United States Solid Waste and 

Environmental Protection Emergency Response September 2001 

Agency (5101) 

EPA 500-F-01-348 

Washington, DC 20460 

The Brownfields Economic 

Redevelopment Initiative 

Proposal Guidelines for 

Brownfields Cleanup 
Table of Contents 

Questions & Answers ........................................................... 2

Background ................................................................... 8

The Proposal Evaluation Process .................................................. 10

The Cooperative Agreement Award Process ......................................... 11

BCRLF Terminology ........................................................... 12

Roles and Responsibilities ........................................................ 14

Legal and Program Guidelines .................................................... 17

The Proposal Package .......................................................... 22

Structure of the Proposal .................................................. 22

Cover Page ............................................................ 23

Proposal Overview ...................................................... 25

Budget ................................................................ 26

Threshold Criteria (Sections A and B) ........................................ 27

Evaluation Criteria (Sections C-F) ........................................... 32

Proposed Schedule for Awarding EPA’s BCRLF Demonstration Pilots ...................... 38

Submission/Mailing Instructions ................................................... 39

U.S. EPA Regional Office BCRLF Coordinators ...................................... 40

Appendix A: List of EPA Brownfields Policy and Guidance ............................... 41

Appendix B: List of Current BCRLF Pilots ........................................... 42
Questions & Answers 

What is the U.S. Environmental Protection Agency’s Brownfields 

Program? 

The Environmental Protection Agency’s (EPA) Brownfields Economic Redevelopment 

Initiative is designed to empower states, federally recognized Indian tribes, local governments, 

communities, and other stakeholders involved in economic redevelopment to work together in a timely 

manner to prevent, assess, and safely cleanup brownfields in order to facilitate their sustainable reuse. 

As part of this Initiative, EPA has awarded cooperative agreements to States, and political subdivisions 

(including cities, towns, counties) to capitalize Brownfields Cleanup Revolving Loan Fund (BCRLF) 

pilots. 1 

What is a Brownfield? 

EPA defines brownfields as abandoned, idled, or underused industrial and commercial facilities 

where expansion or redevelopment is complicated by real or perceived environmental contamination. 

What is the Purpose of the BCRLF Program? 

The purpose of the BCRLF pilots is to enable States, and Indian tribes, and political 

subdivisions to facilitate the cleanup and redevelopment of brownfields properties. In particular, these 

pilots will test revolving loan fund models that facilitate coordinated public and private cleanup efforts. 

Financial assistance provided to a BCRLF recipient may be awarded in an amount up to $1,000,000 

per eligible entity. 

How may a Pilot use the cooperative agreement funds? 

EPA will award a cooperative agreement for up to $1,000,000 per eligible entity. A BCRLF 

pilot (cooperative agreement recipient) must use at least 70 % of the funds provided to capitalize a 

clean up loan fund. A percentage of the loaned amount may be discounted for particular types of 

borrowers.2 EPA will allow the recipient to use up to 20% of the cooperative agreement funds as 

1 There are 126 BCRLF pilots that have been awarded since fiscal year 1997. Although no tribes 

have applied for a BCRLF pilot, EPA anticipates tribal government participation in the future. 

2 Cooperative Agreement recipients may “discount” or forego a percentage of the loan amount 

for two types of borrowers: (1) non-profit entities and (2) governmental entities. Non-profit entities may 

receive a 30% loan “discount.” Governmental entities may receive a 20% loan discount. For example, if 

a non-profit entity borrowed $100,000 for a cleanup activity, the cooperative agreement recipient could 

2 
direct financial assistance to the cooperative agreement recipient to carry out its clean up 

responsibilities as “lead agency.” The direct financial assistance must be used by the recipient in 

combination with a specific loan. The remaining 10% of the cooperative agreement may be used for 

the cooperative agreement recipients’ general administrative costs. 

At least 70% of the funds will be used to capitalize a loan fund that “revolves”. A loan 

program “revolves” when it uses loan repayments (principal, plus interest and fees) to make new loans 

for the same authorized purposes. The authorized purpose for the BCRLF is to clean up Brownfields 

sites in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act 

(CERCLA) and consistent with The National Oil and Hazardous Substances Pollution Contingency 

Plan (NCP). 

EPA may provide up to 20% of the cooperative agreement funds to the cooperative 

agreement recipient as direct financial assistance. These funds may be used ONLY by the 

cooperative agreement recipient and ONLY in combination with a loan. These funds may not be given 

to a borrower as a “subgrant.” Upon application for a loan by a borrower, the cooperative 

agreement recipient may use this direct financial assistance to carry out any site-specific “lead 

agency” responsibilities related to that loan. For example, these funds may be used by the 

cooperative agreement recipient to prepare the engineering evaluation/cost analysis (EE/CA) and/or to 

fulfill site specific responsibilities of the lead agency’s brownfields site manager. Other lead agency 

responsibilities that these funds could be used for are described at pages 17-18. 

The remaining 10% of the cooperative agreement may be used for general (non site specific) 

administrative costs. For example, the recipient may used these funds for establishing the administrative 

infrastructure of the revolving loan program. This may include costs related to processing loan 

applications, conducting credit checks, outreach to potential borrowers and loan administration. 

How Many Pilots Will be Selected for the FY 02 BCRLF Program? 

In fiscal year 2002, EPA expects to select up to 25 new BCRLF pilots, awarding up to 

$1,000,000 per pilot. Coalitions are eligible to receive awards up to $1,000,000 per eligible entity. 

Who is Eligible for a BCRLF Pilot? 

Eligible entities for FY 2002 BCRLF pilots will be States, political subdivisions, and Indian 

tribes that have established and can demonstrate the progress already made in the assessment, cleanup 

and revitalization of brownfields in a community, State or Tribe. 

apply the 30% discount and permit the non-profit to repay $70,000 instead of the $100,000 borrowed. The 

amount of the loan discount is determined by the cooperative agreement recipient. 

3 
Consideration will be given to proposals received from eligible entities designated as a Federal 

Empowerment Zone or Federal Enterprise Community. 

Are Pilots Limited to Sites Assessed Under Other EPA Brownfields 

Programs? 

No. Sites cleaned up under the BCRLF pilot program may be drawn from any area within the 

eligible entities’ jurisdiction. Pilot sites are NOT limited to those identified, characterized, or assessed 

under a previously awarded assessment pilot or targeted brownfields assessment. 

Can Proposals from Coalitions be Submitted? 

Yes. Proposals from coalitions, formed among two or more entities, are permitted. However, 

coalition funding will be premised on an award of no more than $1,000,000 per eligible entity. Loan 

funds must be directed to properties located within the jurisdictions of the eligible entities comprising the 

coalition. 

Coalition proposals may take several forms, including the following: 

• two or more eligible entities; one of the eligible entities serves as the cooperative 

agreement recipient for the coalition; or 

• two or more eligible entities with the State serving as the cooperative agreement 

recipient for the coalition; or 

• one political subdivision serving as the cooperative agreement recipient for a smaller 

eligible entity located within the political subdivision’s political jurisdiction, e.g., a county 

acting on behalf of a municipality located within the county’s jurisdiction; or 

• an existing BCRLF coalition may apply on behalf of one or more new eligible entities 

seeking to join a coalition. (The proposal must be submitted by the cooperative 

agreement recipient for the coalition.) 

For each coalition proposal, the following will be required: 

• clear designation of one entity as the cooperative agreement recipient for the coalition 

(this entity will be responsible for administering the cooperative agreement and lead 

agency duties described on pages 14-15); and 

• a letter from each coalition member’s chief executive stating that the entity chooses to 

join the coalition. 

4
• existing coalitions making proposals on behalf of new eligible entities shall provide a 

written affirmative statement that members of the existing coalition (chief executive of 

the coalition entity e.g., the mayor, county executive) have agreed to admission of 

additional entities to the coalition. 

What Must be Demonstrated in the Pilot Proposal? 

Applicants must demonstrate through their proposal: 1) an existing commitment to brownfields; 

2) an ability to manage a revolving loan fund and environmental cleanups; 3) a need for cleanup funds; 

4) commitment to making loans and creative leveraging of EPA financial assistance with public-private 

partnerships and in-kind services3; and 5) a clear plan for sustaining the environmental protection and 

related economic development activities initiated through the BCRLF program. 

Each eligible entity must meet EPA's Threshold criteria and should address the Evaluation 

criteria. A pilot will not be awarded to applicants who cannot meet the Threshold Criteria. However, 

the Agency may seek clarification of threshold issues prior to making a final decision. There is no 

guarantee of an award. The size of the awards may vary, depending on the proposal’s responses to the 

Evaluation criteria. Coalitions are eligible to receive awards up to $1,000,000 per eligible entity. 

What is the Deadline and How Do I Submit the Proposal? 

November 15, 2001 is the deadline for the FY 2002 BCRLF pilots. Proposals must be postmarked by the U.S. Postal Service or sent to U.S. EPA Headquarters via registered or tracked mail by 

the proposal deadline. (Please note that the address for submission of the proposal varies 

according to method used for mailing the proposal – see page 39 for instructions.) A copy of the 

proposal submitted to EPA Headquarters must also be submitted via registered or tracked mail to the 

appropriate U.S. EPA Regional BCRLF Coordinator (See page 40). 

How Does the U.S. EPA Disburse Financial Assistance to the 

Applicant? 

