United States Office of Solid Waste and EPA 500-R-99-003 

Environmental Emergency Response June 1999 

Protection Agency Washington, DC 20460 www.epa.gov/brownfields 

/ 

Summary Report
Additional copies of this document can be obtained from: 

U.S. Environmental Protection Agency 

Office of Solid Waste and Emergency Response 

Outreach and Special Projects Staff 

401 M St. SW (MC 5101) 

Washington, DC 20460 

Phone: 202-260-4039 

You can view or download the document at the following Internet address: 

http://www.epa.gov/brownfields 
INTRODUCTION 

In February 1998, EPA issued its “Interim Guidance for Investigating Title VI Administrative 

Complaints Challenging Permits” for public comment. This guidance is intended to assist EPA’s Office 

of Civil Rights (OCR) in processing complaints filed under Title VI of the Civil Rights Act of 1964, 

alleging discriminatory intent or effect based on race, color, or national origin resulting from the issuance 

of pollution control permits by State or local governmental agencies that receive EPA funding. 

Brownfields stakeholders asserted that the guidance would stifle redevelopment in inner-city areas 

where discriminatory effects could be alleged. In response to this criticism, EPA Administrator Carol 

Browner promised to undertake case studies of Brownfields Pilots as a first step in determining whether 

or not the guidance in fact hinders redevelopment of the nation’s brownfields. This report details the 

findings of case studies conducted at seven EPA Assessment Demonstration Pilots in January and 

February of 1999. 

Section One, Background, provides a history of the guidance and case study process, including the 

criteria used for selecting the case study Pilots and the stakeholders interviewed. Section Two, Overall 

Findings, provides a summary of the results of more than 50 interviews at the selected Pilots. Section 

Three, Findings by Question, is a cross-Pilot detailed examination of stakeholder responses to EPA’s 

case study questions. Section Four, Conclusions, provides concluding statements derived from the 

findings of the report. 

The appendices are intended to provide further background and a more detailed explanation for the 

procedures associated with the case study effort. Appendix A, Case Study Methodology, details the 

proposed timeline and procedures that were used for developing questions, conducting interviews, and 

writing the studies themselves. Appendix B, Pilot Case Studies, are the actual seven case study 

documents from each of the selected Brownfields Assessment Demonstration Pilots. 

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TABLE OF CONTENTS

I. Background ............................................................ 1

II. Overall Findings ........................................................ 5

III. Findings by Question ..................................................... 9

IV. Conclusions ........................................................... 23

APPENDICES 

Appendix A: Case Study Methodology ......................................... A-1

Appendix B: Pilot Case Studies ................................................ B-1

Camden .............................................................. B-3

Charlotte ............................................................ B-11

Chicago ............................................................. B-19

Detroit .............................................................. B-27

Lawrence ............................................................ B-35

Miami .............................................................. B-41

Miami-Dade County ................................................... B-47

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I. BACKGROUND 

In February 1998, EPA issued its “Interim Guidance for Investigating Title VI Administrative 

Complaints Challenging Permits” for public comment. This guidance is intended to assist EPA’s Office 

of Civil Rights (OCR) in processing complaints filed under Title VI of the Civil Rights Act of 1964, 

alleging discriminatory intent or effect based on race, color, or national origin resulting from the issuance 

of pollution control permits by State or local governmental agencies that receive EPA funding. The 

guidance provides a timeline and framework for the processing and investigation of complaints. 

During the 90-day public comment period, local leaders, industry representatives, and national 

organizations formally asserted that the guidance, as currently written, would stifle development in innercity areas where discriminatory effects could be alleged. There was uncertainty and fear that a 

potentially lengthy and costly Title VI investigation could deter potential developers from investment in 

these areas, stifling progress made in recent years in redeveloping brownfields, regardless of tax breaks 

in Empowerment Zones, incentives for brownfields redevelopment, and other urban revitalization 

programs. 

At the Mayors’ Forum on Title VI held in Detroit, Michigan in July 1998, EPA Administrator Carol 

Browner committed to conduct studies to determine whether the guidance proved to be a barrier to the 

redevelopment of brownfields. To test the assertions of the stakeholders and determine the relationship 

between the Title VI Guidance and brownfields activities, EPA chose to conduct case studies at six of 

its Brownfields Assessment Demonstration Pilots (a seventh case study was eventually added). These 

case studies would then be provided to the National Advisory Council for Environmental Policy and 

Technology (NACEPT) Title VI Federal Advisory Committee Act (FACA) Committee for 

consideration as it drafted the final “Guidance for Investigating Title VI Administrative Complaints 

Challenging Permits.” 

In October 1998, EPA convened a panel of brownfields stakeholders to hear their concerns and 

suggestions regarding the case study process. At this meeting, participants were presented with a draft 

case study plan that included proposed Pilot-selection criteria, a preliminary timeline, and draft case 

study questions that expanded on the four “core” case study questions developed by EPA: 

C What is happening around EPA Brownfields Pilot sites in terms of what types of 

redevelopments are planned, who is involved, and what types of cooperative efforts 

exist? 

C Does the Title VI process hinder redevelopment? 

C How and why does this occur? Describe and define the impediments. 

C Are there solutions? Lessons learned? 

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By December 1998, Camden, NJ; Charlotte, NC; Chicago, IL; Detroit, MI; Lawrence, MA; and the 

City of Miami/Miami-Dade County, FL had been chosen as the case study Pilots based on the 

previously proposed criteria: 

C Study Pool. EPA’s 227 Brownfields Assessment Demonstration Pilots. Since 106 of 

these Pilots had just been announced in the spring and summer of 1998, they would not 

have had significant redevelopment activity at the time of the study. The pool was 

narrowed to 121. 

C Information Availability. The Pilot should have a good history of meeting quarterly 

reporting requirements. This was to ensure the availability and currency of Pilot data. 

C Demographics. The racial composition, as well as the size of the municipality were 

considered in the identification process. The Pilot should have a minimum 10 percent 

minority rate to ensure the validity of any Title VI complaint. To examine a crosssection of populations, two Pilots were chosen within each of the following population 

brackets: under 100,000; 100,000 to 500,000; and over 1,000,000. 

C Sites Identified. The Pilot should have two or more locations identified for 

assessment, cleanup, and redevelopment purposes. 

C Permit Data. The Pilot should have at least one project for which some type of 

Federal and/or State environmental permit is required or which has the potential for a 

reuse that requires permitting. EPA also examined cities for permits already existing in 

the area. 

