Brownfields Redevelopment Framework - Comparison Between The US and Singapore

BROWNFIELDS REDEVELOPMENT FRAMEWORK:
THE U.S. AND SINGAPORE
LIM KOK CHING

(BBA (Hons.), NUS, MBA, UC Berkeley)
A DISSERTATION SUBMITTED FOR THE DEGREE OF

MASTER OF SCIENCE
(ENVIRONMENTAL MANAGEMENT)
SCHOOL OF DESIGN AND ENVIRONMENT

NATIONAL UNIVERSITY OF SINGAPORE
2013/2014
Declaration
I hereby declare that this thesis is my original work and it has been written by me in
its entirety.
I have duly acknowledged all the sources of information which have been used in the
thesis.
This thesis has also not been submitted for any degree in any university previously.
_______________
Lim Kok Ching
5 February 2014
Table of Contents
ABSTRACT....................................................................................................................i
ACKNOWLEDGEMENT ............................................................................................ ii
LIST OF ABBREVIATIONS...................................................................................... iii
LIST OF APPENDIXES ...............................................................................................v
LIST OF FIGURES ......................................................................................................vi
LIST OF TABLES...................................................................................................... vii
CHAPTER 1: INTRODUCTION .................................................................................1
1.1 Background ..................................................................................................................... 1
1.2 Singapore Context ........................................................................................................... 5
1.2.1 Economy .................................................................................................................. 5
1.2.2 Land Use .................................................................................................................. 6
1.3 Potential Risks of Brownfields........................................................................................ 8
1.4 Research Intent ................................................................................................................ 9
CHAPTER 2: LITERATURE REVIEW ....................................................................10

2.1 Definition of Brownfields ............................................................................................. 10
2.2 Policy Transfer and Lesson-Drawing............................................................................ 16
2.2.1 What is Policy Transfer?........................................................................................ 16
2.2.2 What is Lesson-Drawing?...................................................................................... 19
2.2.3 Section Conclusion ................................................................................................ 20
2.3 Brownfields Redevelopment Framework...................................................................... 20
2.3.1 CABERNET Conceptual Models .......................................................................... 21
2.3.2 De Sousa Framework ............................................................................................. 25
2.3.3 Luo, Catney and Lerner Framework ...................................................................... 25
2.3.4 CCLR-Lim Framework.......................................................................................... 26
2.3.5 Section Conclusion ................................................................................................ 39
CHAPTER 3: RESEARCH METHODOLOGY ........................................................41

3.1 Research Design ............................................................................................................ 41
3.1.1 Theoretical Development Stage ............................................................................. 42
3.1.2 Field Research Stage.............................................................................................. 44
3.1.3 Conclusions Stage .................................................................................................. 45
3.2 Research Methodology.................................................................................................. 45
3.2.1 Comparative Method ............................................................................................. 45
3.2.2 Primary and Secondary Sources ............................................................................ 46
3.2.3 Expert Interviews ................................................................................................... 46
CHAPTER 4: THE U.S. FRAMEWORK ..................................................................48

4.1 Overview ....................................................................................................................... 48
4.2 Principles in the U.S...................................................................................................... 51
4.3 Brownfield Site Dynamics in the U.S. .......................................................................... 54
4.4 Oversight Agencies in the U.S. ..................................................................................... 55
4.5 Contaminant Framework in the U.S.............................................................................. 57
4.6 Legislation and Liability Framework in the U.S........................................................... 58
4.7 Site Due Diligence Options in the U.S.......................................................................... 60
4.8 Risk Control Strategies in the U.S................................................................................. 62
4.9 Funding Sources in the U.S........................................................................................... 65

4.10 Further Discussions ..................................................................................................... 69
CHAPTER 5: THE SINGAPORE FRAMEWORK ...................................................71

5.1 Overview ....................................................................................................................... 71
5.2 Principles in Singapore.................................................................................................. 74
5.3 Brownfield Site Dynamics in Singapore ....................................................................... 75
5.4 Oversight Agencies in Singapore .................................................................................. 76
5.5 Contaminant Framework in Singapore.......................................................................... 78
5.6 Legislation and Liability Framework in Singapore....................................................... 79
5.7 Site Due Diligence Options in Singapore...................................................................... 80
5.8 Risk Control Strategies in Singapore ............................................................................ 81
5.9 Funding Sources in Singapore....................................................................................... 81
5.10 Chapter Conclusion ..................................................................................................... 82
CHAPTER 6: FURTHER DISCUSSIONS ................................................................83