The U.S. EPA has established procedures governing how BCRLF financial assistance to a 

recipient may be paid to the pilot cooperative agreement recipient and, in particular, procedures to 

capitalize the loan fund and subsequent disbursement to borrowers. Payments for direct financial 

assistance (up to 20% of the award) and general administrative expenses (up to 10% of the award) will 

be made on the basis of the costs the recipient incurs or expects to incur within a reasonable time after 

the recipient makes a payment request. (All payments will be made consistent with 40 C.F.R. Part 

35.6280 and 40 C.F.R. 31.21.) 

3 Note, although applicants are encouraged to leverage funds, the program does not impose a 

mandatory match requirement. 

5 
With respect to the financial assistance to capitalize the loan fund and loan fund payments (at 

least 70% of the award), the recipient may establish loan disbursement procedures that allow 

borrowers to request funds based on either actual expenses (e.g., invoices) or a schedule (e.g., 

progress payments). EPA will make payments to the recipient to meet the recipient’s obligations to the 

borrower based on either approach. 

Where Can I Find Additional Information on the BCRLF Program? 

Information regarding the BCRLF pilot program may be found at the EPA Brownfields 

Homepage (http://www.epa.gov/brownfields) under the reference to the “Revolving Loan Fund Pilots.” 

Interested parties are strongly encouraged to review information found in the Brownfields Cleanup 

Revolving Loan Fund Administrative Manual (EPA 500-B-98-001) published in May 1998, which 

is also available at the following location http://www.epa.gov/swerosps/bf/rlflocat.htm. 

Additionally, EPA has made several policy clarifications which may be of assistance to you in 

understanding aspects of the BCRLF program. These policy clarifications include: 

• memorandum dated July 10, 2000, signed by Linda Garczynski, Director, Outreach 

and Special Projects Staff, entitled “Clarification of Site Manager (On-Scene 

Coordinator Role)”, etc.; 

• memorandum dated September 5, 2000, signed by Timothy Fields, Jr., Assistant 

Administrator OSWER, entitled “Clarification of Borrower Eligibility Under the 

Brownfields Cleanup Revolving Loan Fund Program.”; 

• memorandum dated January 10, 2001, signed by Timothy Fields, Jr., Assistant 

Administrator OSWER entitled “Financial Structure of Cooperative Agreement Funds 

Under the Brownfields Cleanup Revolving Loan Fund Program”; and 

• memorandum dated July 17, 2001, signed by Michael H. Shapiro, Acting Assistant 

Administrator OSWER entitled “Amendment to Governmental Entity Loan Discount 

Rate for the Brownfields Cleanup Revolving Loan Fund Program.” 

These policy memoranda may be found at the web site indicated above. 

What is EPA’s Involvement with the BCRLF Program Once the Award 

is Made? 

EPA does not intend to be involved in prioritizing loan proposals, or in the day-to-day 

management of the BCRLF loan program, and, specifically, will have no contractual ties with individual 

borrowers. However, EPA anticipates being substantially involved in monitoring the BCRLF 

program to ensure that applicable legal, financial, and environmental response requirements are met. 

Substantial involvement may include: approval of procedures for site and loan recipient selection, 

review of the substantive terms of loan documents, review or approval of project phases. Substantial 

involvement may also include a general monitoring of operational matters. 

6
7
Background 

The Brownfields Program reflects a new paradigm in environmental protection which is locallybased, encourages strong public-private partnerships, and promotes innovative and creative ways to 

address brownfields sites. Across the country, more than 600,000 properties that were once used for 

industrial, manufacturing, or other commercial uses now lie abandoned due to suspicion of hazardous 

substance contamination, creating blight, joblessness and despair. Perceptions about potential 

environmental liability keep developers, investors, and lenders from restoring such lands to productive 

use. 

Far from a typical regulatory or enforcement initiative, the Brownfields Program encourages 

market incentives and private sector actions to restore brownfields. Its novel approach empowers 

state, tribal, and local environmental and economic redevelopment officials to oversee brownfields 

activities, ensuring that local solutions are created to solve local problems. 

The U.S. Environmental Protection Agency (EPA) supports efforts to assess and cleanup 

brownfields. EPA does this by providing technical and financial assistance, facilitating information 

sharing, and coordinating relationships between 20 federal agencies, as well as trade associations, 

business groups, and non-profits. These relationships are what make the Brownfields Program unique; 

they enable brownfields assessment and cleanup activities to work more effectively in conjunction with 

local, state and federal health, workforce development, housing, and transportation programs, without 

duplication of effort. 

EPA’s Brownfields Cleanup Revolving Loan Fund Pilots facilitate cleanup of brownfields 

properties. The focus of the BCRLF pilots is to capitalize low-interest loan funds for cleanup. Once 

loans are paid back, cleanup loans are then awarded to address other sites, “recycling” the fund as well 

as these properties. EPA also has established other pilot programs. The Assessment Demonstration 

Pilots provide financial assistance to local governments to create two-year programs that build capacity 

and partnerships at the local level, and develop innovative approaches to brownfields issues. EPA’s 

Brownfields Assessment Demonstration Pilots have jump-started brownfields efforts by performing 

environmental assessments, conducting cleanup planning which takes long-term future land-use into 

consideration, and bringing together community groups, investors, lenders, and developers. EPA’s Job 

Training Pilots create locally-based environmental job training programs to ensure that the economic 

benefits derived from Brownfields efforts remain in local neighborhoods. Finally, the Brownfields 

Showcase Communities projects serve as exemplary models of collaboration and cooperation between 

Federal agencies, and public and private stakeholders. 

By participating in EPA’s pilots, each recipient is enhancing its own capacity to address the 

brownfields sites, building partnerships, and developing innovative approaches to brownfields issues. 

Thus, the momentum generated by these Brownfields Pilot projects is expected to long outlive federal 

8
involvement by leveraging state, tribal, local and private investment, and by replacing despair and blight 

with community vitality. 

9
The Proposal Evaluation Process 

BCRLF pilots are selected through a competitive process. All proposals are initially evaluated 

by U.S. EPA Regional evaluation panels. The panels consist of EPA Regional staff, including Regional 

Brownfields Coordinators, and other Federal Agency representatives. The panels assess how well the 

proposal meets the selection criteria and make recommendations on the number and size of the awards. 

Final selection of the pilots is made by EPA Senior Management, following the regional panel reviews. 

Decisions may take into account policy considerations such as geographic distribution of funds. EPA 

reserves the right to reject all proposals and make no awards. 

Proposals must be clear, decisive, and strictly follow the criteria. Proposals for BCRLF pilots 

should address each “Threshold” and “Evaluation Criteria.” (see pages 27-37). The eligible entities 

must meet EPA's threshold criteria. The Agency may seek further clarification of threshold criteria 

during the review process. Proposals also must provide sufficient detail so the panels may compare the 

merits of each, while deciding which proposals best support the intent of the pilot program. Proposals 

providing the best evidence of a true need, a quality project, and appropriate use of funds will have the 

best chance of being recommended by the panels. Vague descriptions and unnecessary redundancy 

may reduce the chance of a favorable rating. 

Applicants are strongly encouraged to familiarize themselves with the Brownfields Cleanup 

Revolving Loan Fund Administrative Manual (EPA 500-B-98-001, May 1998) and the 

Brownfields Cleanup Revolving Loan Fund Administrative Manual: Model Terms and Conditions 

(EPA 500-B-98-002, October 1998) (see, http://www.epa.gov/bf/rlflocat.htm). In addition, policy 

clarifications including the memorandum dated July 10, 2000, signed by Linda Garczynski, Director, 

Outreach and Special Projects Staff, entitled “Clarification of Site Manager (On-Scene 

Coordinator Role)”, etc., and the memorandum dated September 5, 2000, signed by Timothy Fields, 

Jr., Assistant Administrator OSWER, entitled “Clarification of Borrower Eligibility Under the 

Brownfields Cleanup Revolving Loan Fund Program” are located at web site indicated above. 

Applicants may also contact and meet with EPA Regional BCRLF Coordinators for assistance 

prior to submission of their proposal. 

can be found on page 40 of the guidelines. 

A list of Regional BCRLF Coordinators and their phone numbers 

10
The Cooperative Agreement Award Process 

Upon selection, applicants will receive a confirmation letter from EPA Headquarters. 

Applicants not selected also will be informed in writing. 

Successful BCRLF pilot proposal applicants also will be contacted by the appropriate EPA 

Regional office. Successful applicants will be asked to prepare documentation to support the signing of 

a cooperative agreement with the U.S. EPA. 

Cooperative agreements are awarded by the EPA Regional offices. The information in the 

BCRLF pilot proposal, the answers submitted in response to the selection criteria, will form the basis 

for the cooperative agreement application. However, the cooperative agreement application will 

require more detailed information on specific products, schedule, and budgets. 

The cooperative agreement application package will include: 

• the standard application and budget forms (SF 424); 

• a formal work plan that provides a detailed description of the work to be performed, 

including a schedule, milestones, products, and budget backup information; 

• information related to community relations, health and safety, and quality assurance 

plans; 

• and the required certification forms. 

The EPA Regional Brownfields Office and Regional Grants Specialist will work closely with the 

applicant to process and finalize the cooperative agreement package. Unless the Agency makes an 

exception, EPA Regulations require the award official4 to sign the cooperative agreement before costs 

are incurred. 

EPA strongly encourages BCRLF pilot proposal applicants to contact their State 

Intergovernmental Review office early so that the required intergovernmental review process may begin 

immediately upon selection by EPA. If the State does not have an Intergovernmental Review Office, 

the successful applicant must provide notice of the proposed agreement directly to affected State, areawide, regional, and local entities. EPA will provide further guidance, if needed. 