After the cities were chosen and contacted, appropriate stakeholder group representatives were 

identified. The types of stakeholder groups were determined based on their perceived ability to answer 

the core case study questions. Since the studies would examine Brownfields Assessment 

Demonstration Pilot sites, EPA determined that it would be appropriate to review existing information 

for each Pilot, create a potential list of individual stakeholders based on stated and active Pilot partners, 

and confirm this list with the Pilot contacts to capture the breadth of opinion necessary for the validity of 

the study. The types of stakeholders identified were Pilot contacts; community and environmental 

justice groups; community development corporations (CDCs) and other business associations; lenders 

and developers; environmental groups; and local, State and Federal government contacts. The Pilot 

contacts would provide the most accurate and up-to-date information on the status of brownfields 

activities and the active and inactive players. Community and environmental justice groups would 

provide input on the level and timeline of community involvement, as well as provide a context for the 

demographics of the area. CDCs and other business associations would give a balanced view of the 

business and community aspects of redevelopment and community involvement. Lenders and 

developers would provide feedback on the barriers to brownfields redevelopment, and how community 

involvement was viewed in the process. Environmental groups would provide information on whether 

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the activities and influences of “outside” groups may play a role in complaints filed. Local government 

contacts would provide an objective history of the brownfields area, including past use and 

redevelopment activities as well as activism in the area. State government contacts would provide 

information on permitting and enforcement issues. Finally, other Federal contacts would provide a nonEPA perspective on the activities and partnerships involved in the Pilot project. 

The case studies were underway by January 1999. It should be noted that the responses received in 

the course of these case studies may not be representative of all of EPA’s Brownfields Assessment 

Demonstration Pilots, and that references in this document to “Pilot” activities and experiences reflect 

only the information received from the seven case study Pilots. 

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II. OVERALL FINDINGS 

This section presents the general findings and overall themes of the seven case studies as they relate to 

the four primary questions addressed in the study effort: 

• What is happening around EPA Brownfields Pilot sites in terms of what types of 

redevelopments are planned, who is involved, and what types of cooperative efforts exist? 

• Does the Title VI process hinder redevelopment? 

• How and why does this occur? Describe and define the impediments. 

• Are there solutions? Lessons learned? 

Brownfields Pilot Redevelopment Requires Few Environmental Permits 

At all of the Pilot sites studied, redevelopment activities are either underway or planned. Sites range in 

size from less than 2,000 square feet to more than 40 acres. At three sites, the redevelopment projects 

are complete, including a stamping press operation, a plastic rack manufacturer and a construction 

company. Of the 20 targeted sites identified in the case study effort, all but three sites have at least 

tentative redevelopment plans, examples of which include concrete manufacturing, container-making, 

parking, residential, retail and office buildings, flex space and road and bridge improvements. The 

majority of sites are either planned for service or light-industrial types of reuse. Although the original 

documentation used in selecting Pilot cities for the case studies indicated that permits would likely be 

required at many of the targeted sites, the case study effort has revealed that in fact very few, if any, of 

the planned reuses (e.g., concrete manufacturing, container manufacturing) at these sites may require 

environmental permits. The low number of emissions permits required lessens the chance of formal 

Title VI complaints being an issue in the future. 

A Wide Variety of Governmental, Community and Business Stakeholders Are Involved in 

Brownfields Cleanup and Redevelopment Decision-Making Across Pilots 

At every Pilot studied, multiple municipal agencies—including environmental and economic 

development departments—are involved in Pilot activities and decision-making, as are a variety of 

community and business group stakeholders. While each Pilot had a different stakeholder mix and a 

unique approach to communicating with and educating stakeholders, each of the seven Pilots had 

formalized relationships with members of the business community, citizen groups, and local and State 

government agency representatives. In all cases, stakeholders help guide Pilot activities, although levels 

of decision-making responsibility provided to community residents vary widely. For example, in 

Charlotte, community members are voting members of the Pilot’s site-selection committee, while in 

Lawrence, community groups function more as observers since Pilot activities are being conducted in 

an almost exclusively industrial part of town. 

The most common model for community involvement and decision-making across the Pilots is a 

working or advisory group comprised of community, municipal, business, real estate, and lender 

representatives. Five of the Pilot cities studied—Charlotte, Chicago, Camden, Miami and Miami-Dade 

County (the City of Miami case study was expanded to Miami-Dade County)—used some sort of 

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public/private/community advisory or working group as their primary means for making decisions. 

Charlotte and Detroit focused on developing outreach materials and conducting outreach activities. 

Charlotte targeted community groups with materials and meetings, while Detroit produced a Pilot 

toolkit discussing the City’s brownfields and explaining to stakeholders how to get involved in Detroit's 

Pilot. In addition, the City of Lawrence’s effort is largely private-sector driven, with a Brownfields 

Advisory Committee that includes brownfields business owners, City and State representatives, and 

other large businesses making redevelopment decisions. Meetings are open to the public, but have 

been poorly attended. All Lawrence stakeholders interviewed believe this is because there are virtually 

no residential areas near the brownfields redevelopment area, and because redevelopment activities are 

transportation improvements which are much desired in the community. 

Across the board, interviewees were appreciative of the Pilots’ efforts to educate and involve 

stakeholders in Pilot activities, and acknowledged that the coordination of so many groups is a difficult 

job. At the same time, Pilot Managers, municipal employees, and both active and non-active 

community groups offered many suggestions about how to improve community involvement activities at 

their Pilot, including: providing materials in local foreign languages; soliciting involvement from and 

coordinating with State regulatory agencies; making meetings more accessible by speaking in “plain” 

English (i.e., no technological jargon) and providing a scientific interpreter when necessary; and 

maintaining contact throughout the redevelopment process. 

Brownfields Pilots Coordinate with Other Community Efforts Where Appropriate, but 

Participants Agree that More Coordination Would Be Beneficial 

Two Pilots reported coordinating their activities with other community development or revitalization 

projects. The Lawrence Pilot coordinates cleanup and redevelopment plans with the Merrimack 

Corridor Enhancement Project (MCEP). The MCEP serves an umbrella function and helps to facilitate 

and prioritize brownfields activities with two additional projects: Massachusetts Highway Department 

transportation improvements, and National Park Service Groundworks Trust open-space protection 

and planning efforts. Public planning and visioning meetings have been held jointly, and many of the 

same individuals sit on more than one of these community committees. As a result of the coordination, 

Lawrence has been able to leverage Intermodal Surface Transportation Efficiency Act (ISTEA) funding 

for three transportation projects (intersection/road improvements and a bridge) on brownfields sites. 