6.1 Principles ....................................................................................................................... 83
6.2 Brownfield Site Dynamics ............................................................................................ 85
6.3 Oversight Agencies ....................................................................................................... 85
6.4 Contaminant Framework............................................................................................... 87
6.5 Legislation and Liability Framework ............................................................................ 88
6.6 Site Due Diligence Options........................................................................................... 89
6.7 Risk Control Strategies.................................................................................................. 91
6.8 Public/Private Funding Sources .................................................................................... 92
6.9 Chapter Conclusion ....................................................................................................... 92
CHAPTER 7: CONCLUSION AND RECOMMENDATIONS ................................94

7.1 Conclusion..................................................................................................................... 94
7.2 Recommendations ......................................................................................................... 96
7.3 Research Limitations................................................................................................... 101
7.4 Future Research Directions ......................................................................................... 103

(19,803 words)

ABSTRACT
Brownfield refers to real estate whose expansion, redevelopment, or reuse could be
complicated by actual or potential presence of pollutants or contaminants (U.S. EPA
2002). Brownfields redevelopment framework is the eco-system that supports
effective recycling of potentially contaminated land through optimizing three
dimensions, namely, public health and safety, community participation, and economic
potential. The United States of America (the U.S.) is the leader in brownfields policy
innovations: it introduced the worlds first legislation targeted at cleaning up
contaminated industrial sites, known as CERCLA or Superfund, in 1980. On the
other hand, Singapore is a relatively new nation and can learn from other countries
approaches to managing potentially contaminated land resources.
This paper uses the CCLR-Lim Brownfields Redevelopment Framework to compare
the differences between the U.S. and Singapore. The comparative study examines
eight components of the framework for both countries: Principles, Brownfield Site
Dynamics, Oversight Agencies, Contaminant Framework, Legislation and Liability
Framework, Site Due Diligence Options, Risk Control Strategies, and Public/Private
Funding Sources.
The study concludes that the U.S. brownfields redevelopment framework is
sophisticated and multi-dimensional in orientation, and is effective in addressing
diverse concerns from multiple stakeholders, including communities and property
developers. Singapore can learn from the U.S. in several areas. Possible policy
transfers include the adoption of key environmental principles such as Environmental
Justice and Right-to-Know Principle into Singapores environmental legislative and
bureaucratic system.
(225 words)
ACKNOWLEDGEMENT
I would like to thank Dr Malone-Lee for her comments and opinions that helped
shape the direction of this paper, and all the experts, officers from NEA, SLA, PUB,
and URA, who contributed their experiences and knowledge. I would like to express
my gratitude to Mr Rick Reidinger, NUS Lecturer and CEO of Eco Special Waste
Management, and Mr Benny Lim, Permanent Secretary of MND, for their help in the
process. This study would not be possible without their patience and assistance.
ii
LIST OF ABBREVIATIONS
ARAR
A*STAR
ASTM
BCA
BERI
BLRA
BP
BRERA
BTSC
CAA
CABERNET
Cal
CCL
CCLR
CEQA
CERCLA
CIA
CLERRA
CLRRA
COBRAMAN
COE
COPPC
CPCFA
CWA
DTSC
EBS
EIR
EJ
EPCRA
EPHA
EPMA
ERDU
ESA I
ESA II
GDP
GST
HCD
HDB
JTC
LAG
LSA
LUDA
Applicable and/or Relevant and Appropriate Requirements

