Brownfield Redevelopment and Environmental Justice

A Preliminary Equity Analysis of Remediation Programs in Minneapolis/Saint Paul

March 2nd, 2021

Evan Davis


At face value, the cleanup of post-industrial blight seems like a worthwhile project. Many of these hazardous waste sites have been forsaken by government regulation and public financing for decades. If developers, planners, and policymakers carefully construct remediation and development projects, brownfield cleanup and renewal could be a step towards rectifying years of discrimination, exclusion, and cumulative toxic exposure in poor communities and communities of color. However, the advantages of urban revitalization projects such as brownfield redevelopment are far from unconditional. If brownfield redevelopment continues down a path of relying on market-based mechanisms and a universal application of environmental justice, it risks becoming another toxic cycle of development that perpetuates environmental inequities and green gentrification. This project brings the related topics of brownfield redevelopment and environmental justice into conversation and offers a preliminary analysis of efforts in the state of Minnesota. I aim to raise questions about the viability of brownfield redevelopment as a corrective tool for the disproportionate siting of brownfields and waste sites in low income neighborhoods and communities of color.

If the embedded link below is inaccessible or improperly formatted you can view the interactive dashboard here


The Minnesota Pollution Control Agency (MPCA) oversees the Voluntary Investigation and Cleanup (VIC) program and Petroleum Brownfields (PB) program. MPCA provides liability assurances and technical assistance in the assessment, cleanup, and redevelopment of brownfields. Minnesota Department of Employment and Economic Development (DEED) administers the Contamination Cleanup & Investigation Grant Program. DEED ranks prospective developer applications based on the following criteria:

  • Potential increase in the property tax base - 15 points

  • The social value to the community (Number of new jobs, removal of blight, likelihood of project completion, etc.) - 75 points

  • MPCA review of the reduction of threats to human health and the environment due to cleanup - 25 points

  • Probability of site cleanup without government intervention - 15 points

  • Cleanup costs for the site - 10 points

  • Local resources available for cleanup costs - 5 points


Minnesota Analysis - Since Environmental Justice (EJ) Areas contain a disproportionate amount of brownfields, it makes sense that we see an outsized percent of the total funding going to these jurisdictions statewide. The minimal funding flowing to Racially Concentrated Areas of Affluence (RCAA) is consistent with the environmental justice approach. However, a more granular analysis is necessary due to the concentration of sites and projects in the Twin Cities.

Twin Cities Analysis - There is a degree of disproportionality in the Twin Cities area since EJ tracts have a greater share of the brownfields and a lower share of the total funding. There is also evidence of differences between low-income EJ areas, and low-income EJ areas with higher populations of people of color. Two of the three areas that received $5,000,000 or more in grant funding were only low-income and did not have communities of 50 percent or more people of color.

Fragmentation - The state remediation program is regulated in part by MPCA and grant funded by DEED. Thus we often see an inconsistent application of departmental goals and interagency coordination. For example, MPCA holds "fair treatment" and "meaningful involvement" clauses in their environmental justice framework. These are, however, sometimes at odds with DEED's aims of workforce recruitment, business retention, and economic development.

Data Accessibility - MPCA has address information for all registered brownfield sites. However, the DEED dataset only contains the grantee, the project name, and the award amount. The project names are different in each of the datasets, making data interpolation a cumbersome and imprecise process. DEED does not collect geographic data because projects frequently change or have an indeterminate scope. This poses considerable empirical challenges that limit the ability to perform multivariate regression, rigorous geospatial mapping, or other quantitative analyses.

Questions for Further Investigation

  • How do these findings vary at different spatial and jurisdictional levels?

  • What are the cumulative impacts of brownfield exposure?

  • What are the standards for the quality of brownfield remediation? Which policy mechanisms can induce equitable brownfield remediation?

  • Are there correlations between brownfield redevelopment and gentrification?

  • Which sites get cleaned up first?

  • Which sites have expedited timelines?

  • Who gets to decide these questions and to what extent do the projects involve the affected communities?


This data was gathered through a variety of crowd sourcing, web scraping, and interviews. Thus, it is inherently incomplete. While there is some data from 2000, most of the records are projects funded during the 2018, 2019, and 2020 grant cycles.

EJ Area - MPCA defines an Environmental Justice Area as a census tract that meets one of the following criteria: Greater than or equal to 50% residents of color Greater than or equal to 40% residents at or below 185% of the Federal Poverty Guidelines Federally recognized Tribal area

RCAA - Goetz, Damiano, & Williams (2019) define a racially concentrated area of affluence as a census tract that meets both of the following criteria: Greater than or equal to 80% white residents Median household income greater than or equal to $125,000

Reference List