The Miami-Dade County Pilot is coordinating with a U.S. Department of Housing and Urban 

Development (HUD) Model City. These entities sit on each other’s working groups and share 

information across projects. Both the Pilot and Model City representatives agreed that coordination is 

beneficial, although sometimes challenging, and that more opportunities to share information and discuss 

priorities are needed. 

Title VI Issues Have Had Little Effect at Brownfields Pilots 

According to more than 50 interviews at the seven case study Pilots, Title VI concerns have not slowed 

down, blocked or otherwise negatively impacted redevelopment activities to date at these Pilots. There 

have been no Title VI complaints filed relating to any Pilot’s activities. While in-depth information was 

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only gathered at seven of more than 200 active Pilots, these Pilots were chosen for their high potential 

for Title VI complaints (e.g., double digit minority rates, active redevelopment and relatively high rate of 

existing permits). It is logical to assume that if Title VI complaints were not negatively impacting 

progress at sites chosen for their high likelihood of conflict, remaining sites are not likely to be more 

impacted than those in this study. 

Fear of Title VI Complaints Does Not Appear to Discourage Developers at Brownfields Sites 

To begin to understand whether fear of Title VI complaints was having a “chilling effect” on developers 

and investors, causing them to shy away from considering brownfields properties at these seven Pilots, 

case study participants were asked what the major barriers were to conducting redevelopment 

projects. Neither Title VI nor fear of environmental justice complaints were mentioned as obstacles. 

As has been borne out in a recent HUD/EPA study titled The Effects of Environmental Hazards and 

Regulations on Urban Redevelopment, such issues as financing, construction season, and cleanup 

costs were mentioned as driving forces. Delays in cleanup and redevelopment activities suffered at 

these seven Pilots were not related to Title VI or community involvement issues, but were caused by 

waiting for liability protection agreements from States, jurisdictional and ownership uncertainties, and 

prohibitive cleanup costs. Two interviewees did mention that anything that has a capacity to delay a 

project (including Title VI complaints) could have a chilling effect on redevelopment activity. While it is 

impossible to say whether fear of Title VI complaints is creating hesitation in developers across the 

country or those not experienced in brownfields redevelopment, the interviewees at the seven case 

study Pilots felt that it was neither a driving nor impeding force in their redevelopment decisions or 

activities. 

Lack of Title VI Complaints Is More Impressive in Context of Environmental Justice Activism 

The lack of Title VI complaints at these Pilots should not be construed as apathy or lack of 

understanding of EPA’s Title VI Interim Guidance on the part of local environmental justice or 

community groups or activists. In four of the Pilot cities (Chicago, Camden, Miami-Dade and 

Lawrence), significant environmental justice activism and protests are a major concern of stakeholders 

in the Pilot communities. In Chicago, two Title VI complaints have been filed by community groups 

against incinerators in nearby South Cook County. In Lawrence, an organized environmental justice 

group has managed to shut down two incinerators, one of which was a medical waste incinerator 

located in the poorest part of the City. Participants in the Miami-Dade Pilot are aware of a very 

contentious Title VI complaint ongoing in Broward County, Florida and have had to work especially 

hard to build trust with stakeholders affected by those events. In Camden, a class action lawsuit has 

been filed against the New Jersey Department of Environmental Protection for disparate impact related 

to a sewage treatment plant. Furthermore, active and contentious enforcement and land use issues also 

serve as a backdrop for brownfields activities in the two of the Pilots. For example, the southwest 

Detroit community recently fought a request by Allied Signal to renew an EPA permit to dispose of 

waste in underground injection wells. 

Environmental justice and community groups at these Pilots state that they are focusing their limited 

resources on what they view as pressing problems, such as more traditional “dirty” industries like 

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incinerators and sewage treatment plants. It should be noted, however, that this sophisticated education 

in environmental justice and understanding of the Title VI Interim Guidance could potentially slow down 

or block actions in the future if community involvement and decision-making methods break down, or if 

a group feels a proposed end use is unacceptable. In fact, one interviewee observed that, “When 

[community] groups don't feel like they have gotten their fair share of the benefits, one way to remedy 

that is to stir up community activism about the environmental contamination of the site.” Examples such 

as these show that community and environmental justice groups are aware of the rights afforded them 

under Title VI, and have used them effectively, but that none feel that current brownfields-related 

activities warrant a complaint. 

Lessons Learned—Reasons Cited for Lack of Title VI and Environmental Justice Complaints 

When interviewees were asked that if there had been an issue relating to environmental permits and 

environmental justice, did they think the Pilot’s stakeholder involvement efforts would be adequate to 

resolve a problem, the predominant answer was “yes.” Answers fell into three major categories: 1) a 

relationship of trust has been developed among stakeholders, municipalities and developers; 2) almost 

any development is an improvement over conditions of contamination and blight, especially if it includes 

jobs for local community residents; and 3) the types of redevelopment activities typically undertaken at 

brownfields sites are not pollution-heavy or permit-intensive. 

Trust has been developed in a variety of ways at the studied Pilot cities. In Miami, the local developer 

went to the affected community and discussed new cement-making processes, which allayed fears of 

pollution in the community. In Camden and Chicago, involving the community allowed potential 

problems to be identified and solved from the beginning when stakes were lower and design changes 

could more easily be made. Charlotte representatives noted that the trust built between the community 

and the developer and the fact that involvement continued throughout the project gave community 

organizations a sense of ownership in the project and prevented opposition. 

Another important component in reducing Title VI and other opposition to redevelopment projects is 

the fact that brownfields areas tend to be abandoned, polluted or otherwise blighted areas, thereby 

making redevelopment projects all the more welcome to neighboring, usually low-income communities. 

For example, in Miami, it is believed by stakeholders interviewed that no complaints will be filed on the 

new cement plant because the plant will be so large an improvement over the current blight, crime and 

unemployment. Job creation is a big component of these improvements, and community satisfaction 

was mentioned by representatives of five of the seven Pilots as driving factors in community reaction to 

proposed developments. For example, in Camden, job creation for local residents at the Liberty 

Concrete factory played a key role in turning community opposition to approval. 

Finally, as previously discussed, a majority of the redevelopment activity at the sites is not of the type 

likely to cause an environmental justice complaint, as this activity is not the type to require environmental 

permits. 

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III. FINDINGS BY QUESTION 

This section presents a detailed examination of stakeholder responses to EPA’s case study questions. 

