Superfund: Barriers to Brownfield Redevelopment (Letter Report, 06/17/96,
GAO/RCED-96-125).

Pursuant to a congressional request, GAO reviewed proposed legislation
to redevelop abandoned, urban industrial sites, focusing on: (1) the
number of potential sites nationwide; (2) impediments to redeveloping
sites posed by the Superfund program; and (3) whether proposed loans to
local governments are sufficient for conducting site assessments.

GAO found that: (1) researchers estimate that about 150,000 acres of
abandoned or underused industrial land exists nationwide; (2) lenders,
property buyers, and property owners are reluctant to redevelop these
sites because federal and state environmental laws may require expensive
cleanups of latent industrial wastes before property improvements can be
made; (3) federal law limits the liability of a party that holds
ownership in a property but does not manage the property; (4) proposed
legislation would limit the amount lenders would have to pay in the
event they are liable, limit the liability of property buyers who assess
a site for contamination before buying it, and provide assistance for
state programs that encourage voluntary cleanup of industrial waste
sites; (5) even if the liability of lenders and property buyers is
limited, abandoned industrial sites might continue to be viewed as risky
investments due to the possibility of contamination; and (6) proposed
legislation would provide interest-free loans to localities to conduct
site assessments to determine the extent of contamination.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-96-125
     TITLE:  Superfund: Barriers to Brownfield Redevelopment
      DATE:  06/17/96
   SUBJECT:  Urban economic development
             Industrial facilities
             Industrial wastes
             Economically depressed areas
             Liability (legal)
             Environmental law
             Toxic substances
             Proposed legislation
             Loans to localities
             Environment evaluation
IDENTIFIER:  EPA National Priorities List
             Superfund Program
             
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Cover
================================================================ COVER


Report to Congressional Requesters

June 1996

SUPERFUND - BARRIERS TO BROWNFIELD
REDEVELOPMENT

GAO/RCED-96-125

Barriers to Brownfield Redevelopment

(160334)


Abbreviations
=============================================================== ABBREV

  ASTM -
  CERCLA -
  EPA -
  GAO -
  NPL -

Letter
=============================================================== LETTER


B-271652

June 17, 1996

The Honorable John Chafee
Chairman, Committee on Environment
 and Public Works
United States Senate

The Honorable Robert Smith
Chairman, Subcommittee on Superfund,
 Waste Control and Risk Assessment
Committee on Environment
 and Public Works
United States Senate

Over the past several decades, manufacturing has been declining in
many of the nation's cities.  When the businesses closed, they left
abandoned and idled properties commonly known as "brownfields," which
are sometimes contaminated with chemical wastes from the
manufacturing processes.  Because, in part, of the high cost of
assessing the sites to determine the nature and extent of
contamination and to clean them up in accordance with federal and
state environmental laws, some new businesses have chosen to locate
on uncontaminated sites outside of urban areas, known as
"greenfields." These decisions lead to the loss of tax revenue and
employment in central city neighborhoods.  Lenders and developers are
wary of investing in such contaminated property because, under the
environmental laws, they could be held liable for cleaning up the
contamination.  They have often cited the liability provisions in the
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), commonly known as Superfund, as one of the major
disincentives to redeveloping brownfields.  In June 1995, we reported
on the barriers, including liability under CERCLA, to redeveloping
urban industrial property.\1

The Senate's proposed legislation to reauthorize Superfund, S.  1285,
seeks to encourage local governments to redevelop brownfields by
addressing two of the barriers to redevelopment:  liability under the
Superfund legislation and the costs of assessing the sites.  The bill
would protect lenders and property purchasers from Superfund
liability under certain circumstances.  It also proposes to assist
with the costs of assessing the sites by providing interest-free
loans of $100,000 per year, up to a total of $200,000 per site, which
local governments could use to cover these costs. 

