Brownfields ACRES Frequent Questions - Property-Specific Information
When is cleanup considered started?
When the cleanup contractor mobilizes at the property. Cleanup activities include, but are not limited to, demolition for environmental reasons; emergency removals; drum barrel removal; soil, water, and ground water treatment; capping; and operation and maintenance activities.
When is a cleanup considered completed?
When cleanup activities at a property are completed to a regulatory risk-based standard. This typically occurs when one of the following conditions applies:
- A "clean" or "no further action" letter (or its equivalent) has been issued by the state or tribe under its voluntary response program (or its equivalent) for cleanup activities at the property; or
- The grant recipient or property owner, upon the recommendation of an environmental professional, has determined and documented that on-property work is finished. Ongoing operation and maintenance activities or monitoring may continue after a cleanup completion designation has been made.
When is redevelopment considered started?
Generally, redevelopment is considered started at a brownfields property when infrastructure preparation, property preparation (site grading), or a groundbreaking ceremony has occurred. Conceivably, the redevelopment start date can precede the date of cleanup completion when portions of the property are undergoing simultaneous cleanup and redevelopment activities. However, environmental cleanup activities necessary to prepare the property for redevelopment (i.e., demolition of a remaining structure) should not be considered as redevelopment started.
Who determines if Institutional Controls (ICs) are in place?
The determination that ICs are in place (e.g., state, tribal, and local government, private parties) varies depending on the type of IC, the specific circumstances at each site, and which authorities are being applied.
For additional information on institutional controls, refer to the EPA's Web page on ICs or contact your EPA Regional representative.
Do Institutional Controls (ICs) need to be in place for cleanup to be considered complete?
Some State/Tribal Response Programs (i.e., Voluntary Cleanup Program) have different approaches with respect to ICs. Some of them may require ICs be in place in order to certify a cleanup. Please contact your state or EPA Regional Representative for more details. The Brownfields Program states that a cleanup occurs when one of the following conditions applies:
- A "clean" or "no further action" letter (or its equivalent) has been issued by the state or tribe under its voluntary response program (or its equivalent) for cleanup activities at the property; or
- The cooperative agreement recipient or property owner, upon the recommendation of an environmental professional, has determined and documented that on-property work is finished. Ongoing operation and maintenance activities or monitoring may continue after a cleanup completion designation has been made.
Where do I put additional EPA funds spent at the property that are not from the EPA Brownfields Program?
Any additional EPA funds (e.g., EPA Smart Growth funding) should be entered under the "Other Federal" option in ACRES. Enter the funding amount and the name of the funding source (i.e., EPA Environmental Education Grant, EPA Environmental Justice Grant, etc.).
Note that funding from EPA's Brownfields Program (i.e., RLF, cleanups, assessments, 128(a), TBA) is not considered "leveraged" funding; therefore should not be entered in ACRES.
I know we will be receiving additional leveraged cleanup/redevelopment funding — when can I count this in ACRES?
Leveraged funding should be entered in ACRES only when actually manifested; uncommitted funding should not be entered in ACRES. For more information on "Leveraged" activities including funding, please see the Instructions for Completing the Brownfields Property Profile Form.
Our 10-acre property was assessed with EPA Brownfields Assessment funding, but cleaned up using non-EPA Brownfields Program funding (i.e., Cleanup, RLF, and State and Tribal property-specific cooperative agreements) — how do we enter the leveraged cleanup activities into ACRES?
For Assessment cooperative agreement recipients, enter available information relating to cleanup activities conducted with funding from other sources in the appropriate fields provided for "Environmental Cleanup Information" in ACRES (e.g., the leveraged funding source(s), name of entity providing leveraged funds, and the amount of funding leveraged for cleanup).
Why was an assessment start/completion or a cleanup start/completion moved to the Data Documentation Notes in ACRES?
Typically, if a performance measure was moved to Data Documentation Notes in ACRES, it was done to avoid or correct the double-counting of performance measure accomplishments. Double-counting of performance measure accomplishments can occur between Pilots/Grants (e.g., Pilot accomplishments are sometimes duplicated on the Grant PPFs) or Grants/Grants (e.g., accomplished are sometime duplicated when multiple grants are awarded to the same organization).