4 An “Award official” is the individual who signs the assistance agreement ensuring that all 

technical, legal, and administrative evaluations have been made and that the proposed agreement is 

awardable. For regionally administered programs, the award official is either the Regional Administrator, 

Assistant Regional Administrator, or Division Director. 

11 
P

BCRLF Terminology 

The following terminology will be used throughout the proposal guidelines: 

P Applicant, or legal recipient, is the state, political subdivision (e.g., city, town, county), or 

Indian tribe that submits a proposal for a BCRLF Demonstration Pilot with EPA. If the 

proposal is from a coalition, the “applicant” must be the legal recipient (lead agency/cooperative 

agreement recipient) for the coalition. 

P • Brownfields Site Manager is the qualified government employee who helps the lead agency

carry out its responsibilities on a site specific basis. The brownfields site manager works on 

behalf of the lead agency. See also, Roles and Responsibilities section on pages 14 for 

further explanation. 

P Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as 

amended or CERCLA, also known as “Superfund,” is a Federal law that governs the 

investigation and cleanup of sites. The BCRLF demonstration pilot program is funded under § 

104(d)(1) of CERCLA. 

P Coalition is a grouping of two or more eligible entities (i.e., State, political subdivision, or 

Indian tribe) joined together under one cooperative agreement recipient. One member of the 

coalition must agree to administer the cooperative agreement and act as lead agency. 

P Cooperative Agreement is the document negotiated between EPA and those applicants EPA 

selected to receive BCRLF pilot financial assistance. The cooperative agreement awards 

federal funds and outlines the terms and conditions to be met by the recipient of the funds. 

P Cooperative Agreement Recipient is the entity with the authority to enter into the 

cooperative agreement and is responsible for the overall implementation of the BCRLF 

demonstration pilot. See also, Roles and Responsibilities section on page 14 for further 

explanation. 

P Eligible Entity is a State, political subdivision, or Indian tribe that has established and can 

demonstrate environmentally sound brownfields programs are underway in its jurisdiction. 

P Fund Manager is the cooperative agreement recipient or its legally designated representative. 

The Fund Manager manages the financial aspects of the fund and ensures that the BCRLF is 

managed in conformance with the cooperative agreement, applicable laws and regulations, and 

prudent lending practices. See also, Roles and Responsibilities section on page 15 for 

further explanation. 

12
P Lead Agency is the cooperative agreement recipient. See also, Roles and Responsibilities 

section on page 14 for further explanation. 

P The National Oil and Hazardous Substances Pollution Contingency Plan or NCP, 40 

CFR Part 300, is the Federal regulation that governs the cleanup of releases of hazardous 

substances, pollutants, and contaminants under CERCLA. 

P Pilot Area is the section(s) of the eligible entities’ jurisdiction in which it intends to make 

BCRLF loans. It is NOT limited to those areas targeted by the Brownfields Assessment 

Demonstration Pilot program or the Targeted Brownfields Assessment program. 

P Political Subdivision is a unit of government that the State determines to have met the 

State’s legislative definition of a political subdivision. 40 CFR § 35.6016(a)(31) 

P Proposal is the document submitted to EPA that provides responses to the criteria described in 

this guideline. If the proposal is selected by EPA, the applicant will be requested to prepare a 

formal application for a cooperative agreement. 

13
Roles and Responsibilities 

The following section describes the roles and responsibilities associated with a BCRLF Pilot. 

This is NOT an exclusive listing of all roles and responsibilities, it is merely a guide. 

P The Cooperative Agreement Recipient 

The Cooperative Agreement Recipient is the entity with the authority to enter into the 

cooperative agreement. As the Cooperative Agreement Recipient, the entity: 

• enters into the cooperative agreement with U.S. EPA; 

• ensures the overall implementation of the BCRLF pilot; 

• ensures that the funds provided by EPA are used for authorized purposes; 

• ensures that these funds are tracked, recorded, and reported to EPA; 

• selects the Fund Manager; and 

• is responsible for the actions of the Fund Manager. 

P The Cooperative Agreement Recipient is the LEAD AGENCY and must carry out all lead 

agency responsibilities identified in 40 C.F.R. §300.415. Lead Agency responsibilities include: 

• determining whether BCRLF cleanup activities at a particular site are authorized by 

CERCLA and the NCP based on site evaluation (described in the NCP at 40 C.F.R. § 

300.410) and on current site conditions; 

• conducting a site-specific engineering evaluation and cost analysis of cleanup 

alternatives as required by 40 C.F.R. § 300.415(b)(4); 

• ensuring that a BCRLF cleanup meets applicable or relevant and appropriate 

requirements under Federal and State environmental laws, as required by 40 C.F.R. § 

300.415(j); 

• ensuring that the NCP public participation requirements (see, 40 C.F.R. § 300.415(n)) 

are met. This includes ensuring the availability of documents, providing adequate public 

comment periods, and designating a spokesperson to inform the community of actions 

taken, respond to inquiries, and provide information; 

14
• establishing an administrative record for each site, as required by 40 C.F.R. § 

300.800(a). (The administrative record contains all the information that forms the basis 

for the selection of a cleanup action, including a decision document describing the final 

selection of a BCRLF cleanup.); 

• working with the Fund Manager, as loan agreements are developed, to ensure that all 

environmental response requirements will be met and that BCRLF funds are used only 

for authorized activities; 

• ensuring the adequacy of each BCRLF cleanup as it is implemented, including, but not 

limited to, ensuring that all Federal and state requirements for worker health and safety 

are met; 

• ensuring that Natural Resource Trustees are promptly notified and coordinated with 

when there are potential damages to natural resources; 

• ensuring that a site is secure and that it poses no immediate threat to human health or 

the environment, if a borrower is unable or unwilling to complete a BCRLF cleanup; 

and 

• identifying the government employee5 who will be the lead agency’s 

“BROWNFIELDS SITE MANAGER.” The brownfields site manager will carry 

out the lead agency’s responsibilities on a site-specific basis. 

P The Cooperative Agreement Recipient selects the FUND MANAGER 

The Fund Manager is the cooperative agreement recipient or its legally designated 

representative. The Fund Manager: 

• ensures that the BCRLF is managed in conformance with the cooperative agreement, 

applicable laws and regulations, and prudent lending practices. 

5 See, policy clarification in the memorandum dated July 10, 2000, signed by Linda Garczynski, 

Director, Outreach and Special Projects Staff, entitled “Clarification of Site Manager (On-Scene 

Coordinator Role)”, etc. Typically, the site manager is an employee of the lead agency. Other options 

include: 1) an employee of the political subdivision, a state government employee, or federal employee 

such as someone from the U.S. Army Corps of Engineers or Bureau or Reclamation; 2) a political 

subdivision’s use of a city ordinance that permits the temporary hiring of city personnel; 3) designation by 

the lead agency of an employee as site manager who utilizes technical support from EPA regional staff; 

and 4) designation by the lead agency of any employee as site manager and contracts for technical 

support. 

15 
• may be a third party (either governmental or non-governmental). If the cooperative 

agreement recipient uses pilot funds to enter into agreements with non-governmental 

entities for these activities, the agreements must comply with 40 C.F.R. §31.37 in the 

case of a subgrant to a non-profit organization, or 40 C.F.R. Part 35 Subpart O for 

contracts with service vendors. Intergovernmental agreements may be used for 

transactions between governmental units. 

16
Legal and Program Guidelines 

The BCRLF program is funded through the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA). BCRLF pilot funds must be used in accordance with 

CERCLA. All CERCLA restrictions on the use of funding also apply to BCRLF funds.6 

P Eligible Applicants for BCRLF Pilots 

• States, political subdivisions (40 C.F.R. 35.6015(a)(31)), and Federally recognized Indian 

tribes. 

• Proposals from coalitions are permitted to apply (see specific requirements for Coalition 

proposals listed on page 18). 

P Eligible Borrowers 

• The cooperative agreement recipient may loan to any entity, public or private, that is authorized 

to enter into a loan agreement, can establish a legally binding agreement to repay the loan, and 

can identity a potential source of income for the repayment. 

• BCRLF pilot funds may be loaned to a party that is an owner/operator of the site only if: 

N the owner/operator would fall under a statutory exemption from CERCLA liability; or 

N EPA would use its enforcement discretion and not pursue the party in question under 

CERCLA, as described by EPA guidance (see list in Appendix A). 

N the owner/operators acquired the property after the time of disposal or placement of 

hazardous substances and the lead agency determines that the owner/operator has not 

caused, contributed to, permitted, or exacerbated the release of a hazardous substance on, 

or emanating from that property. 

6 The BCRLF demonstration pilot program is funded under §104(d)(1) of the Comprehensive 

Environmental Response, Compensation, and Liability Act of 1980, as amended (CERCLA). Regulations 

applicable to this program include 40 C.F.R. Part 31 (Uniform Administration Requirements for Grants 

and Cooperative Agreements to State and Local Governments), 40 C.F.R. Part 35, Subpart O 

(Cooperative Agreements for Superfund Response Actions), and 40 C.F.R. Part 300 (The National Oil 

and Hazardous Substances Pollution Contingency Plan). 

17 
• BCRLF pilot funds may NOT be loaned to a party that is a generator or transporter of 

contamination at the site for which that party is requesting funds. 

• BCRLF funds may not be loaned to a party that is suspended, debarred, or otherwise ineligible 

to participate in Federal financial assistance programs. 

Determinations regarding borrower eligibility made by the lead agency do not, however, 

limit the authority of the Federal or state government. 

