Brownfield Cleanup Loan Program

The Brownfield Cleanup Loan Program (BCLP) offers below-market rate loans to brownfield property owners and prospective purchasers. The objective of this program is to assist in the cleanup of brownfield properties to return them to productive use.

The BCLP provides financing only for the environmental cleanup portion of the total costs of a real estate redevelopment project on a brownfield site. To learn about available assistance with environmental assessments please see information on the Brownfield Assessment Program.

The program is funded by the U.S. Environmental Protection Agency (EPA), and participation requires property eligibility, public participation, and compliance with federal rules and regulations. Applicants for this program must be deemed eligible for funding by staff prior to submitting a loan application. The BCLP is administered through METCO, the Metropolitan Business Development Corporation.

Brownfield Cleanup Loan Program Requirements 

 

The Economic Development Department requires compliance with Environmental Protection Agency (EPA) cleanup rules and regulations and program policies will be revised on a periodic basis to ensure compliance with changes in federal and state laws, rules, and regulations. Loan recipients are responsible for hiring a Qualified Environmental Consultant or QEC. For more information on QEC’s requirements visit the EPA’s website here.

Analysis of Brownfields Cleanup Alternatives: Qualified environmental consultant hired by the Department of Economic Development will prepare an Analysis of Brownfields Cleanup Alternatives (ABCA) or equivalent state-required document summarizing information about the site and contamination (i.e., exposure pathways, identification of contaminant sources, types and levels of contamination, etc.); cleanup standards; applicable laws; alternatives considered (at least two, evaluated in terms of effectiveness, ability to implement and cost); and the proposed cleanup plan. The Department of Economic Development will facilitate public notice and comment prior to commencing cleanup.   

Build America Buy America Act (BABA): This act went into effect in 2022 and required that federally funded infrastructure projects use American iron, steel, manufactured goods, and construction materials. For more information visit this Frequently Asked Questions page.

An example from the EPA: "If a recipient hires a contractor to conduct cleanup and that cleanup involved the capping of the site with concrete that contains rebar that rebar would be considered “infrastructure” and would trigger BABA consideration, assuming no waiver applied. The recipient through their contractor would need to make sure that the rebar was made domestically.

Bipartisan Infrastructure Law (BIL) Signage: Loan recipients are required to display BIL signage at the site for the duration of the project. PDFs of the signs that must be used can be found online here. A photo of the sign must be submitted to the Department of Economic Development within one week of an executed loan agreement. 

Cleanup Action Memo or Report: After selecting the environmental cleanup action, the Department of Economic Development will prepare an action memo or a report that identifies the proposed removal action taken and the cleanup standards and goals. This document will explain why the cleanup is authorized; the rational for selecting that particular action and the responses to public comments on the ABCA.

MWBE Participation: Per Louisville Metro Code of Ordinances Chapter 37, the Metro Government, by and through its agencies and individual departments have established the following minimum goals of annual procurement expenditures. These requirements do not apply to forgivable loans, but are encouraged: 

  • 15% certified minority owned businesses 
  • 5% certified female owned businesses 
  • 5% certified second chance supporting businesses 
  • 0.5% certified disabled owned businesses

Loan recipients are required to follow the six good faith efforts whenever procuring construction, equipment, services, and supplies with this funding. 

Davis Bacon Act: The Davis-Bacon Act applies to construction, alteration, and repair contracts and sub-contracts awarded with EPA grant funds. For cleanup activities funded through the BCLP, recent and applicable wage rates from the U.S. Department of Labor must be incorporated into construction, alteration, and repair (including painting and decorating) solicitation and contracts. For more information visit the Department of Labor’s website.

ESA and NHPA: To comply with the Endangered Species Act (ESA) and National Historic Preservation Act (NHPA), Department of Economic Development will provide EPA the following information obtained during Phase 1 Site Assessments: location of a project, any threatened or endangered species or habitat which may be affected by a project, whether the site is considered to be of concern by the State Historic Preservation officer, and a list of Tribes who may believe your site or project could disturb cultural resources.

Quality Assurance and Health and Safety Plans: On sites cleaned up with program funding, site specific Quality Assurance Project Plans (QAPP) will be prepared and submitted to EPA for review and concurrence.  Also, an OSHA-compliant Health and Safety Plan will be prepared and followed; a copy of the plan will be placed in the cooperative agreement file. Loan recipients will be required to hire a qualified environmental consultant to perform this task.   

Confirmation Sampling: A qualified environmental consultant hired by loan recipient will perform sampling activities in support of the cleanup or to confirm cleanup standards have been met. Quality Assurance Project Plans will be submitted to EPA for approval. 

Final Cleanup Report: After the cleanup is performed, the qualified environmental consultant hired by the loan recipient will prepare a final report or other documentation that shows cleanup is complete and meets the cleanup standards identified in the Cleanup Action Memo or Report, and that any required institutional, land use or engineering controls are in place.

The application and more information is available below: 

Brownfields Cleanup Loan Program: METCO Policy
METCO Loan Application: Brownfields Cleanup Loan Program
Brownfield Cleanup Loan Program Eligibility Checklist

Contact Sara Ellis, Brownfields Project Manager, at 502-574-1569 or email for more information. 

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