These questions are: 

C Have cleanup and redevelopment been done/completed? Was cleanup or 

redevelopment slowed or blocked and why? 

C Describe the stakeholder involvement at the Pilot site. Do stakeholders feel they were 

involved in decision-making? Are the community and the developer working together? 

C What types of permitting issues (e.g., RCRA, CAA) exist at these sites and how has the 

community reacted to the issues? Does the public, through the State permitting process 

or other mechanisms, have an opportunity to affect the process or provide input into the 

decision-making? 

C Since no Title VI complaints were filed relating to any Pilot activities, what were the 

factors present which ensured there would be no complaints? 

C How is the municipality’s environmental office working with its redevelopment office? 

What other working relationships are in place in the Pilot municipality (such as with the 

local civil rights office)? 

C Has the presence of nearby Title VI complaints or environmental justice concerns 

influenced the level of community environmental justice activity? What is the effect of 

these activities on communities and the local economy? 

C Was alternative dispute resolution used or considered at any of the Pilots? If so, was it 

effective in preventing Title VI complaints? 

C Are there examples or models of how Pilots can ensure sustained, meaningful 

community involvement? 

C How can the findings of this study be applied beyond Brownfields activities? 

Findings from across the case study Pilots are presented in this section, and specific stakeholder 

responses illustrate these findings. 

1. Have cleanup and redevelopment been done/completed? Was cleanup or redevelopment 

slowed or blocked and why? 

Cleanup and redevelopment efforts are underway at most of the Pilot sites. Redevelopment of three 

sites is complete. Cleanup activities at several sites was delayed by liability or ownership issues. 

Collectively, the seven Pilots have focused on 20 distinct sites ranging from 1,920 square feet (Thomas 

Construction Site in Charlotte) to more than 40 acres (Knox Gelatin in Camden), with multiple parcels 

requiring assessment and cleanup. All but three of the sites have entirely completed the necessary 

Phase I and/or Phase II environmental assessments. Two of the remaining three’s assessment 

processes are nearly complete, but are suffering delay due to jurisdictional and ownership issues. On 

three of the twenty sites assessed to date, no significant contamination was found and redevelopment 

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activities have progressed without the need for cleanup, while others have estimates of cleanup costs as 

high as $18 million. Examples of contaminants that were found at these sites include petroleum 

hydrocarbons, lead, construction debris, polychlorinated biphenyls (PCBs), treated wood, industrial 

chemicals and diesel fuel. 

Cleanup has been completed or is ongoing at 14 of the targeted sites identified in the case study effort. 

Three sites in Charlotte suffered delays where cleanup or redevelopment activities were postponed 

pending liability protection agreements under North Carolina’s new brownfields law. At both the ABC 

Barrel site in Camden and the Detroit Coke site, State-sponsored cleanup activities at the sites were 

halted when previous owners redeemed the properties by paying back taxes, creating ownership and 

jurisdictional uncertainty regarding who would pay for cleanup. Finally, the intended developer at the 

76th and Albany site in Chicago has not moved forward with plans for a container-making plant due to 

the prohibitively expensive cleanup estimate ($18 million). The developer is investigating additional 

sources of cleanup funding. 

Redevelopment activities are complete at three of the sites. The Burnside Steel Foundry site in Chicago 

is now home to an expanded stamping press manufacturer that created 100 new jobs for local 

residents. A plastic rack manufacturer (Perstorp Xytec) opened its doors in Detroit in the summer of 

1997, creating 30 new jobs with the potential for 70 more. Thomas Construction renovated a building 

in Charlotte for its operations, and construction for a variety of retail and design-related businesses is 

underway. Finally, all but three sites have at least tentative redevelopment plans, examples of which 

include concrete manufacturing, black cable television, container-making, parking, residential, 

administrative offices and flex space and road and bridge improvements. 

2. Describe the stakeholder involvement at the Pilot site. Do stakeholders feel they were 

involved in decision-making? Are the community and the developer working together? 

Stakeholder involvement approaches are as individual as the Pilots themselves. The level of community 

involvement ranges from the experience in the City of Lawrence—where the “effort is largely privatesector driven,” with little direct citizen involvement as there are virtually no residential areas near the 

redevelopment area—to the City of Charlotte, which received awards for its outreach materials and 

approach. 

Community groups/residents and developers are working together in some interesting ways across the 

Pilot cities. For example, in Chicago, Charlotte and Detroit, interviewees mentioned that it was 

common practice for developers to solicit support from community members before they invested in a 

redevelopment project or redevelopment planning. These “up-front dialogues” saved time and money 

for the developers and got the community in on the ground floor. In Miami, the Pilot brought in a 

toxicologist to explain to concerned citizens the likely emissions from a new type of cement processing. 

In the Camden Square project in Charlotte, developer Tony Pressley lowered the height of some of his 

planned buildings to address community concerns about light and tree health. Great trust has been 

achieved here and, in turn, community groups wrote letters of support for Pressley, allowing him to get 

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a State brownfields liability protection agreement. 

In some cases, Pilot managers and cities often thought that they were doing a better job of involving the 

community than the community representatives did. Although community representatives were generally 

pleased with the Pilots’ efforts—if not always the results—some explained that even though they were 

involved, business interests or other more powerful groups still held more decision-making power. 

Other community representatives felt that they should have been brought in earlier in the process, and 

still others expressed that cultural or language barriers prevented full participation from some community 

groups. 

Three Pilots used a type of working group or forum to exchange information and make site-selection 

and redevelopment decisions. Miami/Miami-Dade and Lawrence have Brownfields Working Groups 

with representatives from the business communities, neighborhoods and local governments. Holding 

meetings in the evenings, videotaping meetings, and assigning a liaison to local communities were all 

strategies used to increase community involvement. The Chicago Pilot conducted an evaluation of the 

City’s Brownfields Forum, which operated in 1994 and 1995 and involved more than 130 people from 

businesses, banks, lenders and government agencies. Through three public hearings and dozens of 

committee meetings, the Forum developed more than 65 recommendations that influenced regional 

planning efforts and increased community access to brownfields decision-making. 

Charlotte and Detroit primarily focused on creating outreach materials and conducting outreach 

activities. Charlotte involved community groups early by inviting them to assist with the Brownfields 

application. The City received an award by the National City/County Marketing Communications 

Association for their door hangers, mailings and flyers. Detroit focused its effort on creating a Pilot 

toolkit and video targeted to business and community stakeholders interested in brownfields cleanup 

and redevelopment. 