P Eligible Properties and Activities 

• Use of BCRLF pilot funds is limited to brownfields sites, within the eligible entities jurisdiction, 

that have been determined to have an actual release or substantial threat of a release of a 

hazardous substance. Funds may also be used at sites with a release or substantial threat of 

release of a pollutant or contaminant which may present an imminent and substantial danger to 

the public health or welfare. 

• BCRLF pilot funds may NOT be used for activities at any sites: 1) listed (or proposed for 

listing) on the National Priorities List; 2) at which a removal action must be taken within six 

months; or 3) where a federal or state agency is planning or conducting a response or 

enforcement action (including sites that are the subject of a unilateral administrative order, a 

court order, and administrative order on consent or judicial consent decree). 

• Coalition funding is premised on an award of no more than $1,000,000 per eligible entity. 

Loan funds must be directed to properties located within the jurisdictions of the eligible entities 

comprising the coalition. A preference shall be given in the first round of lending to a loan to 

each individual entity of the coalition. Subsequent lending to coalition members may be based 

upon project need after the first round of lending has occurred. See also “Special 

Requirements for Coalitions.” 

Eligible Activities 

• A BCRLF pilot (cooperative agreement recipient) must use at least 70 % of the funds provided 

to capitalize its clean up loan fund. EPA will award up to 20% of the cooperative agreement 

funds as direct financial assistance to the cooperative agreement recipient to carry out its 

clean up responsibilities as “lead agency” when used in combination with a specific loan. The 

remaining 10% of the cooperative agreement may be used for the cooperative agreement 

recipients’ general administrative costs. 

• BCRLF activities must be removals, as defined in CERCLA §101(23). The NCP at 40 C.F.R. 

§300.415 describes some examples of removal actions. 

18
P

• BCRLF cleanups must meet the NCP requirements identified for non-time critical removal 

actions -- i.e., removal actions for which a planning period of at least 6-months exists. These 

requirements are identified primarily in 40 C.F.R. §§300.415 and 300.800. Pilot funds may be 

used for costs associated with meeting any of these requirements, including the requirement to 

conduct engineering evaluation and cost analysis of cleanup alternatives and all public 

participation requirements. 

• BCRLF pilot loan funds may be used for site monitoring activities that are necessary during the 

cleanup process (e.g., site sampling for cleanup verification). 

• BCRLF pilot funds may NOT be used to conduct environmental response activities preliminary 

to cleanup, such as site assessment, site identification, and site characterization. 

• BCRLF pilot funds may NOT be used to clean up products that are part of the building 

structure and result in exposure within residential buildings or business or community structures 

(e.g., interior lead-based paint contamination or asbestos which results in indoor exposure). 

• BCRLF pilot funds may NOT be used for cleanup of petroleum products, unless they are 

believed to be co-mingled with a hazardous substance, pollutant, or contaminant (e.g., used oil). 

CERCLA expressly excludes petroleum from the definition of hazardous substances. 

• BCRLF pilot funds may NOT be used for development activities that are not removal actions 

(e.g., construction of a new facility or marketing of property). 

P Special Requirements for Coalitions Proposals 

• A single entity must be identified as the applicant. 

• A letter of agreement, from each coalition member, must be included as an attachment. 

• Only one award will be considered per eligible entity within the coalition, i.e. a political 

subdivision would only be eligible for up to $1,000,000. 

• Coalition financial assistance is premised on an award of no more than $1,000,000 per eligible 

entity of which a BCRLF pilot (cooperative agreement recipient) must use at least 70 % of the 

funds provided to capitalize its clean up loan fund. EPA will award up to 20% of the 

cooperative agreement funds as direct financial assistance to the cooperative agreement 

recipient to carry out its clean up responsibilities as “lead agency” when used in combination 

with a specific loan. The remaining 10% of the cooperative agreement may be used for the 

cooperative agreement recipients’ general administrative costs. The 20% direct financial 

assistance may only be used in combination with a loan. 

19
P

• Loan funds must be directed to properties located within the jurisdictions of the eligible entities 

comprising the coalition. 

• A preference shall be given in the first round of lending to a loan to each individual entity of the 

coalition. Subsequent lending to coalition members may be based upon project need after the 

first round of lending has occurred. Each coalition member must consent to a loan(s) to other 

coalition entities when the amount of the loan exceeds the proportionate share for each coalition 

member. 

• Costs (including costs covered by loan funds and direct financial assistance) associated with a 

particular cleanup may not exceed $2 million. (CERCLA §104(c)(1)). 

• An existing coalition (a coalition already having been selected to receive a BCRLF pilot), may 

apply on behalf of a new entity seeking to join the existing coalition. The entity seeking entry 

into the coalition must otherwise meet the eligibility requirements, i.e., be a State, political 

subdivision, or Indian tribe that has established and can demonstrate the progress already made 

in the assessment, cleanup and revitalization of brownfields in the community, State or Tribe. 

• Existing coalitions making proposals under this guidance on behalf of new entities shall provide 

a written affirmative statement that members of the existing coalition (chief executive of the 

coalition entity, e.g., the mayor or county executive) have agreed to admission of additional 

entities to the coalition. 7 

P Other Restrictions 

• BCRLF pilot funds may NOT be used for job training. Support for job training activities may 

be available through the Hazardous Material Training and Research Institute, EPA programs, 

other Federal agency programs, and state and local programs. 

• BCRLF pilot funds may NOT be used to support “lobbying” efforts of the cooperative 

agreement recipient (e.g., lobbying members of Congress or State legislatures, or lobbying for 

other Federal grants, cooperative agreements, or contracts). 

• The cooperative agreement recipient cannot use BCRLF pilot funds to match any other Federal 

funds without specific statutory authority. (However, the borrower may use BCRLF loan 

funds to match other federal funds if the use of BCRLF funds is in accordance with 

all other BCRLF requirements and the requirements of the other federal agency.) 

7 EPA strongly recommends that coalitions establish agreements addressing membership 

responsibilities and operating procedures to ensure the efficient functioning of a coalition, particularly if 

the coalition is made up of more than 2 or more members and that such agreements be in place prior to 

approval of cooperative agreement. 

20 
• The cooperative agreement recipient is responsible for complying with all applicable Federal 

requirements that are applicable to the BCRLF by operation of statutes, executive orders, and 

regulations, in addition to CERCLA requirements (e.g., The Davis Bacon Act, 40 U.S.C. 

§276a et seq. applies to all construction, repair, or alteration projects funded entirely, or in 

part, with CERCLA funds.) 

• The cooperative agreement recipient must provide evidence that it is making significant progress 

toward loaning the amount available under this agreement through its quarterly reports. If the 

loan funds are not used by the end of this agreement, and the term is not extended by EPA, the 

funds will be withdrawn. 

21
The Proposal Package 

Structure of the Proposal 

Proposals for BCRLF pilots should include the following: 

! Cover Page (1 page)

! Proposal Overview (1-2 pages)

! Budget (1 page)

! Responses to Threshold Criteria -- Section A and B (up to 5 pages)

! Responses to Evaluation Criteria -- Sections C- F (up to 9 pages)

! Attachments (as appropriate; please provide an index)

! Coalition proposals may exceed page limits, as needed. Coalitions should pay particular

attention to Evaluation Criteria “C1" and “C2" in preparing their proposals. 

Attachments should be kept to a minimum. Attachments that will be considered during proposal 

evaluation include maps and letters of certification and commitment, support, or partnership from other 

government or private entities. Examples of attachments that will not be considered during proposal 

evaluation include strategies or plans developed for other programs, advertising brochures, newspaper 

articles, resolutions, statutes, and videotapes. Information in these types of attachments should be 

distilled and incorporated into the responses to criteria. 

To ensure fair and equitable evaluation of the proposals, please do not exceed the above, 

single-sided page limitations. In addition, all materials included in the proposal (including maps and 

other attachments) must be printed on letter-sized paper (81⁄2" by 11") and font sizes may be no 

smaller than 11 points. 

Applicants should clearly mark information they consider confidential. EPA will make final 

confidentiality decisions in accordance with Agency regulations at 40 C.F.R. Part 2, Subpart B. 

Please submit two copies of your proposal materials, including attachments. 

should be submitted directlyto EPA Headquarters and the other copy should be submitted to the 

appropriate EPA Regional BCRLF Coordinator. (See page 39 for mailing directions). 

One copy 

22
Cover Page 

This is intended to identify the BCRLF Demonstration Pilot applicant and a point of contact for 

communication with EPA. This should be on a single page and in the format of your choice. 

1. Proposal title: this should be as specific as possible. 

2. Location: city, county, and state of the pilot area. 

• For a coalition proposal, please list the relevant information for EACH eligible entity, 

with the lead member identified. 

3. Scope and population of the pilot area. 

• For a coalition proposal, please list relevant information for EACH eligible entity. 

4. Applicant identification: the name of the proposed cooperative agreement recipient (e.g., state 

or local agency). 

• For a coalition proposal, the entity named here will be considered the cooperative 

agreement recipient. 

5. Proposal director: the name of the person who is responsible for the proposal. We will contact 

this person if we need further information. 

6. Mailing address of the proposal director. 

7. Telephone/Fax/E-mail of the proposal director. 

8. Name of the chief executive of the applicant (e.g., Governor, Mayor, County Executive, Tribal 

President, etc.), if different from the proposal director. 

• For a coalition proposal, please list the chief executive of EACH entity. 

9. Mailing address of the chief executive, if different from the proposal director. 

• For a coalition proposal, please provide the mailing address of the chief executive for 

EACH eligible entity. 