Agency for Science, Technology, and Research
American Society for Testing and Materials
Building and Construction Authority
Brownfield European Regeneration Initiative
Baseline Risk Assessment
British Petroleum
Brownfields Revitalization and Environmental Restoration Act
of 2001
Brownfields and Land Revitalization Technology Support Center
Clean Air Act
Concerted Action for Brownfield and Economic Regeneration
Network
California
Contaminant Candidate List
Center for Creative Land Recycling
California Environmental Quality Act
Comprehensive Environmental Response, Compensation, and
Liability Act of 1980
Central Intelligence Agency
California Land Environmental Restoration and Reuse Act
California Land Reuse and Revitalization Act of 2004
Manager Coordinating Brownfield Redevelopment Activities
Certificate of Entitlement
Code of Practice on Pollution Control
California Pollution Control Financing Authority
Clean Water Act of 1972
Department of Toxic Substances Control
Environmental Baseline Study
Environmental Impact Report
Environmental Justice
Emergency Planning and Community Right-to-Know Act of
1986
Environmental Public Health Act, Cap. 95
Environmental Protection and Management Act, Cap. 94
European Regional Development Fund
Environmental Site Assessment Phase 1
Environmental Site Assessment Phase 2
Gross Domestic Product
Goods and Services Tax
Housing and Community Development
Housing Development Board
JTC Corporation
Local Action Group
Limited Site Assessment
Large Urban Distress Area
iii
MCL
MOH
MPA
MRT
N.A.
NEA
NFA
NRF
OBLR
OSWER
PEA
PPA
PUB
RCRA
RSL
RWQCB
SDWA
SL
SLA
SVOC
SWQCB
The Corps
U.K.
U.S.
U.S. DOT
U.S. EDA
U.S. EPA
U.S. GPO
U.S. HUD
UST
URA
VCP
VOC
WHO
Maximum Contaminant Level

Ministry of Health
Marine Port Authority
Mass Rapid Transit
Not Available
National Environment Agency
No Further Action
National Research Foundation
Office of Brownfields and Land Revitalization
Office of Solid Waste and Emergence Response
Preliminary Endangerment Assessment
Prospective Purchaser Agreements
Public Utilities Board
Resource Conservation and Recovery Act of 1976
Regional Screening Level
Regional Water Quality Control Board
Safe Drinking Water Act of 1974
Screening Level
Singapore Land Authority
Semi-Volatile Organic Compound
State Water Quality Control Board
U.S. Army Corps of Engineers
United Kingdom
United States of America
U.S. Department of Transportation
U.S. Department of Commerce, Economic Development
Administration
U.S. Environmental Protection Agency
U.S. Government Printing Office
U.S. Department of Housing and Urban Development
Underground Storage Tanks
Urban Redevelopment Authority
Voluntary Cleanup Program
Volatile Organic Compound
World Health Organization
iv
LIST OF APPENDIXES
Appendix 1:
List of Brownfield Projects in Europe
Appendix 2:
Singapore Land Use Master Plan 2003 & 2008
Appendix 3:
Brownfield Definitions by European Countries
Appendix 4:
Selected Variations in State Definitions of Brownfields

(the U.S.)
Appendix 5:
The U.S. EPA Brownfields Definition (Legal)
Appendix 6:
Initial Fact Finding Forum and Initial Discussion with

Experts
Appendix 7:
Expert Interviews
Appendix 8:
Interview Questionnaires
LIST OF FIGURES
Page
Figure 1:
CABERNET Bath Model
22
Figure 2:
ABC Model
23
Figure 3:
Land Use Puzzle Model
24
Figure 4:
CCLR-Lim Framework
28
Figure 5:
Research Design
42
Figure 6:
The U.S. Brownfields Redevelopment Framework
50
Figure 7:
Singapore Brownfields Redevelopment Framework
73
vi
LIST OF TABLES
Page
Table 1:
Comparison of the U.S. Definitions against Landuse Lifecycle