Although the City of Lawrence has a Brownfields Working Group, the City’s effort is largely privatesector driven, with a Brownfields Advisory Committee that includes brownfields business owners, City 

and State representatives, and other large businesses making redevelopment decisions. Meetings are 

open to the public, but have been poorly attended. All Lawrence stakeholders interviewed believe this 

is because there are virtually no residential areas near the brownfields redevelopment area, and because 

the redevelopment activities are transportation improvements which are much desired in the community. 

3. What types of permitting issues (e.g, RCRA, CAA) exist at these sites and how has the 

community reacted to the issues? Does the public, through the State permitting process or 

other mechanisms, have an opportunity to affect the process or provide input into the decision 

making? 

The following examples largely indicate that communities are interested and involved in permitting issues 

in their communities, and are carefully looking at trade-offs between potential environmental issues and 

other community goals such as revitalization and job creation. 

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The types of redevelopment activities currently underway or planned at the Brownfields Pilots 

comprising the case studies generally fall in the category of activities that will not require Federal or 

State emissions permits, such as retail shops, transportation improvements, parking, television 

networks, storage, and administrative buildings (see table below for complete list of types of planned 

redevelopment activities at the case study Pilots). For the few planned developments where it is 

anticipated that permits will be required—such as a container manufacturer in Chicago, and cement 

plants (air and water permits) in Miami and Camden—all interviewees stated that they did not expect 

controversy over the permits to be an issue. 

TYPES OF REDEVELOPMENT PROJECTS 

UNDERWAY OR PLANNED AT CASE STUDY BROWNFIELDS SITES

construction company retail shops restaurants 

architectural offices graphics production interior decorating 

administrative offices flex space concrete manufacturing 

parking spaces residential supermarket/food bank 

tire distributor stamping press mfg. container making 

television network plastic racks mfg. cement storage silos 

road improvements bridge open space/parks 

While none of the stakeholders interviewed anticipated that permitting will be controversial, concern for 

nuisance and pollution issues has been a part of several Pilot discussions. For example, in Camden, the 

community was concerned about potentially unacceptable emissions from a newly patented concrete 

plant. Citizens’ fears were allayed when the developer, Liberty Concrete, described the new, cleaner 

process it planned to employ and agreed to the community request that an independent engineering firm 

conduct on-site monitoring. In Miami, concerns were similarly mitigated by the technology involved in 

current cement processes, the fact that an existing cement plant down the street has not had any 

complaints, and the scarcity of residents in the area of production. 

In southwest Detroit, community representatives felt that any proposed waste treatment facility sitings 

were likely to run up against permitting issues because the area is already highly industrialized and 

contains several waste treatment facilities that carry a large number of permits. The sentiment of the 

surrounding community is summarized in a quote by one community activist, “We are not saying ‘not in 

my backyard,’ we are saying, ‘my backyard is full.’ Now it is our turn for clean jobs.” The Pilot 

Manager echoed these sentiments and said that “they’ve got plenty of permitted facilities; any permitted 

facility would have to greatly benefit the community for them not to have opposition.” With these 

concerns in mind, the most recent proposed developments at the Detroit Pilot do not raise 

environmental issues because they are residential, commercial or light industrial. 

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In Chicago, a developer was interested in spending $2 million to clean up and redevelop a site, but 

could not get the necessary permits from the State because the site was located in a non-attainment 

area. Since the developer was going to create jobs for local residents, the community 

became an advocate for the project and the developer was able to get an emissions credit from 3M, a 

company also located in the non-attainment area. 

Some community groups were aware of how they could get involved in permitting decisions in their 

states. For example, interviewees in Camden knew that there was a ten-day comment period and a 

mandatory public meeting before the issuance of environmental permits. North Carolina, according to 

those interviewed in Charlotte, has a 60-day public comment period under which stakeholders can 

oppose a project under the State’s new brownfields act. To date, no projects in Charlotte have been 

canceled due to public opposition, possibly because the State requires documentation of local 

community support before issuance of liability protection under the law. However, in Lawrence, 

representatives were not aware of the State process for permitting. 

4. For sites in which no Title VI complaints were filed, what were the factors present which 

ensured there would be no complaints? 

For the seven case study Pilots, no Title VI complaints have been filed at any of the Pilot-targeted sites. 

According to interviewees across Pilots, the two most common factors cited that have prevented Title 

VI complaints to date at these sites are: 1) early and meaningful community involvement; and 2) 

redevelopment that creates a benefit for the local community. Interviewees across the board said that 

community outreach and involvement serve to prevent Title VI complaints and other opposition to 

redevelopment projects in many ways. In Camden and the City of Chicago, involving the community 

allowed potential problems to be identified and solved from the beginning, when stakes were lower and 

design changes could more easily be made. Charlotte representatives noted that the trust built between 

the community and the Camden Square site developer, and the fact that involvement has continued 

throughout the project, gave community organizations a sense of ownership in the project and 

prevented opposition. 

Another important component in reducing the likelihood of Title VI complaints and other opposition to 

redevelopment projects is that brownfields tend to be abandoned, polluted or otherwise blighted, 

thereby making redevelopment projects all the more welcome to neighboring, usually low-income 

communities. For example, in Miami, stakeholders interviewed believed that in addition to the 

anticipated “green” production of the proposed cement plant, no complaints will be filed because the 

plant will be such a big improvement over the current blight, crime and unemployment. Further, the site 

is located in a predominantly Hispanic neighborhood, where the developer, who is Cuban-American, 

has promised to train local residents for jobs in the plant. According to those interviewed, job creation 

is a big component of community satisfaction, and was mentioned by stakeholders in five of the seven 

Pilots as key factors in the community’s reaction to proposed developments. 

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It should also be noted that most of the planned redevelopment activities are not the type of activities 

that require environmental permits, but are generally non-controversial, non-industrial, service or 

administrative functions. 

5. How is the municipality’s environmental office working with its redevelopment office? 

What other working relationships are in place in the Pilot municipality (such as with the local 

civil rights office)? 

The case study cities span the range of inter-governmental cooperation between the local environmental 

and other departments and have a variety of working agreements. All of the case study Pilots except 

Lawrence have some mechanism by which the municipality or State environmental office is working 

with the redevelopment office or local community development or business development organization. 