10. Telephone/Fax/E-mail of the chief executive, if different from the proposal director. 

23
• For a coalition proposal, please provide the Telephone/Fax/E-mail of the chief 

executive for EACH eligible entity. 

11. Identification as to whether an eligible entity(ies) is designated as a Federal Empowerment 

Zone(EZ)/Enterprise Community(EC). 

• For a coalition proposal, please identify the Federal EZ/EC for EACH eligible entity, if 

applicable. 

12. Date submitted: the date when the proposal is postmarked by the U.S. Postal Service or sent 

to EPA via registered or tracked mail. 

13. Pilot period: the cooperative agreement recipient generally has three years from the 

cooperative agreement start date to obligate (enter into loan agreements) all funds awarded. 

Final payment, disbursement of award funds, and close out must be complete within 5 years of 

award date. This will be determined by the applicant’s projected implementation schedule for 

the initial round of lending to be described in “Criteria D.1: “Describe Your Proposed BCRLF 

Pilot Financial Plan” (See page 31). 

14. Community background: demographic statistics on minority, unemployment, and poverty rates 

or other statistics that demonstrate distress in the pilot area. 

• For a coalition proposal, please provide the relevant demographic statistics for EACH 

eligible entity. 

15. Please classify whether the pilot area is urban, suburban, or rural. 

• For a coalition proposal, please provide the relevant information for EACH eligible 

entity. 

16. Cooperative partners: provide a list of the individuals and organizations that have agreed to 

participate in the implementation of the pilot without charge. 

24
Proposal Overview 

The Proposal Overview is an important opportunity to briefly summarize the overall goals and 

objectives of the proposed pilot. Some of the information you provide in the Proposal Overview will 

overlap with the evaluation criteria. 

Provide an overview of the following topics: 

• Overall brownfields goals and objectives. 

• How capitalization of a BCRLF will help advance your goals and objectives. 

• How the EPA cooperative agreement funds will be used (e.g., administration, loans, and 

financing). 

• For a coalition proposal, please list the relevant information for EACH eligible entity. 

25
Budget 

Provide a potential budget for your proposal. This should show the distribution of the BCRLF pilot 

financial assistance, including the portion of funds to be used to capitalize the revolving loan fund (at 

least 70%), the direct financial assistance portion of the funds (up to 20%); and the portion of the funds 

(up to 10% of the total award) for administrative costs, legal fees, and professional services. A clear 

and concise budget is a critical element of the proposal package. 

For coalition proposals, the budget should clearly identify how the funds will be distributed 

among each coalition member. No one member may receive more than a $1,000,000 allotment. 

PROPOSAL TASKS 

Budget 

Categories 

Task 1 Task 2 Task 3 Task 4 TOTAL 

Administrative 

Expenses 

Personnel 

Fringe Benefits 

Travel 

Equipment 

Supplies 

Contractual 

Other 

Subtotal: *can not exceed 

$100,000 on 

$1,000,000 award 

Loan 

Capitalization 

Subtotal: 

* at least $700,000 

on $1,000,000 award 

26
PROPOSAL TASKS 

Budget 

Categories 

Task 1 Task 2 Task 3 Task 4 TOTAL 

Direct 

Financial 

Assistance to 

support Lead 

Agency funding 

Subtotal: 

* may be up to 

$200,000 used only 

in combination with 

loans made 

TOTAL 

Threshold Criteria (Sections A and B) 

This section addresses the threshold criteria, i.e., the minimum criteria, an applicant must 

demonstrate to assure U.S. EPA it has the ability to implement a BCRLF pilot. Applicants must meet 

the threshold criteria, i.e.,demonstrate an existing commitment to brownfields, and demonstrate an 

ability to manage a revolving loan fund and environmental cleanup, to be selected for a BCRLF 

Demonstration Pilot. All threshold criteria are equally important. The Agency may seek further 

clarification of threshold responses, if necessary, during the selection review process. 

A. Existing Local Commitment to Brownfields 

Any state, Indian Tribe, or political subdivision with an established brownfields program may apply 

for a BCRLF cooperative agreement. 

Describe the progress that your community has made in the assessment, cleanup, and revitalization 

of brownfields. Include in your description any sites in your community that have been identified, 

characterized, or assessed as brownfields sites, including those sites identified, characterized, or 

assessed under a previously awarded EPA Assessment Demonstration pilot or a targeted brownfields 

assessment. 

Coalitions should pay particular attention to the presentation of information in this portion 

of the proposal to ensure information on EACH coalition member is provided. 

B. Ability to Manage a Revolving Loan Fund and Environmental Cleanups 

The proposed cooperative agreement recipient will carry out two primary functions: 1) lead agency 

responsible for managing environmental cleanups; and 2) be responsible to EPA for fund management, 

for the purposes of directing and administering the BCRLF pilot. 

27
B.1. Demonstrate That You Have an Effective Institutional Structure in Place or 

Planned 

(a). Please identify: 

(1) the entity that will be lead agency (reminder: cooperative agreement 

recipient = lead agency), including the government employee that will be the 

lead agency’s brownfields site manager; and 

(2) the types of entities that may act as fund manager8. 

If, at this time, the applicant is unable to identify the government employee who will act as the 

Brownfields Site Manager or the entity that will act as Fund Manager, describe your plan for selecting 

the Brownfields Site Manager or Fund Manager. 

(b). Lead Agency 

(1) Provide background information on the institution and staff comprising the 

Lead Agency (reminder: cooperative agreement recipient = lead agency). This 

background information should describe the experience and qualifications the applicant has to 

act as Lead Agency or describe how the applicant intends to acquire this expertise. (Please 

note, a cooperative agreement recipient/lead agency may enlist the services of other entities that 

have experience with overseeing and carrying out environmental response actions to help the 

cooperative agreement recipient fulfill its lead agency responsibilities. The cooperative 

agreement recipient may NOT, however, designate another entity to act as the lead agency.) 

Your description of lead agency experience and qualifications should be based 

on the responsibilities described on page 14 and must include a demonstration that the 

proposed Lead Agency has, or has access to, the following: 

(a) Expertise in conducting or overseeing environmental response 

actions carried out in accordance with federal and state requirements and, in particular, 

experience with, or knowledge of, the non-time critical removal requirements in the 

National Contingency Plan (40 C.F.R. § 300.415); and 

(b) Sufficient record-keeping expertise to ensure that the use of 

BCRLF funds (by the Cooperative Agreement recipient and by the borrower) is tracked, 

recorded, and reported to EPA. 

8 Recipients who intend to contract with an entity to perform fund manager services must comply 

with competitive procurement procedures as required by 40 CFR Part 35, Subpart O. 

28 
(2) Provide specific information, including experience and qualifications, on the 

government employee proposed to be your Brownfields Site Manager.9 Your description of 

your brownfields site manager’s experience and qualifications must include a demonstration that 

the employee identified to serve this function has, or will have, the following: 

(a) Experience with on-site coordination, direction, and review of 

environmental response activities; and 

(b) Experience with, or knowledge of, the non-time critical removal 

requirements in the National Contingency Plan (40 C.F.R. § 300.415). 

(3) Provide information on any past or pending legal actions against the 

institutions or individuals comprising the Lead Agency (including the brownfields site manager) 

relating to public and commercial financial and environmental matters, how those actions were 

resolved, and whether any are currently suspended, debarred, or otherwise ineligible to receive 

federal funding. 

(4) If the proposed Cooperative Agreement Recipient plans to enlist the 

services10 of other entities to assist in carrying out Lead Agency responsibilities, describe the 

relationship between the potential Lead Agency and these institutions and the type of agreement 

(e.g., intergovernmental agreement, or contract) that is planned. 

(5)If the proposed Cooperative Agreement Recipient plans to enlist the 

services of a government employee to act as the Brownfields Site Manager who is not an 

employee of the Cooperative Agreement Recipient (e.g., the Brownfields Site Manager is an 

employee of the State or Federal government that will work under the direction of a political 

subdivision lead agency), describe the relationship between the proposed Cooperative 

Agreement Recipient and the proposed Brownfields Site Manager. 

(6) If the proposal is from a coalition, please describe how the proposed 

Cooperative Agreement recipient will implement its lead agency responsibilities with respect to 

the coalition, for example, how the lead agency would ensure that environmental response 

9 Options are available for the selection of a BCRLF Site Manager. (See, policy clarification 

memorandum dated July 10, 2000,“Clarification of Site Manager (On-Scene Coordinator Role)”, 

etc.) See footnote 6 page 14. 

10 Intergovernmental agreements may be used for transactions between governmental units. 

Contracts with vendors of services and produces must be entered into under procedures that are 

consistent with the procurement procedures found in 40 C.F.R. Part 35, Subpart O. Note: a lead agency 

may NOT designate another entity nor may it subgrant to another entity the authority to act as the 

lead agency. 

29 
requirements are met at sites where it does not typically assert jurisdiction (i.e., sites located in 

other member’s political boundaries). 

Note: Political subdivision applicants who are selected to receive BCRLF funds must 

obtain written agreement from the State that the political subdivision may assume lead 

agency responsibility for removal activities at any site or sites addressed with BCRLF funds. 

This should be submitted with the formal cooperative agreement application package in the 

form of a letter from the State. 

should consult with the U.S. EPA Regional BCRLF Coordinator (see page 40) if they expect 

they will be unable to obtain this letter in time to submit it with the formal cooperative 

agreement application package. 