To help you evaluate whether these provisions in S.  1285 would
encourage redeveloping the brownfields in the nation's cities, you
asked us to provide information on (1) what the universe of potential
brownfield sites nationwide is, (2) what legal barriers Superfund
presents for redeveloping brownfields, and (3) whether the proposed
loans to local governments are likely to be sufficient for conducting
site assessments. 


--------------------
\1 Community Development:  Reuse of Urban Industrial Sites
(GAO/RCED-95-172, June 30, 1995). 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

Abandoned or idled industrial sites that could be classified as
brownfields probably total hundreds of thousands of acres, but no
official nationwide count exists.  The researchers at the Urban Land
Institute, a nonprofit research organization involved in urban
issues, estimate that about 150,000 acres of abandoned industrial
land exist in the nation's major cities.  This number represents the
lower end of the potential estimates because it excludes some types
of commercial properties, such as ones with underground storage tanks
and former dry cleaners, that could be classified as brownfields. 
Some municipalities also made their own estimates of brownfield
acreage within their borders; these estimates range from hundreds to
thousands of acres.  Because the cities attempting to develop
brownfield inventories used different definitions of brownfields and
because many cities have not completed an inventory yet, precise
nationwide estimates are difficult to make. 

Superfund's liability provisions make brownfields more difficult to
redevelop, in part, because of the unwillingness of lenders,
developers, and property owners to invest in a redevelopment project
that could leave them liable for cleanup costs.  While brownfields
usually are not contaminated seriously enough to become Superfund
sites, these parties still fear that they could be sued for cleanup
costs if they become involved with a contaminated site.  For example,
as a result of the liability problem and the general riskiness of
investing in redeveloping brownfields, banks sometimes refuse to lend
funds for this purpose.  S.  1285 seeks to lower these barriers by
exempting from liability both lenders and property purchasers under
certain conditions and by supporting the state programs that provide
protection from the states' liability laws to the parties that
perform voluntary cleanups. 

Officials who have overseen brownfield redevelopment projects told us
that the proposed interest-free loans of $100,000 per year, up to a
total of $200,000, would be sufficient to cover the average costs of
assessing the contamination at a single site and preparing a formal
site cleanup plan.  However, the assessment costs for very large
properties or those with complex contamination might exceed either
the annual or total loan limit. 


   BACKGROUND
------------------------------------------------------------ Letter :2

Under CERCLA, the Environmental Protection Agency (EPA) can compel
the parties responsible for hazardous waste contamination to pay to
clean up sites.  The cleanup costs can be considerable.  EPA
estimates that the average cost to clean up a site on the National
Priorities List (NPL), its list of highly contaminated sites, is $26
million.  Although most brownfields are not highly contaminated,
cities, lenders, and developers cite the possibility that the
liability provisions in CERCLA could be applied to these properties
as a major barrier to redeveloping them.  Under CERCLA, the
responsible parties are strictly liable for cleanup costs--they can
be compelled to perform cleanups--and can be subject to "joint and
several" liability.  Under strict liability, a responsible party is
liable regardless of whether the party is at fault.  Under joint and
several liability, each party can be held responsible for the entire
cost of the cleanup.  Most states have similar liability laws and
develop their own lists of the sites needing cleaning up. 

EPA defines brownfields as "abandoned, idled or underused industrial
and commercial facilities where expansion or redevelopment is
complicated by real or perceived environmental contamination." When
industries choose to avoid such potential problems by locating on
uncontaminated sites rather than on brownfields, they may seek
suburban "greenfields." Although these sites may require building
additional infrastructure, such as access roads and sewer systems,
that brownfield sites would not, the developers may still view
greenfields as more cost-effective than the sites requiring a
cleanup.  When the developers choose greenfields over brownfields,
city residents lose employment opportunities, city governments lose
tax revenue, and the new development contributes to urban sprawl. 