Stages
Table 2:
Brownfield Site Dynamics Equation
30
Table 3:
The U.S. Brownfield Site Dynamics
54
Table 4:
Singapore Brownfield Site Dynamics
75
Table 5:
Comparison of Oversight Agencies
86
Table 6:
Comparison of Contaminant Framework
87
Table 7:
Comparison of Legislation and Liability Framework
88
Table 8:
Comparison of Site Due Diligence Options
90
Table 9:
Comparison of Risk Control Strategies
91
Table 10:
Comparison of Funding Sources
92
vii
CHAPTER 1
INTRODUCTION
1.1 Background
When Adam Smith (1776) wrote his classic text The Wealth of Nations, he modeled the
real wealth of a nation into three connected aggregates: Land + Labor + Stock (sometimes
known as Capital or Savings)1. The quantity and quality of each factor has a direct bearing
to the wellbeing of a nation, and these three aggregates of wealth interact in a multitude of
permutations and exert influence on each other. There exists an intimate relationship
between land and labor: when one is impaired, the other will also be adversely affected.
In other words, when land is contaminated, labor suffers both a loss of material wellbeing
and physical health (Stehr-Green and Lybarger 1989). It is therefore unfortunate that as
countries develop their economies and industrializations ensued, lands frequently get
polluted by hazardous materials that were discharged as waste by industries.
The notion that contaminated lands, sometimes known as brownfields, should be cleaned
up to protect the publics wellbeing did not gain recognition until the later part of the
twentieth century. For example, although the United Kingdom (U.K.) is the worlds first
industrialized nation as a result of the Industrial Revolution in the 1760 to 1840, its
legislation did not adequately address this issue until the creation of the land use planning
system to deal with contaminated non-agricultural land in 1947 and the establishment of
its first centralized institutional mechanism in 1976, the Inter-Departmental Committee on
the Redevelopment of Contaminated Land (Berlanstein 1992; Henneberry, et al. 2005).
An Inquiry into the Nature and Causes of the Wealth of Nations was originally published in 1776. Quotes
in this research are based on the New York Bantam version (2003), which is based on the fifth edition as
edited and annotated by Edwin Canna (1904). Smiths work lays out the foundations of modern economics,
where land quality is considered a key driver for productivity.
Similarly, while the United States of America (U.S.) achieved rapid economic growth in
the last two decades (1910-1930) of the Second Industrial Revolution, and consequently
created huge inventory of brownfields, concerns about cleaning up these contaminated
sites only picked up momentum after pollution disasters such as the Love Canal dumpsite
seized the U.S. publics attention with media headlines in 1978 (Vatter, Walker, and
Alperovitz 1995; Francis 1978). The Love Canal site was subsequently declared a Federal
Emergency site by then U.S. President, Jimmy Carter, in May 1980 (Ecumenical Task
Force of the Niagara Frontier Records 1980). Following this Love Canal environmental
crisis, the U.S. Federal Government found that though several federal environmental
statutes did exist, including the Clean Water Act of 1972 (CWA) and The Resource
Conservation and Recovery Act of 1976 (RCRA), these laws were not enough to address
the problem. Seeking to obtain authority to act on hazardous waste sites, the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
Superfund legislation, hereafter known as CERCLA, was passed in December 1980
(U.S. Senate 2002a). The U.S. Environmental Protection Agency, hereafter referred to as
U.S. EPA, was appointed as the lead agency.
In essence, the gravity of the adverse impacts of brownfields on public health and
community was fully recognized by the U.S. at the federal level only after several decades
of free pollution by the industrial sector. The toxic materials in Love Canal were buried
for over three to four decades before remediation was conducted.
These precedents are not encouraging examples for urban planners who are often tasked
with building a sustainable city and responsible for the welfare and health of the residents.
This aspect of planners responsibility2 can be examined by looking into the description of
urban planning by the American Planning Association:
Planning, also called urban planning or city and regional planning, is a dynamic
profession that works to improve the welfare of people and their communities by
creating more convenient, equitable, healthful, efficient, and attractive places for present
and future generations. (American Planning Association 2013) [Bolded words are
authors own emphasis]
Several public health practitioners also noted that the disciplines of public health and
urban planning have begun to integrate over the past two decades (Kochtitzky, et al. 2006).
Examples include incorporating better transportation planning to improve air quality in the
community and setting up parks to encourage physical activity for residents. Kochtitzky,
et al. (2006) further proposed that a renewed integration between urban planning and
public healthcare is fundamental to revitalizing the health of the people and land.
If the rhetoric from public health professionals were accepted as sound, it then follows
logically that brownfields redevelopment should be a key topic for urban planners to
examine, if they have not already done so. The stakes are high to the local communities
and the surrounding region to correctly identify risky sites, clean them up, and redevelop
them in a balanced manner.
Given the benefits of revitalizing contaminated land, it is therefore not surprising that
global interests on brownfields redevelopment has increased enormously over the past two
decades.
It should be noted that planners are part of the team within the broader government devices to
deliver better quality of life to residents. As such, the responsibility is shared among several
professions including health service providers and policing officers.
3
In Europe, the European Regional Development Fund, hereafter referred to as ERDU,

