Approved by the Energy, Environment, and Water Policy Committee on January 16, 2025 
Approved by the Public Policy and Practice Committee on March 28, 2025
Adopted by the Board of Direction on July 10, 2025

Policy

The American Society of Civil Engineers (ASCE) supports and encourages: 

  • Continued federal financial aid to facilitate the redevelopment of brownfields sites, which are defined as properties where expansion, redevelopment, or reuse may be complicated by the presence or potential presence of hazardous substance, pollutant, or contaminant. 
  • Full funding of the Environmental Protection Agency (EPA) Brownfields Program, state sponsored brownfields programs, or other programs that encourage brownfields redevelopment.
  • Collaboration and improved communication among government agencies, private developers, and community organizations to share resources and expertise in brownfield revitalization efforts.
  • Reforms to streamline regulatory frameworks to accelerate site assessments, cleanup approvals, and redevelopment timelines.
  • Establishment of metrics and frameworks to evaluate the environmental, social, and economic outcomes of brownfield revitalization projects.
  • Modification to EPA regulation 40 CFR 312.10 to restrict the definition of an "Environmental Professional" to individuals with relevant experience holding a current: 1) Professional Engineer's license; or 2) Professional Geologist's license; or 3) appropriate certifications.

Issue

Brownfields are properties complicated by the potential or confirmed presence of hazardous substances, pollutants, or contaminants. These sites, often remnants of industrial, manufacturing, or commercial use, are prevalent in urban, suburban, and even rural areas.  They represent a dual challenge: the need to address environmental hazards and the opportunity to reclaim valuable real estate for sustainable development.  While brownfields are sources of risk, they also have immense potential for revitalization that benefits communities economically, socially, and environmentally. 

In 2002, the Small Business Liability Relief and Brownfields Revitalization Act (Act) was passed, which amended the Comprehensive Environmental Response, Compensation, and Liability (CERCLA) Act to establish the EPA Brownfields Program, the law clarified liability protections, expanded funding for brownfields assessment and cleanup, and increased support for state and tribal programs. 

EPA's role on the Standards and Practices for All-Appropriate Inquiries (AAI) set the qualifications for the Environmental Professional who is authorized to perform the AAI process at brownfields sites under CERCLA. Currently an individual can be qualified as an Environmental Professional with 10 years of relevant experience, with no associated education requirements. This would allow technicians with no formal education beyond the high school level to perform key engineering duties at hazardous waste facilities. This regulation places human health and the environment at risk by allowing unlicensed personnel to practice engineering at sites and facilities contaminated by hazardous substances. These functions include determinations of the nature of hazardous waste and other toxic materials on the site, the extent of the pollution, the potential risk to public health, site hydrology, as well as the development of potential engineering or environmentally sound solutions to the site's contamination.

Rationale

The revitalization of brownfields requires a comprehensive, coordinated effort that combines technical expertise, policy innovation, and community collaboration.  Engineers are uniquely positioned to play a pivotal role in this process from assessing and remediating contamination to designing infrastructure that supports sustainable and equitable redevelopment. Through policies, funding, and community engagement, brownfields can be transformed into thriving hubs of economic activity, environmental restoration, and social vitality. 

A targeted brownfields restoration program should take into account site-specific environmental exposure factors and risks based on a reasonable assessment of the future use of the property by competent licensed professional engineers, or licensed professional geologists or persons with appropriate certifications.

ASCE Policy Statement 485 
First Approved in 2001