Our project consists of constructing a high-rise dormitory building on the site of an existing parking lot in downtown Boston. To the best of our knowledge, the site is not classified as a Brownfield by the EPA, and there are no classified Brownfields on campus. However, the site requires significant remediation of contaminated soils. Our site selection process considered other "greenfield" sites, but chose this site in order to maintain existing campus green space. The intent of this credit is to "rehabilitate damaged sites where development is complicated by real or perceived environmental contamination, reducing pressure on undeveloped land." We believe that our project meets this intent. Can we still apply for this credit if the site is not classified as a Brownfield by the EPA?
You may be able to demonstrate that you meet the intent of the credit by demonstrating that a regulatory agency (the EPA or other agency with jurisdiction) has determined that the site is contaminated. Through your regional EPA office or local regulatory agency, you might be able to make a case that the site fits the current definition of brownfields standards. We suggest you contact the Region 1 EPA office for further information concerning this definition and whether or not this site can be assessed as a brownfield. It would be necessary to provide documentation from the EPA or a local regulatory agency stating that even though the site is not classified as an actual EPA Brownfield, it does meet the EPA criteria for a brownfield. Indicate that you have adopted appropriate remediation measures to clean up the contamination. Region 1 Brownfields: http://www.epa.gov/region1/brownfields/basics/reuse.htm EPA Targeted Brownfields Assessment: http://www.epa.gov/region1/ Also, keep in mind that if only part of the project site is a brownfield, it can qualify for this credit. Credit Inquiry 1000-SP902-6/9/99 states: "If the project incorporates a parcel into the overall building site that qualifies as an EPA brownfield, and the owner follows the EPA guidelines for re-development, the project can earn this credit. The brownfield does not need to cover the entire project parcel."