Applicants who are selected to receive BCRLF funding 

(c). Fund Manager 

(1) If the proposed Cooperative Agreement Recipient plans to enlist the 

services of other institutions or individuals to act as the Fund Manager, describe the relationship 

between the potential Cooperative Agreement Recipient and the institution or individual and the 

type of agreement (e.g., intergovernmental agreement, contract, or subgrant) that is planned.11 

(2) Provide information on the qualifications of institutions and staff the 

applicant intends to have act as Fund Manager.12 Typical information should include: 

11 Intergovernmental agreements may be used for transactions between governmental units. Any 

subgrants must be consistent with 40 C.F.R. §31.37 and with the distinction between subrecipients 

and vendors made in OMB circular A-133. Contracts with vendors of services and produces must be 

entered into under procedures that are consistent with the procurement procedures found in 40 C.F.R. 

Part 35, Subpart O. Note: The cooperative agreement recipient may subgrant to a Fund Manager. 

12 To reduce their administrative costs, cooperative agreement recipients are permitted to 

designate third parties to serve as the fund manager. Should an applicant choose to (1) coordinate the 

administration of the BCRLF pilot with other existing revolving loan funds (e.g., EDA, others); (2) enter 

into agreements with the state to administer the BCRLF pilot funds; or (3) coordinate the administration of 

funds with other selected BCRLF cooperative agreement recipients, the applicant must ensure that 

BCRLF pilot funds are used only for authorized purposes. 

The cooperative agreement recipient will be responsible for all actions of the fund manager. 

Therefore, should a BCRLF pilot cooperative agreement be terminated by EPA, the recipient must 

appoint a receiver to manage outstanding loans or EPA will appoint a receiver at the Agency’s discretion. 

30 
(a) Financial skills to manage the financial health of the fund; 

(b) Analytical skills to evaluate potential borrowers on both technical 

and financial criteria; 

(c) Legal skills to structure loan agreements, collateral arrangements, 

and repayment instruments; and 

(d) Recordkeeping skills to track and report on the activities of the 

BCRLF and its borrowers (e.g., number of loans, categories of borrowers, and program 

income). 

(3) For coalition proposals, please describe how the fund manager will manage 

and separately track the funds for each of the eligible entities that are part of the coalition. 

Note, that as part of its substantial involvement EPA may request information on any 

past or pending legal actions against the institution or individuals proposed to be the Fund 

Manager relating to public and commercial financial and environmental matters and how 

those actions were resolved. The institution or individual selected as fund manager must not 

be currently suspended, debarred, or otherwise ineligible to receive federal funding. 

B.2. Demonstrate Your Legal Authority to Manage BCRLF Cleanups 

Please provide a legal opinion (in the form of an attachment) from the applicant’s legal 

counsel that demonstrates the applicant’s legal authority to perform the actions necessary to manage 

environmental cleanups. This should include a demonstration of jurisdiction, as well as the authority to 

carry out the responsibilities, described previously, of the Lead Agency and Brownfields Site Manager 

(see pages 14-15). This authority may be based in statute, regulation, or other authority.13 This must 

be submitted with the proposal. 

B.3. Demonstrate Your Legal Authority to Manage a Revolving Loan Fund 

Please provide a legal opinion (in the form of an attachment) from the applicant’s legal 

counsel that demonstrates the applicant’s legal authority to perform the actions necessary to manage a 

revolving loan fund. Legal authority must include, among other things, the ability to enter into the 

cooperative agreement, hold funds, make loans, enter into loan agreements, hold collateral, charge 

13 In some cases, all authority may come from one source. For example, if the potential 

cooperative agreement recipient is a municipal government, your state may have granted broad powers to 

all municipalities that include those needed to manage a BCRLF cleanup. In some cases, however, such 

broad authority may not exist. In these cases, the legal opinion must cite specific authorities. 

31 
interest, and collect repayments. This authority may be based in statute, regulation, or other authority. 

14 This must be submitted with the proposal. 

B.4. Demonstrate the Applicant’s Status as a Political Subdivision 

Provide evidence that your entity is a political subdivision according to state law, e.g., a letter from 

you State Attorney General’s office. 

14 In some cases, all authority may come from one source. For example, if the potential 

cooperative agreement recipient is a municipal government, your state may have granted broad powers to 

all municipalities that include those needed to manage the loan administration portion of the BCRLF. In 

some cases, however, such broad authority may not exist. In these cases, the legal opinion must cite 

specific authorities. 

32 
Evaluation Criteria (Sections C-F) 

Those applicants that meet the threshold criteria will then be evaluated based on their responses 

to four evaluation criteria: (1) demonstration of need; (2) commitment to make loans and to creative 

leveraging of EPA funds; (3) benefits of BCRLF pilot loans to the local community; and (4) long-term 

benefits and sustainability. 

Your response to the following criteria will be the primary basis on which EPA determines the size 

of award. However, there is no guarantee of an award. EPA’s evaluation panel will review the 

proposals carefully and assess each response based on how well it addresses each criterion. All 

evaluation criteria are equally important. 

Responses for coalition proposals must provide sufficient detail for each of the eligible 

entities within the coalition, where applicable. 

C. Evaluation Criteria: Demonstration of Need 

C.1. Problem Statement and Unique Needs of the Community 

[Coalitions should pay particular attention to presentation of information in this portion of the proposal to 

ensure information on EACH coalition member is provided.] 

(a). Provide demographic measures that demonstrate economic distress in targeted 

municipalities and neighborhoods. Demographic measures should include population (including 

distribution of minorities), poverty rates, and unemployment rates. Other measures could include 

per capita or family income levels or other measures that demonstrate distress. 

(b). Explain the unique needs of the community, including why certain demographic 

problems are a priority. Specific goals and strategies developed to deal with problems should be 

identified. Connecting to environmental justice issues, city or county-wide strategic planning, or 

comparative risk efforts is encouraged. If specific neighborhoods or communities have been 

targeted for enhanced development, a brief description of those plans should be included in the 

proposal. 

(c). Explain interactions with other local, state, or federal economic incentive programs 

designed to increase jobs and capital investment (e.g., federal enterprise communities and 

empowerment zones, state-designated zones, tax increment financing districts, and public 

improvement districts). Any public/private investment activities associated with the demographic 

concerns should be described. 

33
C.2. Description of Potential Borrowers and Property 

[Coalitions should pay particular attention to presentation of information in this portion of the proposal to 

ensure information on each coalition member is provided. ] 

(a). Detail the types of borrowers expected to benefit from BCRLF pilot financing and 

provide general information about their financial needs. If subawards will be used in combination 

with loans to non-profit or governmental borrowers, please indicate whether you intend to include 

this feature as part of your loan program. 

(b). Explain the process for identifying and selecting prospective BCRLF borrowers 

and detail how they will be certified as qualified borrowers. Identify planned procedures for 

determining how potential borrowers requesting BCRLF pilot loans are well qualified to direct the 

proposed redevelopment and have a demonstrated record of success. 

(c). Describe specific areas that are to be included in the BCRLF pilot eligibility pool. 

Maps of eligible areas of emphasis, with clear explanations attached, should be provided. When 

possible, the proposal should provide descriptions of eligible properties. 

(d). Considering the information requested in (a), (b), and (c), provide a proposed 

BCRLF pilot implementation schedule and time line for the initial round of lending.15 (EPA strongly 

urges proposal applicants to work toward making an initial loan within 12 months of award.) 

D. Evaluation Criteria: Commitment to Making Loans and to Creative 

Leveraging of EPA Financial Assistance 

D.1. Describe Your Proposed BCRLF Pilot Financial Plan16 

Briefly outline your proposed financial plans. Provide the following: 

(a). the proposed financing structure for the program, such as planned level of fund capitalization, 

loan schedule, and administrative costs; 

15 Failure to comply with the pilot period can result in the deobligation and recovery of 

undisbursed cooperative agreement funds, at the option of EPA. 

16 Once a BCRLF pilot proposal is selected, but prior to when the cooperative agreement is 

signed, applicants will be asked to provide a more detailed financial plan demonstrating the applicant’s 

financial management capabilities. 

34 
(b). a brief description of how the BCRLF program may be operated in relationship with funding 

mechanisms other than EPA pilot funds; 

(c). a description of how BCRLF funds will be integrated into an existing redevelopment loan, 

grant, or tax incentive program, if appropriate; 

(d). if possible, identify anticipated initial loan recipients and the level of funding to be provided 

(this is not required); and 

(e). a proposed BCRLF pilot implementation schedule for the initial round of lending. 

D.2. Ability to Attract and Support Other Financing 

(a). Provide information on all other currently available or anticipated sources of funding for 

cleanup in the eligible area, including other federal, state, local, non-profit, and private funding 

sources. Proposals should demonstrate the extent to which EPA seed funding of a BCRLF pilot will 

attract other resources and be used in conjunction with those resources to maximize benefit. 

(b). Discuss how you plan to use BCRLF pilot funds to address funding gaps for cleanup of 

eligible BCRLF pilot area properties. 

(c). Describe how the BCRLF pilot program will be coordinated with other revolving loan funds 

or financing programs for environmental assessment and cleanup, if available. 

D.3. Cash and In-Kind Contributions 

While applicants are not required to match seed capitalization funds, financial participation is 

encouraged and will be taken into account in evaluating proposals. Applicants, therefore, should 

describe their intended financial contributions to capitalizing the proposed BCRLF and the sources of 

these capitalization funds. This discussion can include both direct cash contributions and access to 

relevant in-kind services. 

D.4. Efficiency of Planned Administrative Structure 

Describe the anticipated administrative framework for the BCRLF pilot and discuss how the 

planned BCRLF pilot structure will be integrated with other programs (e.g., other revolving loan fund 

programs) in a manner that minimizes administrative costs for the BCRLF pilot program. 