In the Miami-Dade Pilot, where multiple municipalities and agencies are involved, an “interdepartmental 

agreement” will be put in place which outlines roles and responsibilities for not only the departments 

with an environmental or economic focus, but the police department, port, airport and public works 

departments as well. The Redevelopment of Urban Sites (R.E.U.S.) Action Team in Detroit consists of 

the Pilot Manager, representatives from the Detroit Department of Environmental Quality, EPA Region 

5, the Detroit Departments of Building Safety and Engineering, Water and Sewage, and Planning and 

Development, and representatives from Detroit Edison. The team was formed to partner regulators 

with the Detroit City offices that would be involved in the permitting process. 

No Pilots reported specifically working with the local civil rights office. 

While cooperation and collaboration is common, almost all Pilots felt they could do even better. 

Stakeholder suggestions included: 

C coordinate redevelopment discussions and activities between different areas of the 

municipality (e.g., North and South Camden and Miami and Miami-Dade County); 

C establish effective relationships between the municipality and the State (e.g., in Chicago, 

the Illinois EPA bureaucracy makes it difficult to complete permits and get a “No 

Further Remediation Letter”; the Miami-Dade Pilot hopes to improve the relationship 

between residents and the Office of Community and Economic Development to ease 

community concerns over job creation); and 

C ensure redevelopment activities have high-level, municipal buy-in and active support 

(while Detroit cited this as key to its successful relationships, Lawrence reported that its 

lack of leadership accounted for its low redevelopment activity). 

6. Has the presence of nearby Title VI complaints or environmental justice concerns 

influenced the level of community environmental justice activity? What is the effect of 

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these activities on communities and the local economy? 

Title VI complaints and environmental justice complaints have been avoided at Pilottargeted sites. However, historical enforcement problems and Title VI complaints in nearby

areas have created a potentially volatile and distrustful atmosphere in some instances. For

example, in three of the Pilot cities (Camden, Lawrence, and Chicago) there are active Title VI

complaints or environmental justice concerns. Outside the Pilot areas in Lawrence and Chicago,

there are environmental justice concerns and Title VI complaints, respectively, that focus on

incinerators. In Camden, community members have filed a class action lawsuit against the

County municipal authority and the New Jersey Department of Environmental Protection

(NJDEP) for disparate impact related to a sewage treatment plant.

Enforcement issues are also a major concern for community groups in Detroit, where EPA

Region 5 has recently reached an agreement with Detroit Coke owners/operators relating to

violations of the Safe Drinking Water Act regarding underground injection wells, resulting in a

$15,500 fine. Several interviewees noted that there is a perception of uneven enforcement in

southwest Detroit. For example, one interviewee commented, “Enforcement is treated differently

in southwest Detroit than in the affluent suburbs...a violation in the suburbs would get the plant

shut down; in the City we are lucky to get a citation.”

The atmosphere under which the Miami-Dade Pilot is operating is particularly distrustful. 

Activists who are concerned about environmental issues in Tallahassee and incinerators in

Broward County, Florida are holding meetings in Miami-Dade County to raise awareness among

residents there. Issues at the incinerator sites have caused the residents nearby to question

whether complete environmental and health information is being disclosed to them. These

meetings, then, are raising the suspicions of residents and community groups in Miami-Dade

about disclosure closer to home. This has the potential to cause some problems for Pilot

activities when redevelopment choices are being made.

Generally speaking, due to quality community involvement, open decision-making and noncontroversial redevelopment projects, the heightened awareness and sophistication of community

groups relating to Title VI issues, interviewees stated that Title VI has not proven to be a

problem, but could potentially slow down or block progress in the future.

7. Was alternative dispute resolution used or considered at any of the Pilots? If so, was it 

effective in preventing Title VI complaints? 

None of the case study Pilots have used formal alternative dispute resolution (ADR) for Title VI, 

environmental justice or any other conflicts. While no one interviewed noted the existence 

of deal-breaking conflicts relating to Title VI, lesser conflicts with communities (e.g., regarding 

nuisance related to noise and traffic, redevelopment design and job creation) all had the potential 

to derail the projects regardless of the lack of formal Title VI issues. 

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Three of the Pilots (Camden, Miami and Miami-Dade) said that personal communication and 

dialogues had been used between property owners and other stakeholders to resolve specific 

disputes. For example, in Miami, residents’ fears regarding traffic and dust were allayed through 

conversations with the owner at the Wynwood site, negating the need for a more formal 

dispute resolution process. In Camden, the non-profit group, Save our Waterfront, served as a 

catalyst for better communication between the City and interested community stakeholders and 

facilitated face-to-face discussions with the targeted site’s redevelopment team. Finally, in 

Charlotte, communication between local neighborhood associations and the Camden Square 

developer resulted in a compromise to lower building heights, a problem that could have caused 

delay for the developer and resistance from the community if it had not been dealt with early in 

the process. 

8. Are there examples or models of how Pilots can ensure sustained, meaningful 

community involvement? 

Each Pilot has a unique community involvement approach or model, specifically designed 

for its community’s political, geographic and organizational structure. While it is clear that 

models cannot simply be transplanted from one city to another, the case studies revealed 

promising components of various Pilot activities that other Pilots can use to help ensure 

sustained community involvement. These strategies include: 1) educating community 

representatives and other stakeholders; 2) institutionalizing the brownfields decision-making 

process; 3) facilitating timely and clear environmental decision-making with State officials; 4) 

making meetings/information accessible; and 5) creating and promoting trust through the use of 

neutral parties. These are discussed in more detail below. 

Educate Community Representatives and Other Stakeholders 

According to those interviewed, continuing education and outreach to stakeholders is critical to 

maintaining trust and communication about brownfields redevelopment’s technical aspects and 

priorities. At the Camden Pilot, the New Jersey Institute of Technology (NJIT) is entering into a 

contract with Save our Waterfront to provide training to residents on risk assessment, permit 

issues, and community organization that has proven successful for other New Jersey community 

groups. In Detroit, the Southwest Detroit Environmental Vision (SDEV) group carries out a 

variety of community capacity-building activities, including pollution prevention projects with 

small local businesses, and job training for local residents. SDEV has worked with a variety of 

university students and partnered with other non-profits and city departments to collect a lot of 

background information on various sites within the southwest neighborhood area, and uses 

trained citizen volunteers to conduct Phase I assessments, environmental surveys and market 

research for companies interested in relocating onto brownfields in their neighborhood. 

According to SDEV representative Kathy Milberg, SDEV is “actively engaged in marketing 

clean companies so that we don’t have to be victims again.” 

Institutionalize the Brownfields Decision-Making Process 

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The examples illustrated below indicate that “institutionalizing” processes that have been 

successful at involving the community can help ensure that the community stays involved. 