Several legislative proposals that would address brownfield issues,
including S.  1285, have been introduced.  Also, the President
recently proposed tax incentives for those who voluntarily clean up
brownfield properties.  Besides these proposals, other executive
agencies have provided funds for brownfield redevelopment.\2 EPA
issued a "brownfields action agenda" in 1995, which, among other
things, provides 50 grants to local governments to fund a wide
variety of 2-year demonstration projects that address brownfield
problems.  It has also removed nearly 28,000 sites from its list of
potential NPL sites, thereby potentially stimulating redevelopment at
these sites by reducing the possibility of Superfund liability. 
Additionally, EPA clarified its enforcement policies toward lenders,
property purchasers, and certain property owners to alleviate their
concerns and facilitate their involvement in the cleanup and
redevelopment of brownfields. 


--------------------
\2 The Department of Housing and Urban Development and the Department
of Commerce also sponsor research and provide technical assistance on
redeveloping industrial sites. 


   HUNDREDS OF THOUSANDS OF
   BROWNFIELD ACRES MAY EXIST IN
   U.S.  MUNICIPALITIES
------------------------------------------------------------ Letter :3

The abandoned or idled industrial sites that could be classified as
brownfields probably number in the tens of thousands, totaling
hundreds of thousands of acres, but no official nationwide count
exists.  Some of the research and advocacy organizations involved in
urban issues have developed estimates, and municipalities have also
estimated the potential number of brownfield sites, or acreage,
within their borders.  However, any estimate of the number of
brownfields is likely to be imprecise because the cities and others
measuring the number of brownfields often use different techniques
and definitions. 

The researchers at the Urban Land Institute estimated that about
150,000 acres of abandoned or underused industrial land exist in
major U.S.  cities.\3 This estimate excludes some commercial
properties that could also be classified as brownfields; those
excluded are sites with underground storage tanks, such as former gas
stations, or dry cleaners.  Therefore, this estimate represents the
lower end of the range of estimates.  While the federal government
and the states have not identified and listed brownfield properties,
several local governments that received grants under EPA's
brownfields pilot program have also developed estimates of brownfield
acreage within their borders.  (See table 1). 



                                Table 1
                
                   Estimates of Brownfield Acreage in
                 Selected Municipalities That Received
                 Grants Under EPA's Brownfields Program

                                        Population           Number of
Location                                  (1992)\a  brownfield acres\b
------------------------------  ------------------  ------------------
Birmingham, AL                             265,000      500 to 1,000\c
Bridgeport, CT                             137,000                 500
Indianapolis, IN                           747,000               1,000
Baltimore, MD                              726,000                 450
Cuyahoga County, OH                      1,411,000              40,000
----------------------------------------------------------------------
\a Source:  County and City Data Book, Bureau of the Census, 1994. 

\b Source:  Discussions with municipal officials in these cities. 

\c Note that these estimates are not strictly comparable because
local governments did not always use the same definition of a
brownfield site.  For example, officials in Bridgeport, Connecticut,
and Baltimore, Maryland, identified properties in limited areas of
these cities, focusing on the properties believed to be contaminated,
while Cuyahoga County officials included all abandoned industrial and
commercial properties throughout the entire county. 

In addition, the U.S.  Conference of Mayors, an organization for
local government issues, recently surveyed its member cities about
the amount of brownfield acreage in their cities.  (See app.  I for a
summary of the survey results for cities with populations over
100,000.) As with the cities participating in EPA's brownfields
program, these estimates varied considerably, from a low of 39 acres
in Houston (the estimate was limited to a 20-square-mile area of the
city targeted for redevelopment) to a high of 14,000 acres in
Cleveland, depending, in part, on how the cities defined and counted
their brownfields. 

The researchers and the cities have used different techniques and
definitions in measuring the number of brownfields.  For example, the
Urban Land Institute's estimate used a relatively narrow definition
of a brownfield site because it focused primarily on the industrial
corridors in larger cities.  The number of brownfield acres could
actually be greater than that estimate if it were based on the
broader definitions that some local governments used in preparing
their own estimates.  Table 2 outlines the ways in which brownfield
definitions vary. 