E. Evaluation Criteria: Benefits of BCRLF Loans to the Local Community 

E.1. Announcement and Notification of BCRLF Fund Availability 

35
(a). Describe your procedures for providing for public hearings and Notification of Funds 

Available (NOFA) when a BCRLF program is being planned and before it is implemented. 

(b). Describe the public outreach process that must be held for the initial notification of the loan 

program. If a formal public comment period is provided, and the applicant allows for no action on 

the program until the comment period is completed, details must be included in the proposal. 

Documentation of all outreach efforts must be provided to EPA upon the Agency’s request. 

(c). Describe your procedures for notifying minority business enterprises, women’s business 

enterprises, and small business enterprises located within your jurisdiction about the BCRLF 

availability. Discuss any relationship which might already exist between the proposed cooperative 

agreement recipient and these types of business enterprises. Describe any existing procedures for 

linking these enterprises with opportunities under the BCRLF and, if no procedures currently exist, 

how you might develop such procedures. (For coalition proposals, answer for each coalition member 

community.) 

E.2. Community Involvement in Future Land Reuse 

(a). Provide evidence of your community’s or communities interest in brownfields problems. 

Describe you efforts to involve community-based organizations in developing this proposal. 

(b). Describe how the proposed BCRLF pilot is community-based or how the applicant plans to 

involve the community in targeted areas of the pilot. Specifically, describe how you will involve the 

public in cleanup decisions, including decisions about future land use, for each site addressed by 

BCRLF funds. 

(c). Describe partnerships with academic associations, environmental justice groups, established 

community contacts, and organizational networks. Detail the method for including these groups in 

land reuse decisions. 

(d). Describe any standards for land-use based environmental cleanups. Include particulars on 

community involvement in the determination of the selected environmental cleanup standards. 

(e). To demonstrate significant involvement of other community organizations or local agencies, 

please provide letters of commitment from involved organizations, if available. (These letters are not 

required). 

E.3. Contribution to Community Economic Development Plans 

Cooperation among municipal, county, state, federal, and private economic development programs 

is encouraged. Please provide the following: 

36
(a). a summary of such partnerships already developed for the delivery of economic benefits to 

the impacted brownfields area; 

(b). details on how the partners cooperate for overall economic community development; and 

(c). a description of the relationship envisioned with these partners under the BCRLF pilot 

program. 

E.4. Environmental Justice Benefits 

Environmental justice seeks to rectify the disproportionately high burden of environmental pollution 

that is often borne by low income, minority, and other disadvantaged communities. 

(a). Describe how these communities have participated in the development of your brownfields 

redevelopments plans and how they will continue to participate in your Brownfields Cleanup 

Revolving Loan Fund. 

(b). Describe your plans for ensuring that affected disadvantaged populations benefit 

environmentally and economically (directly or indirectly) from the cleanup and reuse of brownfields as 

proposed in your proposal. 

(c). Describe how you plan to ensure that environmental risks to disadvantaged communities are 

not increased during cleanup and redevelopment. 

E.5 Projected Sustainable Benefits 

To evaluate the anticipated benefits of the applicant’s brownfields program when EPA funds are 

exhausted, please provide the following: 

(a). the long-range planning and budget efforts established by entity responsible for 

implementing the brownfields program; 

(b). a description of the environmental and economic benefits of the BCRLF pilot, including the 

benefits of near-term projects and the projected sustainable environmental protection and economic 

stability of the community (Projected taxes, job creation, and pollution prevention information, if 

available, should be presented.); 

(c). a description of how the BCRLF pilot will facilitate the identification of threats to the health 

or welfare of children, pregnant women, minority or low-income communities, or other sensitive 

populations; 

(d). the extent to which the BCRLF pilot will facilitate the use/reuse of existing infrastructure; 

37
(e). a description of how the BCRLF may stimulate the creation/preservation of greenspace; 

(f). a description of the intangible social benefits of the BCRLF pilot (e.g., increased 

community pride, improved perceptions that the community is a good place to live and work, and 

decreased fear of crime). 

F. Evaluation Criteria: Long-Term Benefits and Sustainability 

F.1. National Replicability 

Describe how this pilot can serve as a model for others to use in addressing barriers to revitalizing 

brownfields. (Given the complexity and local nature of the brownfields problem, no single plan will be 

suitable nationwide, but how you address specific barriers may provide lessons for others with similar 

problems.) 

F.2. Measures of Success 

Success in this demonstration pilot should be measured in terms of environmental achievement, 

revolving loan fund activity, and program strategy. 

(a). Describe your plans for measuring success in achieving your BCRLF pilot goals. 

Measures of success should be specific and linked to the goals established for your pilot. Provide 

quantifiable measures whenever possible. 

Measures of success should include: 

• environmental indicators (number of properties with cleanup activities started using BCRLF 

funds; and 

• number of properties with cleanup activities completed using BCRLF funds); and 

• economic indicators (number of BCRLF loans made, amount of BCRLF funds loaned; 

and 

• number of BCRLF loan applications received. 

Measures may also include: 

• institutionalized environmental or outreach processes or other indicators of what you would 

consider a successful brownfields program (e.g., integration of the BCRLF with other funding 

resources may also be considered as a measure of success or the leveraging of private or 

public investment). 

(b). Describe baseline measures that you have developed or plan to develop to measure 

success. If baseline measures have not been developed yet, describe how and when you plan to 

develop them. 

38
(c). Describe your plans to document your pilot’s progress and success and to make quarterly 

reports to EPA. 

39
Proposed Schedule for Awarding EPA’s 

BCRLF Demonstration Pilots 

November 15, 2001 Deadline for submission of BCRLF Pilot proposal 

December 2001 Regions conduct initial proposal evaluation and 

prioritization 

January 2002 EPA Headquarters review and selection of BCRLF 

proposals 

February 2002 Announcement of proposals selected for the FY 01 

BCRLF demonstration pilots 

September 2002 BCRLF demonstration pilot cooperative agreements 

awarded 

40
Submission/Mailing Instructions 

The BCRLF pilot proposals must be post-marked and sent to U.S. EPA 

Headquarters and EPA Regional Offices via registered or tracked mail no later than 

November 15, 2001. Please note address for submission of proposals will vary 

according to the whether a “next day” delivery service (e.g., FEDEX) is used. 

Please send to :

(IF SENDING VIA U.S. POSTAL SERVICE)

U.S. Environmental Protection Agency

Barbara Bassuener

OSWER Outreach and Special Projects Staff 

Mail Code 5105

1200 Pennsylvania Ave, N.W.

Washington, DC 20460

(IF SENDING VIA NEXT DAY DELIVERY SERVICE) 

U.S. Environmental Protection Agency

Barbara Bassuener

OSWER Outreach and Special Projects Staff 

401 M Street, S.W. (Room 385SE)

Mail Code 5105

Washington, D.C. 20460

and 

send a duplicate copy to the appropriate

U.S. EPA REGIONAL OFFICE

ATTN: BCRLF Coordinator

(see page 40 for a listing of EPA Regional Offices)

41
U.S. EPA Regional Office BCRLF Coordinators 

If you have questions regarding the proposal, you may call EPA’s Call Center at 1-800-424-9346 

or your Headquarters contact or Regional representative presented below: 

Regions States Address and Phone Number 

EPA Region 1 

Lynne Jennings 

CT, ME, MA, NH, RI, VT John F. Kennedy Federal Building 

One Congress Street 

Suite 1100 (HIO) 

Boston, MA 02203 

Phone (617) 918-1210 Fax (617) 918-1291 

EPA Region 2 

Larry D'Andrea 

NJ, NY, PR, VI 290 Broadway 

18th Floor 

New York, NY 10007 

Phone (212) 637-4314 Fax (212) 637-4360 

EPA Region 3 

Sherry Gallagher 

DE, DC, MD, PA, VA, 

WV 

1650 Arch Street 

Philadelphia, PA 19103 

Phone (215) 814-3211 Fax (215) 814-5518 

EPA Region 4 

Wanda Jennings 

AL, FL, GA, KY, MS, 

NC, SC, TN 

Atlanta Federal Center 

61 Forsyth Street 

Atlanta, GA 30303 

Phone (404) 562-8682 Fax (404) 562-8628 

EPA Region 5 

Deborah Orr 

IL, IN, MI, MN, OH, WI 77 West Jackson Boulevard (MC SE-4J) 

Chicago, IL 60604-3507 

Phone (312) 886-7576 Fax (312) 886-4071 

EPA Region 6 

Roger Hancock 

AR, LA, NM, OK, TX First Interstate Bank Tower at Fountain Pl. 

1445 Ross Avenue, Suite 1200 

Dallas, TX 75202-2733 

Phone (214) 665-6688 Fax (214) 665-6660 

EPA Region 7 

Debi Morey 

IA, KS, MO, NE 901 N. 5th Street 

Kansas City, KS 66101-2728 

Phone (913) 551-7593 Fax (913) 551-8688 

EPA Region 8 

Tom Pike 

CO, MT, ND, SD, UT, 

WY 

999 18th Street, Suite 500 (EPR) 

Denver, CO 80202-2405 

Phone (303) 312-6982 Fax (303) 312-6071 

EPA Region 9 

Jim Hanson 

AZ, CA, HI, NV, AS, GU 75 Hawthorne Street, H-1 

San Francisco, CA 94105 

Phone (415) 744-2237 Fax (415) 744-1796 

EPA Region 10 

Timothy Brincefield 

AK, ID, OR, WA 1200 Sixth Avenue 

Seattle, WA 98101 

Phone (206) 553-2100 Fax (206) 553-0124 

U.S. EPA Headquarters Contacts: Barbara Bassuener Jennifer Millett Wilbur

1200 Pennsylvania Avenue, NW 1200 Pennsylvania Avenue, NW

MC 5105 MC 5105

Washington, DC 20460 Washington, DC 20460

(202) 260-9347 (202) 260-6454

42
C

C

C

C

C

C

C

C

C

C

C

C

C

C

C

C

C

C

C

C

Appendix A. 