Camden will institutionalize the monthly redevelopment team meetings; continuing to conduct 

these meetings should help ensure sustained community involvement. In its role as coordinator 

for the Knox site, the Pilot has helped forge working relationships that should allow the 

community to more easily achieve results in future endeavors on this and other brownfields 

projects. In Charlotte, both the Pilot Manager and representatives from community groups 

expect to continue sharing in the decision-making process with regard to current and future 

brownfields projects. Parties across the case study Pilots acknowledged that the key to continued 

success is to maintain open dialogue and trust between the parties and to involve all concerned 

from the beginning. 

Similarly, having an institutionalized stakeholder group like Camden’s redevelopment team 

appears to be effective in preventing disputes, or at least provides a forum for their resolution 

outside of the courtroom. The NJIT community training model has been used in other New 

Jersey cities as a way to empower community members to be credible participants in brownfields 

redevelopment. The Pilot Manager has indicated that the Pilot would like to use the same 

approach for South Camden. In addition, NJDEP recently received a $100,000 Environmental 

Justice grant from EPA to develop an “environmental equities” program. The agency intends to 

work with several communities around the State and with the State Office of Alternative Dispute 

Resolution “so that we don’t have a lawsuit” at the end of the redevelopment pipeline. NJDEP 

hopes that by involving all stakeholders from the beginning, like with the Knox redevelopment 

team, the agency can prevent problems before they start and prevent those who decide not to 

participate in the process from filing lawsuits after the process is complete. 

Facilitate Timely and Clear Environmental Decision-Making with State Officials 

Based on the experiences of the case study Pilots, the quality of the relationship between 

municipal and State agencies can help or hinder the cleanup and redevelopment of brownfields, 

as illustrated below. 

Chicago used part of its original Pilot funds to conduct an independent evaluation of the 

effectiveness of the Brownfields Forum, and the City will implement suggestions from the 

evaluation to develop a more coordinated process with the Illinois EPA (IEPA). According to 

one respondent, the City and IEPA could work together to help prioritize activity on sites related 

not only to environmental and public health needs, but on construction seasons and funding 

cycles as well, as these are sometimes dependent upon “No Further Remediation” letters. 

Currently, the IEPA is viewed by many developers as a barrier to brownfields redevelopment. 

Regardless of a positive relationship between the community, the developer and the Pilot, it is 

important to realize that community revitalization activities can be blocked due to a negative 

relationship with State agencies. In Miami, it was expressed that developers feel that the MiamiDade County Department of Environmental Management (DERM) requires too much testing and 

17
data tracking, and as a result shy away from developing those properties because this process is 

so costly and time-consuming. According to stakeholders interviewed for the Miami Pilot case 

study, it seems important that Pilot efforts work at not only developing positive relationships 

with the local community, but also at putting in place the necessary processes to ensure that 

community redevelopment projects are not unnecessarily delayed by State or Federal agencies. 

Make Meetings/Information Accessible 

According to those interviewed, making meetings and other forums open and accessible to the 

public can go a long way toward promoting and sustaining community involvement. The 

Lawrence Pilot Managers learned that access to decision-making and public meetings does 

not ensure meaningful community involvement. To that end, the Pilot is cooperating with the 

Merrimack College Urban Resources Institute, through an EPA Environmental Justice grant, to 

promote community involvement in neighborhood associations and minority areas. The 

Resources Institute has been conducting surveys with Latino residents to determine if they have 

any environmental questions, health questions, or safety concerns. Future efforts may include 

distributing Spanish-language pamphlets and using an interpreter at meetings. 

It is also important to avoid technological jargon and other complicated approaches that could 

alienate community members at these meetings. One respondent expressed frustrations about the 

weaknesses in community involvement: “I’d like to see [the Brownfields Advisory Committee] 

lay down their redevelopment plans in the simplest terms possible—tell me what is expected and 

when, and how community groups can be involved in real decision making, not just feedback. 

I’d like more specifics [at these meetings], more chances for community groups to make a 

difference.” 

Create and Promote Trust through the Use of Neutral Parties 

Use of neutral parties to interpret and explain technical information was a critical component to

success in several Pilots. In Miami, for example, one respondent explained that trust-building

activities such as bringing in a toxicologist to explain potential impacts goes a long way in

building community support. Several interviewees in Detroit remarked that the use of universities

and other non-profit groups to serve as neutral parties and capacity-building resources has made a

significant difference in the community’s ability to be an effective stakeholder. Community

experts from the universities can provide outreach and education without the distrust sometimes

faced by State/City representatives. Further, these resources help build capacity within the

community, making them credible participants in the redevelopment dialogue.

9. How can the findings of this study be applied beyond Brownfields activities? 

There are several areas in which the results of these case studies appear to be applicable 

beyond Brownfields activities, as detailed in the sections below: 1) brownfields relationships 

have other positive spin-offs; 2) State redevelopment incentives are impacting developers’ 

18
behavior; 3) overcoming bad history and skepticism; 4) alliances with non-profits show results 

and add value; and 5) local/state/federal multi-agency task forces speed cleanup. 

Brownfields Relationships Have Other Positive Spin-Offs 

As illustrated by the examples that follow, relationships developed during brownfields 

redevelopment can form the basis for future cooperation in other local efforts. 

The Charlotte stakeholders have learned that developing trusting, mutually beneficial 

relationships among communities, businesses and the City for brownfields redevelopment can 

create other benefits. The Wilmore Neighborhood Association plans to leverage its strong 

relationship with the City of Charlotte to build further partnerships with public and private 

sectors to achieve such other community goals as job training and education, neighborhood 

beautification, and crime reduction. As a result of the close relationship between 

the Association and the developer for the Camden Square site, the developer is now helping to 

support activities at the neighborhood’s community center as well as conducting redevelopment 

projects. 

Chicago Pilot stakeholders have learned that relationships built between the City and local 

communities during the course of brownfields redevelopment can also be leveraged to help 

address other community issues. For example, Alderman Michael Chandler of the 24th Ward 

illustrated an example of how the City and the local community worked together to solve a 

brownfields-related crime and blight issue. Illegal dumping at brownfields and other sites is a 

large and expensive problem for the City of Chicago, with an annual average cleanup price tag of 

$11.5 million. In the summer of 1995, the Chicago Department of Environment, the 11th Police 

District and local residents began a cooperative enforcement program where residents were given 

brochures in English, Spanish, and Polish that included a hotline to report illegal dumping. 

According to Chandler, “we swarmed the 11th Police District for fly dumpers and caught many of 

them.” 