                                Table 2
                
                   Various Definitions of Brownfield
                               Properties

Factors defining a      Broad definition        Narrow definition
site as a brownfield    includes                includes
----------------------  ----------------------  ----------------------
Size of site            Small properties such   Only properties large
                        as gas stations and     enough to support
                        large multiple-acre     significant
                        sites                   redevelopment

Location                Industrial properties   Industrial properties
                        in any location,        in large central
                        including small towns   cities
                        and rural areas\a

Level of contamination  All abandoned           Property where
                        industrial property     contamination is
                        regardless of whether   perceived or
                        contamination is known  identified
                        to be present\b

Current status of site  All abandoned property  Abandoned industrial
                        and property not        property only
                        available for
                        redevelopment because
                        the owner has decided
                        not to sell\c
----------------------------------------------------------------------
\a EPA's grant program uses this inclusive definition.  In addition
to its grants to large cities, EPA recently awarded grants to several
small Oregon towns to redevelop abandoned lumber mills and to a
coalition of Chicago suburbs. 

\b It is difficult to determine in advance whether suspected
brownfields are, in fact, contaminated.  For example, the city of
Chicago is comparing currently vacant properties with old fire
department maps of the city to identify those properties likely to be
contaminated.  These maps detail the former industrial or commercial
activity at these sites and, therefore, the potential for
contamination. 

\c Owners may avoid selling contaminated properties because they fear
drawing attention to the contamination and thus incurring cleanup
costs. 

Source:  Discussions with municipal officials involved in brownfield
inventories and brownfield researchers. 


--------------------
\3 The researchers at the Urban Land Institute reached this estimate
by identifying the acreage devoted to industrial use in 10 major
cities in the 1950s and 1960s.  It then compared this acreage with
current estimates of vacant land in these cities and projected the
results to other cities where the population exceeded 25,000 in 1970. 


   CERCLA'S LIABILITY PROVISIONS
   RAISE A LEGAL BARRIER TO
   REDEVELOPING BROWNFIELDS
------------------------------------------------------------ Letter :4

The potential of being held liable under CERCLA for the contamination
on brownfield properties is a significant barrier to redevelopment,
according to lenders, property purchasers such as developers, and
property owners.  Most brownfields are not likely to be added to the
list of potential NPL sites because they are not severely
contaminated.  However, these investors still are wary of the cleanup
liability provisions of both federal and state legislation because
these can apply even at non-NPL sites.  As a result, lenders and
developers may avoid investing in potentially contaminated
properties, and current owners may avoid selling them.  To lower the
barriers to brownfield redevelopment, S.  1285 would limit the
liability of lenders and such property purchasers as developers under
certain conditions and also would provide assistance for the state
programs that encourage the voluntary cleanup of hazardous waste
sites.  However, these initiatives will not remove all barriers to
brownfield redevelopment, such as the initial cleanup costs or high
urban property taxes, that may still make them unattractive to
business in comparison with suburban greenfields. 

The liability for the costly cleanup of environmental contamination
is a barrier to brownfield redevelopment because it discourages
lenders, developers, and property owners from participating in these
projects.  Under CERCLA, the owners of property containing hazardous
substances are among those who can be held liable for the cleanup
costs incurred by EPA, the states, and other responsible parties,
regardless of whether the property is currently listed on the NPL.\4
The lenders who hold a security interest in contaminated property may
be considered property owners under CERCLA if they participate in the
management of the property.  The developers who purchase property may
also become liable for any contamination later found at the site. 
Former property owners may also be liable for the cleanup costs if
the contamination occurred during their ownership of the property. 
Thus, even the suspicion of current or prior contamination may make
lenders less willing to provide funds, developers less willing to
purchase property, and owners less willing to place their property on
the real estate market. 

