocatees anticipate making investments in 44 states
 Distribution by area type:
 $2.01 billion (60%) in major urban areas
 $680 million (20%) in minor urban areas
$742 million (20%) in rural areas
 Planned loans to or equity investments in include:
 $2.75 billion (75%) to finance/support business loans
 $831 million (24%) to finance real estate projects
New Markets Tax Credits –
fine print and caveats impacting
brownfield application
• Challenging CDE designation, application
process requires significant capacity,
technical expertise
– Time consuming and complex
• Cannot be combined with LIHTCs, tax-exempt bonds
• Costly – legal, other fees
• Matchmaking a good strategy – find a CDE with allocation!
– Recipients must allocate credits within 5 years
• Historically, 50% + of all allocations have supported forprofit and non-profit business development
– Significant capital investment in distressed areas – often
synonomus with brownfields!
NMTCs : Artspace Commons North – Salt
Lake City, UT
Former metal scrap yard
•
• Redeveloped into 102 rent-to-own
units
• Includes 53,000 sq. ft. of retail
• Key concern – financing gaps
stemming from rehab of brownfield
into affordable housing
• Role of NMTCs – $27.1 million
instrumental in attracting private
capital from US Bancorp Community
Development Corp., American Express
Centurion Bank
• Significant additional private
investment in surrounding area
Historic Rehabilitation Tax Credits
 Taken the year renovated, income-producing building is put into
service
 20% credit for work done on historic structures, with rehab work
certified by state
 10% credit for work on “non-historic” structures built before 1936;
no certification required
In 2013 – 1,155 projects, $1.35 billion in credits
 Leveraged $4.02 billion in private investment
 25% of projects less than $250,000 in size; 39% less than $½
million
 21% of projects for office, 20% for commercial
 Created 55,458 jobs
 Generated $5 billion in state tax revenues, $4.9 billion in local tax
revenues
Rehabilitation Tax Credits –
caveats and “fine print” impacting brownfield
application
 Rehabilitation costs must be “substantial”
–
i.e., exceed minimum of $5,000 or the
building’s adjusted basis
 Property must be “income-producing” – multi-family
rental housing can claim the 20% credit, but not the 10%
credit
 Rehab work must conform to state historic preservation
standards – deter integration of “green” technologies
 Credit is recaptured on a sliding scale (20% annually) if
owner disposes of the building within five years of
completing renovation
Rehab tax credits: Ford Motor Assembly Plant
-- Richmond CA
• Built in 1930, 520,000 sq.ft. ; closed 1953
• Original Albert Kahn “ daylight factory”
• Rehabilitation work began in 2004
– Included seismic retrofits, green
performance measures, including
solar panels on roof
• $11 million in rehab tax credits
• Today – houses several
manufacturers of sustainable
products, plus 45,000 sq ft meeting
and entertainment venue
NMTC/rehab credits blend: Family
Health Care – Fargo, ND
• Former 1920 Pence Automobile Company
renovated in 2011 to house consolidated
operations of Family HealthCare
• $1.4 million in historic rehab tax credits
supported the $14.8 million project
• $4.1 million in NMTC thru Wells Fargo
Bank
• Other financing:
– $6.6 million HRSA facility improvement
grant
– $1.3 million from local foundations,
corporate contributors
– $2.6 million in FHC equity
Low-Income Housing Tax Credits
 Can encourage capital investment in affordable housing
on vacant properties, brownfields, other targeted sites
 States get annual population-based allocation for
distribution to communities and non-profits – approx.