sponsored several collaborative projects to investigate various aspects of brownfields
topics. Projects such as the Brownfield European Regeneration Initiative (BERI)3,
Concerted Action for Brownfield and Economic Regeneration Network (CABERNET)4,
and Large Urban Distress Area (LUDA)5 devoted substantial resources to the study and
improvement of brownfields policies, processes, and conceptual models. Appendix 1
shows a list of ERDU projects on Central European initiatives, as compiled by the
Manager Coordinating Brownfield Redevelopment Activities, hereafter known as
COBRAMAN (ERDU 2009).
As noted, industrial activities usually, though not always, entail contamination of the land,
especially when there is no legislation governing the actions of business interests. One
reason for this is the difference in alignment of material interests between the industrialists
and the public. Adam Smith (1776) wrote about the tendency for industrialists to band
together and act against public interests:
People of the same trade seldom meet together, even for merriment or diversion, but the
conversation ends in a conspiracy against the public, or in some contrivance to raise
price. (Smith 1776, Book 1, Chapter X, Part II: Inequalities Occasioned by the Policy of Europe,
p. 177)
In general, governments with weak legislative and policy frameworks are less effective in
responding to deviant industrial actions within a reasonable timeframe. To address this
legislation and policy gap, forward-looking governments around the world are investing

3
BERI is a project launched between 2004 and 2007 to investigate methods and approaches to promote
holistic brownfield development as an integral component of sustainable development.
4
CABERNET is a project lead by University of Nottingham, US, between 2002 and 2005. It is a
multidisciplinary network with six expert groups to investigate conceptual models for brownfield issues
and to coordinate research across sectors and countries.
5
LUDA is a project launched in Germany, between 2004 and 2008, to address the issue of quality of life in
large distressed areas by providing strategic planning services. Another of its aim is to help planners and
politicians to understand the complex problems and potentials of brownfields.
resources into studying the How, Who, What, Where, When, and Why questions
regarding brownfields redevelopment. There are several useful lessons that Singapore can
learn from studying global trends in brownfields redevelopment to better manage its
limited land resources.
1.2 Singapore Context

Singapore, located at the southern tip of Peninsular of Malaysia, was founded in 1819 as a
British colony. Singapore joined the Malaysian Federation in 1963 but separated from it
two years later and declared independence on August 9, 1965. The city-state has a
population of 5.3 million in 2012 (Department of Statistics 2012), and total land area of
716.1 km2 (Department of Statistics Singapore 2013). The Central Intelligence Agency
(CIA) World Factbook 2009 listed some current environmental issues that Singapore
faced, including industrial pollution, limited natural freshwater resources, limited land
availability and waste disposal problems (CIA 2009).
1.2.1 Economy
Singapores GDP (Constant 2000 U.S. Dollars6) was US$16.2 billion in 1976 and
US$173.8 billion in 2011, a phenomenal 10.7 multiple increment over three and a half
decades (World Bank 2013). GDP per capita was US$7,082 in 1976 and US$33,529 in
2011, a 4.7 multiple increment over the same period. The CIA World Factbook ranked
Singapore at the 26th place in the Distribution of Family Income GINI Index ranking
(CIA 2012).
All GDP data quoted are in constant 2000 US$ to account for the effects of inflation.
Proportion of industrial value-add (including manufacturing activities) accounted for

33.1% and 26.6% of total GDP in 1976 and 2011 respectively (World Bank 2013). This
means that industrial value-add contributed US$5.36 billion to GDP in 1976, and
contributed US$46.23 billion in 2011. In other words, industrial activities increased by 8.6
times over the period. A large increment in industrial activities could lead to an increased
risk of pollution. It should also be noted that pollutions caused by going-concern
industrial activities usually occur repetitively on the same plot of land, and could be
cumulative. Over time, the varieties and concentration levels of hazardous materials could
accumulate and multiply.
1.2.2 Land Use