The Congress and EPA have already taken some steps to limit lenders'
liability.  Under CERCLA, a party (such as a bank) that holds the
evidence of ownership (such as a mortgage) in the property to protect
its interest, and does not participate in the management of the
property, is not considered a property owner.  However, the statute
does not define what actions constitute "participation in the
management of the contaminated property," and the courts have given
varying meaning to this phrase.  As a result, many lenders are
reluctant to finance the purchase of property they suspect is
contaminated,\5 or to foreclose on such property in order to avoid
the potential liability for cleanup.  In an attempt to clarify these
matters, EPA issued a rule in 1992 that outlined the actions a lender
could take without becoming subject to liability.\6

However, in 1994 a federal appeals court held that EPA was not
authorized to issue the rule.  After the rule was invalidated, EPA
and the Department of Justice issued a policy stating that they
intend to apply the provisions of the rule when deciding whether to
take enforcement action against lenders.  However, the lenders can
still be sued by third parties seeking contributions for the cost of
the cleanup. 

The Senate bill proposes two actions specifically designed to lower
CERCLA's liability barriers to redeveloping brownfields.\7 First, the
bill would define in detail the circumstances under which a lender
who holds a security interest could act to protect that interest
without becoming liable for cleanup costs.  It also places a cap on
the total amount that lenders would have to pay in the event they are
liable.  Second, the bill would limit the liability of certain
purchasers of property, such as developers, if they assess a site for
contamination before buying it and find none.  Because the Senate
bill does not exempt property owners from liability, these owners may
continue to avoid selling contaminated properties because they fear
drawing attention to the contamination and thus incurring cleanup
costs.  However, the bill authorizes funds from the Superfund trust
fund to be used to help the states develop their voluntary cleanup
programs.  These programs often provide liability relief from the
states' hazardous waste laws to developers or property owners that
volunteer to clean up contaminated sites. 

Resolving CERCLA's liability concerns may not address all of the
barriers to redeveloping brownfields.  According to representatives
of several large banks, the contamination at brownfields still
generally makes them risky investments.  Because of the potential
contamination, developers have difficulty in predicting what the cost
to clean up a site will be and when it will be ready for
redevelopment; as a consequence, a return on the investment is
uncertain in comparison with the potential return on a project on a
greenfield site.  Lenders, developers, and property owners could also
be liable under other federal laws, such as the Resource Conservation
and Recovery Act, or the states' hazardous waste laws, potentially
increasing costs and slowing down the project. 

Also, it may still be difficult for some of these urban industrial
sites to compete with greenfields even if they are not contaminated. 
Although brownfield sites have some advantages for developers, such
as having the necessary water, power, and road infrastructure in
place to support a business, while greenfield sites may lack this
infrastructure, some brownfield properties present other problems
that can be associated with urban areas, such as higher property
taxes caused by a decline in the tax base.  These problems may be
even more intractable barriers to redevelopment than Superfund. 


--------------------
\4 However, as mentioned earlier, most urban industrial properties
would not be contaminated enough to meet EPA's criteria for adding
sites to the NPL.  In addition, EPA has slowed the rate of the NPL's
annual growth.  It plans to add fewer than 50 sites per year, far
fewer than the number of brownfield properties. 

\5 For example, a survey by the Independent Bankers Association of
America showed that one in five community banks reported a mortgage
default because of environmental contamination, and three out of four
of the banks said that they will not lend funds when they identify
environmental contamination. 

\6 EPA has also issued other guidance documents to encourage
brownfield redevelopment.  These include guidance for prospective
purchasers that allows the agency to enter into agreements with
prospective property purchasers not to sue them for contamination
existing at the time of the purchase.  EPA has also stated that it
will not take action against the owners of property located over
groundwater contaminated by sources outside of the property. 