List of EPA Brownfields Policy and Guidance 

Note: Many of these documents can be found at the EPA Brownfields website, 

http://www.epa.gov/swerosps/bf/gdc.htm 

C Brownfields Cleanup Revolving Loan Fund Administrative Manual (May 1998) 

C Brownfields Cleanup Revolving Loan Fund Administrative Manual: Model Terms and Conditions 

(Oct. 1998) 

C Policy on the Issuance of Comfort/Status Letters (November 12, 1996) 

C Soil Screening Guidance Fact Sheet (July 1996) 

C Revised Model Comfort Letter Clarifying NPL Listing, Uncontaminated Parcel 

Identifications, and CERCLA Liability Involving Transfers of Federally-Owned Property 

(January 16, 1996) 

C Underground Storage Tank Lender Liability Rule (September 7, 1995) 

C Land Use in the CERCLA Remedy Selection Process Directive (May 25, 1995) 

C Community Reinvestment Act Regulations and Home Mortgage Disclosure (May 4, 1995) 

C Guidance on Deferral of NPL Listing Determinations While States Oversee Response Actions (May 

3, 1995) 

C Military Base Closure: Guidance on EPA Concurrence in the Identification of 

Uncontaminated Parcels Under CERCLA Section 120(h)(4) (April 19, 1994) 

C Guidance on Agreements with Prospective Purchasers of Contaminated Property 

(May 24, 1995) 

C Policy Toward Owners of Property Containing Contaminated Aquifers (May 24, 1995) 

C “Asset Conservation, Lender Liability, and Deposit Insurance Protection Act of 1996" (September 30, 

1996) 

C The Effect of Superfund on Involuntary Acquisitions of Contaminated Property by Government 

Entities (December 11, 1995) 

C Policy on CERCLA Enforcement Against Lenders and Government Entities that Acquire Property 

Involuntarily (December 11, 1995) 

C Tax Incentive Fact Sheet (August 1997) 

C Guidance on Cumulative Risk Assessment (July 3, 1997) 

C Liability and Other Guidance (April 1997) 

C Targeted Brownfield Assessment Fact Sheet (November 1998) 

C Fund Brownfields Remediation with the Clean Water State Revolving Loan Fund (October 1998) 

43
Appendix B: List of Current BCRLF Pilots 

Region 1 

Berlin, CT $ 500,000 

Bridgeport, CT $ 500,000 

Hartford, CT $ 500,000 

Naugatuck Valley River 

Communities and Danbury, CT $ 850,000 

New Milford, CT $1,000,000 

Stamford, CT $ 750,000 

Winchester, CT $ 650,000 

Lewiston, ME $ 500,000 

Orono, ME $ 750,000 

Portland, ME $ 500,000 

Boston, MA $ 500,000 

Brockton, MA $ 500,000 

Central Massachusetts 

Economic Development 

Authority $ 500,000 

Franklin Regional 

Council of Governments 

(Colrain & Greenfield, MA) $1,000,000 

Gloucester, MA $ 500,000 

Lawrence, MA $ 500,000 

Lowell, MA $ 500,000 

Lynn, MA $ 450,000 

Montachusett Regional Planning 

Commission, MA $ 500,000 

Mystic Valley Development 

Commission (Malden, Medford, 

and Everett, MA) $ 500,000 

New Bedford, MA $ 500,000 

Pioneer Valley Planning 

Commission (Springfield, 

Chicopee, Westfield, and the 

Pioneer Valley Region) $2,000,000 

Somerville, MA $ 500,000 

Taunton, MA $ 500,000 

State of New Hampshire 

(NH DES, State Planning 

Coastal Watershed, NH DRED, 

Durham, Londonderry, Nashua, 

Bradford, and Greenfield, 

and Concord) $2,450,000 

State of Rhode Island: $1,000,000 

(RI Development Corporation in 

cooperation with RI Dept. of Environmental 

Management) 

Region 2 

Essex County Improvement 

Authority, NJ $1,000,000 

Hudson, NJ $ 500,000 

Trenton, NJ $1,000,000 

Niagara County, NY 

(with Niagara Falls, NY) $1,000,000 

Yonkers, NY $ 500,000 

Region 3 

Washington, DC $ 500,000

Hagerstown, MD $ 500,000

Bucks County, PA $ 500,000

Clairton, PA $ 500,000

Duquesne, PA $ 500,000

Lehigh County, PA $ 500,000

Luzerne County, PA $ 500,000

McKeesport, PA $ 500,000

Neville Township, PA $ 500,000

Northampton County, PA $ 500,000

Philadelphia, PA $ 350,000

Richmond, VA $ 350,000

Wheeling, WV $ 500,000

State of West Virginia $1,000,000

State of Maryland (on behalf of 

Prince George’s County and Baltimore

County) $1,000,000

Region 4 

Clearwater, FL $ 500,000 

Escambia County, FL $ 500,000 

Hillsborough County, FL $ 500,000 

Jacksonville, FL $ 500,000 

South Florida Regional Planning 

Commission, FL (Miami-Dade 

County and cities of Miami and 

Ft. Lauderdale) $2,000,000 

Charlotte, NC $ 500,000 

Fayetteville, NC $ 500,000 

Raleigh, NC $1,000,000 

Winston-Salem, NC $ 500,000 

Charleston, SC $ 500,000 

Columbia, SC $ 500,000 

Cowpens, SC $ 500,000 

State of South Carolina $3,350,000 

(SC Department of Health and Environmental 

Control for Cities of Anderson and Greenville, 

Towns of Bluffton, Lyman, Johnston, and 

Ware Shoals, Abbeville, Anderson, Greenville, 

Spartanburg, Yemassee, & Kershaw Counties) 

Region 5 

Chicago, IL $ 500,000 

State of Illinois 

(IL DEP, Canton, East Moline, 

Freeport, Galva, Lacon, and 

Waukegan) $3,500,000 

Rockford, IL $ 500,000 

West Central Municipal 

Conference, IL $ 350,000 

State of Indiana $ 350,000 

Battle Creek, MI $ 500,000 

Dearborn, MI $ 500,000 

44
Detroit, MI $ 350,000 

Jackson County Brownfields 

Redevelopment Authority, MI $1,000,000 

Lansing Brownfields 

Redevelopment Authority, MI $ 500,000 

Saginaw County Brownfields 

Redevelopment Authority, MI $1,000,000 

Trenton, MI $ 500,000 

Wayne County, MI $ 500,000 

Hennepin County, MN $1,000,000 

Roseville, MN $ 500,000 

Columbus, OH $ 500,000 

Cuyahoga County 

(Cleveland), OH $ 350,000 

Hamilton, OH $ 500,000 

Lockland, OH $ 500,000 

Mansfield, OH $1,000,000 

Toledo, OH $ 500,000 

State of Ohio (on behalf of Lima 

and Cleveland) $1,500,000 

Region 6 

Gretna, LA $ 500,000 

New Orleans, LA $ 350,000 

Regional Planning Commission 

for Jefferson, Orleans, Plaquemines, 

St. Bernard, & St. Tammany 

Parishes, LA $ 500,000 

Shreveport, LA $1,000,000 

Albuquerque and $1,000,000 

Bernalillo Co., NM 

State of Oklahoma $1,000,000 

Austin, TX $ 500,000 

Ft. Worth, TX $1,000,000 

Region 7 

Cedar Rapids, IA $ 500,000 

Des Moines, IA $ 500,000 

Sioux City, IA $1,000,000 

Waterloo, IA $1,000,000 

Unified Government of $ 500,000 

Wyandotte Co. and 

Kansas City, KS 

Kansas City, MO $ 500,000 

St. Louis County, MO 

(City of Wellston, MO) $ 500,000 

Region 8 

Aurora, CO $ 500,000 

Commerce City, CO $ 500,000 

State of Colorado 

(CO Department of Public Health, 

Lakewood, Englewood, Loveland, 

Westminster, and Denver) $3,700,000 

Evanston, WY $ 500,000 

Kemmerer, WY $ 500,000 

Region 9 

State of Arizona 

(Phoenix and Tucson) $1,000,000 

Carson, CA $ 500,000 

East Palo Alto, CA $ 500,000 

Emeryville, CA $1,000,000 

Lynwood, CA $1,000,000 

Long Beach, CA $ 500,000 

Oakland, CA $ 500,000 

Sacramento, CA* $ 500,000 

Stockton, CA $ 500,000 

Las Vegas, NV $ 500,000 

State of Nevada (NV DEP and 

Mineral County) $2,000,000 

Region 10 

Portland, OR $ 500,000 

Oregon Economic and $1,500,000 

Community Development Dept.; 

City of Coos Bay; and Tri-County Metro 

State of Washington $1,500,000 

(Dept. Of Community, Trade & Economic 

Development, Dept. of Ecology, City of Tacoma, 

and City of Seattle/King County) 

45
United States 

Environmental Protection Agency 

(5101) 

Washington, DC 20460 

Official Business 

Penalty for Private Use 

$300 

46