Appendix 2 shows the Singapore Land Use Master Plan for 2003 and 2008, as provided by
Urban Redevelopment Authority (2013a), hereafter known as URA. As observed, the
2008 plan zoned portions of the Northeastern part of Singapore from Business 1 to
Business 2. According to Singapores Zoning Interpretations (URA 2013b), Business 1
uses are for light industries such as computer software development, printing and
publishing, and computer hardware and electronics equipments. Business 2 uses allow
more pollutive industrial activities that include vehicle repair, industry and power
generation plants, and gas installations.
JTC Corporation, hereafter known as JTC, is the lead agency in Singapore for preparing
land for industrial uses, and has been performing this role since its incorporation in 1968.
In 2003, total stock of industrial land was 5,102 hectares, equivalent to 5,102,000 m2 (JTC
2004). In 2012, the total amount of prepared land was 6,374.2 hectares, an increment of
25% over 9 years (JTC 2013). 6,374.2 hectares represents 9.14% of Singapores total land
area. JTC supplies between 100 hectares to 500 hectares of prepared industrial land per
year, variations dependent on market demand and supply. Oil and chemical companies are
the biggest customers for JTC, with Jurong Island as the main hub for oil refinery and
chemical processing plants.
As with all commercial products, industrial land goes through a life cycle. From
greenfields, land parcels are prepared for use. This is followed by usage, of which the
rights-of-use is facilitated via leasing or sale of land to the industrial operator. When the
lease expires or when there is a change in developmental use, the land has to be cleaned up
or prepared for its next intended use.
In essence, land lifecycle can be described in the following stages:

a. Greenfields
b. Prepared land
c. Usage
d. Current Usage ended. Land abandoned, idled, or there is change in developmental
use
e. Clean up and preparation
f. New Usage
The cycle reiterates as long as there is need for land reuse. From a brownfield
management perspective, the Cabernet Bath Model (at Section 2.3.1.1) provides an
alternative perspective to analyzing the flow of brownfield creation and cleanup.
1.3 Potential Risks of Brownfields

Brownfields, sometimes referred to as contaminated, derelict, or abandoned lands, are
known to have adverse health impacts on human if contamination is real. A report by the
U.S. EPA (2012a, p. 3-4) cited carcinogenicity, reproductive impacts, infant effects,
neurotoxicity, and endocrine disruption as some adverse effects of industrial contaminants.
Sites with land uses such as petroleum refineries, power generation plants, chemical
factories, car repairs, petrol kiosks, dry-cleaning shops, and bus/train depots are known to
have high concentrations of industrial chemical such as arsenic, dioxin, mercury, and other
carcinogenic compounds. Prolonged, chronic, or over-exposure to such carcinogenic
compounds are known to lead to higher cancer risks, according to U.S. EPA research and
studies (U.S. EPA 2012a).
Contaminations on brownfields are often not static and tend to migrate to surrounding land
parcels via groundwater pathways. If the contaminant is dust-like, such as dioxin7 dusts, it
flows with air and affects the residents respiratory system. Petrol kiosks with
Underground Storage Tanks (UST) tend to contaminate groundwater with petroleum
hydrocarbons and metalloids, which migrate along with groundwater or in vapor form.
Prevailing scientific understanding is that contaminants follow a source migration path
receptor model. Therefore a residential land parcel near a petrol kiosk is not immune
from petro-chemical pollution. Children are especially susceptible to such contaminants.
Concerns about the adverse impacts of brownfields on health and safety and potential
economic opportunities led developed countries such as the U.S., the U.K., and Canada to
invest heavily into researching this subject. See Appendix 1 for a list of past and present

7
Dioxins are known carcinogens and the recommended exposure by U.S. EPA on human is 0 ppm.
brownfield research projects in Europe. In comparison, brownfield research is relatively

new to Singapore. Searches for research papers and literatures on Singapore brownfields
issues turned out limited entries. There exists several research opportunities in this subject
for Singapore.
1.4 Research Intent

This paper intends to scan, investigate, and understand Singapores current brownfields
redevelopment framework. A case country would be chosen for lesson learning. Based on
the findings, recommendations to Singapores brownfields framework components would
be proposed.
This research intent would be achieved by answering the following questions:

1. What are brownfields?
2. What is a comprehensive brownfields redevelopment framework?
3. What is Singapores current situation?
4. What are Singapore frameworks strengths and weaknesses?
5. What can we learn from others?
6. What can be improved to provide a safer environment for Singapores population?
CHAPTER 2
LITERATURE REVIEW
2.1 Definition of Brownfields
Brownfields redevelopment is a multidisciplinary and complex subject whose concerns cut
across several domains such as environmental, economic, public health, public policy, land
use planning, and legislature. It also affects numerous stakeholders including policy
makers, land owners, land use planners, businessmen, community, and the users of the
land concerned. Due to its complex nature, different countries employ different definitions
according to their unique regulatory framework and legacy.
Appendix 3 shows a list of brownfields definitions used by European countries (Oliver, et