Simultaneously, the City Council passed an ordinance “that gave teeth to a law against illegal 

dumpers.” Stricter punishment provisions for fly dumping now include: fines between $1,000 

and $2,000 for first-time offenders; jail time of up to six months and community service up to 

200 hours; impoundment of vehicles with up to $2,000 in fines; $100 rewards for citizen 

information leading to conviction; and loss of City contracts and business licenses for those 

convicted. 

State Redevelopment Incentives are Impacting Developers’ Behavior 

In North Carolina, the impact that the State’s new brownfields act has had on encouraging 

developers to involve local communities in a meaningful way is showing early, but promising, 

results. According to developers and business owners interviewed, protection from 

environmental liability for pre-existing contamination is often critical to making a project viable 

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in Charlotte. To receive liability protection from the State, the community must provide letters 

of support for the redevelopment project, adding an additional incentive for developers in 

North Carolina to work with affected stakeholders. 

Overcoming Bad History and Skepticism 

As is evidenced by the examples which follow, despite a poor track record or a community’s 

skepticism concerning redevelopment, these obstacles can be overcome and results achieved. 

Chicago’s brownfields activities have shown that through dedication, long-term stakeholder 

involvement, and education, the City was able to overcome initial skepticism, establishing a 

solid track record of past performance for future projects. The broad-based, inclusive type of 

decision-making evidenced in the Chicago Brownfields Forum is easily transferable to other 

types of community decision-making processes that require multiple stakeholders, such as master 

planning, park and greenway development, capital improvements, and stadium siting. 

A lesson learned from this case study effort that can be applied to almost any public program is 

that citizens’ perceptions of past activities dramatically impact chances for success on new 

initiatives. In Miami, for example, Ron Frasier of the Black Business Association believes that 

most residents will be reluctant to get involved until they see development happening. With all 

the promises that have been made in the past, residents are wary of getting their hopes up. Julian 

Perez added that “programs create expectations,” and that public servants need to be aware of 

that going in and tailor their messages and activities accordingly. 

Alliances with Non-Profits Show Results and Add Value 

As illustrated below, strategic alliances with non-profits can add value to a city’s redevelopment 

efforts. 

The environmental knowledge and planning exhibited by Save Our Waterfront in Camden went a 

long way toward realizing not only its redevelopment plan, but its power as an organized, 

educated, and involved stakeholder group. Tom Knoche of Save Our Waterfront described the 

planning process for a redevelopment plan for North Camden as “entirely community driven.” 

Development of the plan involved community meetings, meetings with businesses, churches, 

residents, and social service agencies. Save Our Waterfront serves as the coordinating body 

between several non-profits, private developers, and public agencies as the plan begins to be 

implemented. 

The Detroit Community Outreach Partnership Center (DOCP) is a collaboration between the 

University of Michigan, Wayne State University, and Michigan State University to provide 

outreach services for communities in Detroit. University students have aided SDEV in 

gathering information on sites in southwest Detroit, and the use of university staff to serve as a 

neutral party in environmental discussions has increased credibility and trust of redevelopment 

efforts. 

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Local/State/Federal Multi-Agency Task Forces Speed Cleanup and Redevelopment 

Finally, as evidenced by the following examples, task forces comprising local, State and Federal

agencies can result in quicker cleanup and redevelopment processes.

An innovative multi-agency task force (regulatory and environmental representatives from the

State and Region) created to address cleanup issues at the Oxford Paper site and adjacent

GenCorp property in Lawrence is showing promising results for speeding up environmental

cleanup activities. In addition to helping create the Brownfields Pilot proposal and sitting on the

Lawrence Brownfields Advisory Committee, GenCorp also invested $60,000 to create a task

force that includes environmental and regulatory representatives and decision-makers from the

State of Massachusetts, EPA Region 1 and the City. According to GenCorp representative

Robert Devany, “The first phase of environmental cleanup work [on the Oxford 

Paper site] took 4 years; the second phase [after the creation of the task force] only took one year,

and it dealt with far more environmentally complicated issues.” Getting all the decision-makers

around the same table, with the same information and making decisions in concert really sped up

the process.

As stated earlier, the R.E.U.S. Team in Detroit consists of the Pilot Manager, representatives

from the Detroit Department of Environmental Quality, EPA Region 5, the Detroit Departments 

of Building Safety and Engineering, Water and Sewage, and Planning and Development, and 

representatives from Detroit Edison. Although there are no community members represented on 

the team, it was formed to partner regulators with the Detroit city offices that would be involved

in the permitting process. In this way, the R.E.U.S. Team also serves as a “one-stop shop” for

community members, investors, or developers interested in learning more about the costs, 

concerns, and processes associated with the assessment, cleanup, and redevelopment of 

brownfields.

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IV. CONCLUSIONS 

The findings of these seven case studies demonstrate that claims that EPA’s Interim Title VI

Guidance would hinder brownfields redevelopment are largely unfounded. Although it cannot be

stated that Title VI will never prove to be a deterrent to redevelopment of inner city brownfields

areas, the experience of these seven Pilot cities—chosen for this case study specifically because

of their likelihood to have Title VI issues—seems to indicate that Title VI has not been a major

factor in redevelopment decisions taken for Brownfields Pilot areas. 

More than 50 interviews with various stakeholder groups, including developers, lenders,

community representatives, and public officials, reveal that one of the primary concerns in

redevelopment decision-making is community support for projects. Because of the scope of

community involvement at Brownfields Pilots, residents are not likely to oppose the 

redevelopment projects in their communities. When opposition does occur related to

environmental justice, it is usually in protest to more “traditional” or “dirty” issues, such as

incinerators. Brownfields are usually redeveloped into commercial/retail or light-industrial uses,

further limiting the possibility that Title VI or environmental justice concerns would be raised.

When asked whether Title VI could hinder redevelopment, stakeholders interviewed

indicated that anything with the possibility to slow down or block redevelopment could serve as a

deterrent to planned redevelopment. However, in reality, Title VI has not proven to be an issue

or a deterrent at any of the case study Pilots, and there have been no Title VI complaints at any of

these Pilots’ targeted areas.

It is apparent from the interviews conducted for these case studies that while there are many

potential issues that can forestall redevelopment at brownfields sites, Title VI is not high on the

list of concerns. The quality and scope of community involvement conducted by the Pilots, as

well as the fact that brownfields are not usually redeveloped into heavy industrial or other uses

which would raise Title VI concerns, minimizes the likelihood that Title VI complaints would be

raised at brownfields sites and hinder redevelopment of these areas.

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