\7 The Senate bill proposes other significant changes to CERCLA's
liability provisions that are not directly related to brownfield
redevelopment.  For example, the bill would also establish a process
for allocating the cleanup costs among responsible parties and
require the Superfund trust fund to pay the costs allocated to
insolvent parties, certain costs related to waste disposed of before
1981, and other costs.  These changes could affect decisions at
brownfield sites. 


   LOAN PROVISIONS IN S.  1285
   SHOULD COVER MOST COSTS OF SITE
   ASSESSMENTS
------------------------------------------------------------ Letter :5

The interest-free loans of $100,000 to $200,000 to municipalities
proposed in S.  1285 to fund site assessment activities should be
sufficient to cover the average cost at a brownfield site.  Before
brownfields can be redeveloped, it is necessary to perform a site
assessment to determine the nature and extent of the contamination
present.  Because the site assessment requires research into a site's
history and a technical analysis of the site's conditions, a
substantial expenditure may be involved.  For most brownfield sites,
assessment costs could range from an average of $60,000 to $85,000 to
more than $200,000; thus, the loan amounts proposed in S.  1285 would
cover the costs in most cases.  However, the costs could be higher
for very large sites or those with complex contamination. 

Conducting a site assessment is the first step in deciding how to
clean up and redevelop a site.  The parties conducting these
assessments generally use standard processes developed by the
American Society for Testing and Materials (ASTM).\8 Under this
system, the property owners, investors, or lenders hire a contractor
to conduct a Phase I assessment.  This phase involves identifying
potential contamination by (1) reviewing the site's historical
records, (2) interviewing those with knowledge of the former
activities at the site, and (3) visually inspecting the site for
physical evidence of hazardous waste.  If the Phase I assessment
turns up any evidence of environmental contamination, a Phase II
assessment is necessary.  In this phase, environmental professionals
identify the nature and location of the contamination through
sampling and analyzing materials from the site's structures and
environmental media, such as soil and groundwater.  As a final stage,
the environmental professionals prepare a plan for cleaning up the
contamination identified in Phase II.  These plans are often subject
to review and approval by the local or state government. 

We interviewed cleanup contractors and city officials that have
overseen the assessment and redevelopment of brownfields to determine
the costs of assessing a 10- to 20-acre site.  These officials told
us that developers are typically interested in properties ranging
from 10 to 20 acres in size because these would support a substantial
new business, such as a manufacturing facility or a business park. 
Some small commercial sites, such as former gas stations, are often
consolidated into larger parcels to be economically viable for
redevelopment.  See table 3 for a summary of these officials'
estimates. 



                                Table 3
                
                   Estimated Costs of Performing Site
                              Assessments

                                                         High range of
Assessment activity                  Average costs               costs
------------------------------  ------------------  ------------------
Phase I review                      $1,000 -$5,000             $10,000
Phase II review                   $50,000 -$70,000            $150,000
Cleanup plan                               $10,000             $50,000
======================================================================
Total                             $61,000 -$85,000            $210,000
----------------------------------------------------------------------
On the basis of their experience, these city officials and a
contractor concluded that the proposed loan of $100,000 per year
would be sufficient to assess a site and prepare a cleanup plan for
most sites.  Costs in the high range could be encountered at larger
properties or sites with complex contamination, such as those with
extensive groundwater contamination, which is costly to assess. 
These sites could require more than the proposed $100,000 per year
and could also occasionally exceed the $200,000 loan total.  Local
officials told us that some flexibility to exceed the $100,000 per
year limit and the $200,000 total would be helpful for such sites. 