al. 2005, p. 20). As observed, definitions range from no formal definition in Austria,
Finland, and Sweden, no information in Greece, Hungary, Portugal, and Slovak
Republic, derelict land in Ireland, to contaminated site in Bulgaria, Italy. Other forms
of descriptions such as abandoned, vacant land, and inner city land not under use
also exist.
Even within the U.S., the leader in toxicology research and brownfields domain, a number
of different definitions are used in practice at federal, state, and local levels. The U.S.
EPA itself has two versions of definitions that are slightly different: the first definition
was introduced as part of the Brownfields Action Agenda in January of 1995, hereafter
referred to as the Old Definition, which defined brownfields as:
abandoned, idled, or under-used industrial and commercial facilities where expansion
or redevelopment is complicated by real or perceived environmental contamination. (U.S.
EPA, 1995)
10
This Old Definition was widely used for several years, and could still be found on
published periodicals or brochures under the auspices of Resource Conservation and
Recovery Act of 1976 (U.S. EPA 2012b; U.S. Senate 2002b).
A refined definition was adopted by U.S. EPA under the Brownfields Revitalization and
Environmental Restoration Act of 2001, hereafter known as BRERA Definition (U.S.
Senate 2001):
The term brownfield site means real property, the expansion, redevelopment, or reuse of
which may be complicated by the presence or potential presence of a hazardous substance,
pollutant, or contaminant (U.S. Senate 2001, p. 6)
There are two main conceptual differences between the Old Definition and BRERA
Definition. First, BRERA Definition includes land in current usage as brownfield sites if
there is presence or potential presence of contaminants. The Old Definition only
includes those abandoned, idled, or under-used land parcels. Second, BRERA
Definitions choice of noun real property could be interpreted as referring to all land
uses, including agricultural and residential uses, as potential brownfield sites if there is
presence or potential presence of contaminants. The Old Definition refers to only
industrial and commercial facilities as possible brownfields.
The table below compares the two definitions:
Table 1: Comparison of the U.S. Definitions against Landuse Lifecycle Stages

Lifecycle Stages
Old Definition
BRERA Definition
a. Greenfield
Excluded
Excluded
b. Prepared land
Excluded
Excluded
c. Usage Stage
Excluded
Included (all land uses, as
11
long as there is potential

presence of contaminants)
d. Current Usage Ended.
Included (but only for land
Land abandoned, idled,
with prior industrial or
underused, or there is
commercial use)
Included
change in Developmental
Use.
e. Clean up and Preparation
Included
Included
f. New Usage
Excluded
Included
Source: Authors Work 2013
The U.S. EPA has updated its website and adopted the BRERA version as the standard of
reference. This paper adopts the BRERA Definition as representative of the U.S. EPA
official definition. However, not all U.S. government departments have updated and
standardized their brownfields definition as of 2013. Appendix 4 shows a selected list of
the working definitions in the US at different localities and levels of the government.
The proliferation of definitions in Europe (see Appendix 3) and the U.S. epitomizes the
complex nature of brownfields redevelopment issues: multiple disciplines, stakeholders,
objectives (often conflicting), technological remediation routes (some better than others),
land use options, and ethical principles. In essence, too many moving parts make finding
an optimal solution difficult.
This paper attempts to approach this challenge in a logical and thoughtful way, and the
first step is to anchor the framework by defining brownfields. The following discussion
reviews Yount and Alker, et als propositions on the appropriate brownfields definition.
12
Yount (2003) contends that two levels of definitions are needed: a conceptual definition
that is broad, universally agreed upon and a working definition that specifies program
eligibility qualifications (Yount 2003, pp. 25-26). The conceptual definition should
contain terms that are unambiguous, and should allow policy makers and practitioners
wide latitude in addressing the dual nature of brownfields as both environmental and
economic problems, while the working definition would allow customized addition or
exclusion clauses to meet the specific objectives of the program administrator.
Yount (2003, p. 30) further argued that the best definition that exists is the U.S. EPAs
BRERA Definition. It is superior because of several reasons, chief among them are: one,
it includes current usage and is important to environmental justice. Two, it does not refer
to previous property use, and hence is inclusive of problematic sites such as agricultural
land contaminated by pesticides. Three, it does not specify the classes of contaminants
and is inclusive to new and emerging classes of contaminants such as endocrine disruptors.
Alker, et al., (1999), however, made two different argument. Firstly, they argued that the
U.S. EPA definition is flawed in that it implies that all brownfield is contaminated, which
is not the case (Alker, et al. 1999, p. 52). It should be pointed out that in this case, Alker,
et al.s understanding of U.S. EPA definition is misguided, because the U.S. EPA
definition includes lands that may be contaminated. It therefore includes lands that are
actually not contaminated but merely suspects. De Sousa (2001, p. 132) also interpreted
U.S. EPAs definitions as referring to both known and potentially contaminated sites. In
essence, Alker et al. were incorrect in their interpretation of the U.S. EPA definition.
13
Secondly, in lieu of the U.S. EPA definition, Alker, et al. (1999) proposed an alternative
universal definition:
A brownfield site is any land or premises which has previously been used or developed
and is not currently fully in use, although it may be partially occupied or utilized. It may
also be vacant, derelict or contaminated. Therefore a brownfield site is not available for
immediate use without intervention. (Alkers, et al. 1999, p. 64)
Analysis of this proposed universal definition showed that it excluded contaminated