$1.75 per capita
 Investors can get 9% annual credit for 10 years for
qualified new construction/rehabilitation costs (i.e. 90%
of total) for projects not financed with federal subsidy
 Federal subsidy limits credit to 4%
 Credits can be used for new construction, rehabilitation,
or acquisition and rehabilitation
Low-Income Housing Tax
Credits – fine print and caveats
 Loss of tax incentive value on secondary
market – from peak of 95 cents/$ to 75-85
cents/$ now – impacts syndication value
 “Green” priority for credit allocations within states
 “Difficult development areas” can get greater subsidies
 Credits support a wide range of housing types/situations
 Urban, suburban, rural projects
 Housing for families, special needs tenants, SRO, elderly
$3.85 billion in credits issued in fiscal year 2012,
supporting 1/3 of all new construction that year
Albina Corner – Portland, OR
• 3/4 acre Albina Corner is adjacent
to a bus line and near a major light
rail station
• Abandoned gas station, retail shop
• Small scale contaminants have
deterred reuse
– Tanks, lead paint
• Site redeveloped into a mixed-use
area that includes 48 units of lowincome housing built over 12,000
square feet of commercial space;
includes a child care center and a
second floor courtyard and play lot
• LIHTCs one of 11 funding
sources for the $4.4 million project
– Other include CDBG, Oregon
Housing Trust, foundations
Brian J. Honan Apartments – Boston, MA
•
Allston-Brighton CDC saw an
opportunity to develop former fish
processing plant into affordable
housing
• Low-income housing tax credits
key parts of financing incentive
package needed to attract capital,
convince funders that the project
would work
• Result – affordable units in a
sustainable development: green
energy, pedestrian access to
groceries, shops, transit
State and local
financing tools
and trends
What Innovations Have States Put In Place?
A few highlights…
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Cleanup expensing tax incentives (CO)
TIF guarantees with brownfield priority (PA)
Forgiveness of back taxes on brownfields (WI)
Transferable remediation tax credits (MA)
Licensed site professional (NJ/CT)
Tax refunds to offset cleanup costs (NJ)
Sliding-scale brownfield tax abatements (TX)
G.O. bonds to capitalize cleanup RLF (OR)
Most commonly used local
tools for brownfield finance
Often, it’s Putting a Brownfields “Spin” on the Local
Tried-and-True…
•
•
•
•
•
Tax increment financing/TIF-type financing
Tax abatements
Tax forgiveness (linked to redevelopment)
Special service areas or taxing districts
Revolving Loan Funds (RLFs) – including
locally defined, managed, and capitalized
• General obligation bonds
• Property transfers
Jersey Gardens Metro Mall – Elizabeth, NJ
• 166-acre former garbage
dump, across the street from
Ikea Center – Elizabeth’s
first big brownfield success
• $320 million investment –
1.5 million square feet of retail
space, resulting in 5,200 jobs
and $4.2 million annual tax
revenue increase
• Bonds being paid off through
franchise fees levied within a
“landfill reclamation
district” established for this
project, paid by mall tenants as
part of their rent
Belmar/former Villa Italia Mall – Lakewood, CO
• 22 city block redevelopment at former mall, closed mid-1990s
– Contaminants linked to dry cleaner, supermarket, asbestos
• Redeveloped into Lakewood’s first walkable mixed-use
“downtown” center
• TIF-like financing strategy – new sales tax generated from
project earmarked to cover costs of roads, structured parking
• Saving costs by incorporating renewable energy (solar PV arrays)
on top of 3 parking structures
– 2.3 million kWh annually, 5% of Belmar’s energy use
Waterfront Development – New Bedford, MA
• Locally capitalized
RLF used to pay for
Phase I site
assessments at sites
served with
environmental tax lien
• Capitalization sources
include local
contributions,
proceeds from
property sales as liens
are redeemed
How does EPA
see brownfields/
development
link?
• Manufacturing, housing, transportation, community service
objectives can be consistent with EPA goals related to
brownfields, smart growth, climate change, sustainability, and
overall environmental improvement
• Expanding ability of communities of all size to recycle vacant
and abandoned properties for new, productive reuses in ways
that build on local economic advantages.
• Leveraging private resources, and other federal and state
programs resources to promote site cleanup as part of the
redevelopment and reuse process.
• Expanding awareness of pro-active role EPA can play in
community and economic development and job creation.
Take away message on financing transactions on
brownfield properties…from Warren Zeevon”
“…I took a little risk.
Send lawyers, guns, and money,
Get me out of this….”
Take away message on contaminated
property reuse…from me
• Creatively use a mix of development and environmental
programs to meet the full range of site redevelopment needs,
attract private financing for every aspect of a transaction
involving contaminated property – including those focusing on
renewable energy
• Blend cash, process incentives, and cash offsets to make a
project work
• Focus on creative strategies, ideas, program applications
For additional information….
Contact Charlie Bartsch at
Bartsch.charlie@epa.gov
(202) 566-1054
Plan on attending Brownfields 2015 !!!