Commentary: Report Card on the Market‐Based Approach to Brownfield Redevelopment

Published date01 March 2015
AuthorBruce Rasher
Date01 March 2015
Bruce Rasher is redevelopment manager
for the Revitalizing Auto Communities
Environmental Response (RACER) Trust,
which was created in 2011 to clean and
redevelop former General Motors sites. He
chairs the Association of Redevelopment
Initiatives, serves on the Urban Land
Institute’s Redevelopment and Reuse
Council, and was a two-term mayor of
Marshall, Michigan.
262 Public Administration Review • March | April 2015
Public Administration Review,
Vol. 75, Iss. 2, pp. 262–263. © 2015 by
The American Society for Public Administration.
DOI: 10.1111/puar.12345.
more private involvement and faster cleanups for the
industrial reuse of brownf‌i elds, as I have long held
the opinion that the costs of the remedy to achieve
a safe and protective cleanup for industrial uses are
generally materially less than for residential reuse and
therefore much more manageable. Concurrent with
the enactment of liability reforms and the creation of
brownf‌i elds incentives, there were signif‌i cant changes
to determining “how clean is clean” for brownf‌i elds in
cleanup programs at the federal and state levels. Land
use–based and risk-based cleanup standards that led to
presumptive remedies and a two-tier system of clean-
ups—residential and nonresidential (e.g., industrial,
commercial)—streamlined the process of cleanups
and dramatically reduced their costs.
Another example is that it is not surprising to me to
see that the requirement for public hearings appears
not to have contributed to more cleanups. Most
private developers (and their sources of private capital,
both equity and debt) whom I know strive to reduce
the level of uncertainty for all aspects of their projects
so as to increase the probability of reaching their
f‌i nancial goals. One tenet of uncertainty for develop-
ers is that “time is the enemy” of achieving targeted
f‌i nancial returns because the longer you have to
f‌i nance your carrying costs, the more your f‌i nancial
pro forma gets punished. Public hearings are widely
regarded by developers as a wildcard in terms of costs
and often are perceived as a cause of signif‌i cant delay
of projects. But, as to the central focus of this article’s
exercise, some, myself included, may even conclude
that these f‌i ndings are a vindication the New Public
Management approach to brownf‌i elds in that there
has apparently been an increase in private involve-
ment in brownf‌i eld cleanup and redevelopment since
the abandonment of the stick and the adoption of the
While this article provides many valuable insights into
brownf‌i eld redevelopment trends that have occurred
since the mid-1990s, for me, it raises some related
questions. First, did the widespread fear of strict,
The f‌i ndings of Adam Eckerd and Roy L.
Heidelberg in their article “Public Incentives,
Market Motivations, and Contaminated
Properties: New Public Management and Brownf‌i eld
Liability Reform” represent a long-overdue “audit” of
what was a signif‌i cant paradigm shift in the approach
to the cleanup and redevelopment of brownf‌i elds in
the United States.  is shift was undertaken through
the enactment of laws by Congress and state legisla-
tures and through regulatory reforms supported by
federal and state environmental regulatory agencies
beginning in the mid-1990s, going from a command
and control enforcement framework to the use of
buyer liability protections and public f‌i nancial incen-
tives to induce more private investment in brown-
f‌i elds.  e goals of this shift were to increase the
number of cleanups, accelerate the pace of cleanups,
reduce the threats to public health and the environ-
ment posed by uncontrolled sites of environmental
contamination, foster the reuse of blighted proper-
ties, restore employment and tax base, and increase
reuse of public infrastructure at brownf‌i elds, as well as
reduce the incentives for greenf‌i eld development.  is
shift enjoyed fairly broad bipartisan legislative support
as well as support by regulatory agencies, the business
community, local governments, and, to a lesser extent,
community and environmental groups, as the old way
clearly was not working very well.
I have spent a fair portion of my career working
with brownf‌i elds, f‌i rst as a representative of a PRP
(potentially responsible party), overseeing the cleanup
of brownf‌i elds under an enforcement regime, and
then as either the owner, seller, buyer, or developer of
brownf‌i elds, acting as a third-party deal facilitator of
brownf‌i eld redevelopment and taking advantage of
buyer liability protections and packaging public f‌i nan-
cial incentives in one way or another to ef‌f ectuate the
cleanup and redevelopment of brownf‌i elds.
Some of the f‌i ndings of this article conf‌i rm my obser-
vations as a longtime practitioner. For example, it is
not surprising to me at all to see that there has been
Report Card on the Market-Based Approach
to Brownf‌i eld Redevelopment
Bruce Rasher
Revitalizing Auto Communities Environmental Response (RACER) Trust

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