--------------------
\8 ASTM is a nonprofit organization that writes standards and testing
methods for various products and services, including environmental
services. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :6

We provided a draft of this report to EPA for its review and comment. 
We met with EPA officials that manage EPA's brownfield initiatives,
including the Director of the Outreach and Special Projects Staff in
the Office of Solid Waste and Emergency Response, and an attorney
with the Office of Enforcement and Compliance Assurance.  They
generally agreed with the information in the report.  However, they
pointed out that the estimates of the number of brownfields in the
United States vary widely and that the Urban Land Institute's
estimate is likely to be conservative.  We have provided more details
on the sites potentially excluded from this estimate.  The officials
also explained that the loan program provided for in S.  1285 could
be difficult and costly for EPA to administer and instead preferred
the provision of grants to local governments.  They also noted a
number of policies that EPA has issued to help remove some of these
liability barriers to brownfield redevelopment.  We have recognized
some of these policies, as appropriate, throughout the report. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :7

To estimate the inventory of brownfields in the United States, we
contacted the research organizations attempting to inventory
brownfields.  We also contacted local officials in five cities that
may have developed an inventory as part of their application for a
grant under EPA's brownfields pilot program.  To identify the
difficulties in redeveloping brownfields, we interviewed federal
officials involved in EPA's brownfields program, officials of five
states' voluntary cleanup programs, local officials with experience
in redeveloping brownfields, and representatives of lending
institutions.  To determine the potential cost of assessing
brownfield sites, we contacted city officials in eight cities that
have already redeveloped brownfield properties and environmental
cleanup contractors with experience in working with brownfields. 
Because of time constraints, we could not independently survey cities
to identify the number of brownfield properties within their
boundaries and relied on the information that various cities had
already compiled.  We also reviewed the existing literature on
identifying and redeveloping brownfields.  We conducted our review
from November 1995 through April 1996 in accordance with generally
accepted government auditing standards. 


---------------------------------------------------------- Letter :7.1

As arranged with your office, unless you publicly announce its
contents earlier, we plan no further distribution of this report
until 10 days after the date of this letter. 

Please call me at (202)512-6112 if you or your staff have any
questions about this report.  Major contributors to this report are
listed in appendix II. 

Peter F.  Guerrero
Director, Environmental
 Protection Issues


RESULTS OF CONFERENCE OF MAYORS'
SURVEY OF BROWNFIELDS
=========================================================== Appendix I

The U.S.  Conference of Mayors, an organization for municipalities,
completed a survey of its member cities in January 1996.  The survey
asked the cities to provide information on the brownfields within
their borders.  Table I.1 summarizes the survey results for cities
with populations over 100,000, for those cities that provided
estimates in acres. 



                               Table I.1
                
                 Results of U.S. Conference of Mayors'
                         Survey of Brownfields

                                        Population           Number of
Location                                  (1992)\a  brownfield acres\b
------------------------------  ------------------  ------------------
San Francisco, CA                          729,000                 831
Denver, CO                                 484,000               8,400
Fort Wayne, IN                             174,000               2,975
Gary, IN                                   117,000               1,281
Louisville, KY                             271,000               5,500
Minneapolis, MN                            363,000               2,000
St. Louis, MO                              384,000               1,000
Lincoln, NE                                197,000                  50
Newark, NJ                                 268,000                 203
Rochester, NY                              234,000                 293
Cleveland, OH                              503,000              14,000
Dayton, OH                                 183,000                 100
Tulsa, OK                                  375,000                 100
Portland, OR                               445,000                 400
Erie, PA                                   109,000                 125
Providence, RI                             155,000               2,290
Knoxville, TN                              167,000                 250
Houston, TX                              1,690,000                  39
Salt Lake City, UT                         166,000                 250
Seattle, WA                                520,000               2,070
Tacoma, WA                                 184,000                 400
----------------------------------------------------------------------
\a Source:  County and City Data Book, Bureau of the Census, 1994. 

\b Because the survey questionnaire did not contain a specific
definition of brownfields, these cities used different criteria in
estimating their brownfield acreage.  For example, some cities, such
as Houston, identified the brownfields located in particular
enterprise or industrial redevelopment zones, while others tried to
identify all of the brownfield properties within their borders. 


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix II

Eileen Larence
Katherine Siggerud
Rosa Maria Torres Lerma


*** End of document. ***