lands that are in full use from the brownfields category. Under this definition, a land may
only be considered brownfields if it is not currently in use. This is, however, a flawed
proposition due to two reasons:
One, it goes against the concept of environmental justice because in-use contaminated sites
are not considered brownfields. Environmental Justice is defined by the U.S. EPA as:
The fair treatment of people of all races, cultures, incomes, and educational levels with
respect to the development and enforcement of environmental laws, regulations, and
policies. Fair treatment implies that no population should be forced to shoulder a
disproportionate share of exposure to the negative effects of pollution due to lack of
political or economic strength. (U.S. EPA, 2013a)
Application of Alker et al.s brownfields definition into practice would place

disproportionate health risks to the users of the land, usually the working class and the
surrounding community, who tend to be those lacking in political and economic strength,
and therefore contravenes the fair application of environmental justice.
Secondly, from a management perspective, the first step of setting up a brownfields

inventory database requires a scan of possible brownfields sites. Under Alkerss
14
definition, lands that are in full use are not subjected to investigation and hence it would
omit potentially problematic sites from sight.
Younts (2003) approach is therefore more reasonable and tackles the potential health
threats of contamination in a better way. Its proposed dual-level definition that
differentiates between conceptual and working definitions allows both the economic
potential and community engagement aspects of brownfields revitalization to be
addressed. Having given due considerations on the implications of the wordings, this
paper supports Younts contention that the U.S. EPA BRERA Definition of brownfields is
superior:
The term brownfield site means real property, the expansion, redevelopment, or reuse of
which may be complicated by the presence or potential presence of a hazardous substance,
pollutant, or contaminant (U.S. Senate 2001)
This definition elevated the perspective on brownfields from a simplistic public health
threat to one that embraces also the economic potential and community development
dimensions. The term real property, in addition to its inclusivity of multiple
developmental uses, also denotes the positioning of the brownfields as a part of the local
community and its role in enhancing economic wellbeing.
Henceforth, the U.S. EPA BRERA Definition shall be the standard definition for this
paper. The complete legal definition is attached in Appendix 5: U.S. EPA Brownfields
Definition (Legal).
15
2.2 Policy Transfer and Lesson-Drawing

The multidisciplinary and complex nature of brownfields redevelopment framework
means that neither the process of finding a solution nor the solution itself would be simple.
This paper is interested in learning more about the brownfields redevelopment framework
that exists in other countries and how Singapore can learn from those experiences. This
inquiry, however, is not limited to only the public policy domain: private parties such as
insurance providers, remediation service providers, and the bankers who bankroll the real
estate redevelopment are important actors. Investigations include those considerations that
can maximize the motivations for the various parties involved and also the possible
interactions that can happen when one variable changes status. In essence, the focus is in
emulating the entire eco-system instead of only the public policy domain.
The public policy domain, however, would remain an important aspect to this investigation
because it is the hub where all decisions and information exchange ultimately has to
converge. Therefore, this section will explore the theoretical foundation for policy transfer
and lesson drawing as a learning tool to investigate the public policy domain of the
brownfields redevelopment framework.
2.2.1 What is Policy Transfer?

Policy transfer is an area of policy analysis that:
seeks to make sense of a process or set of processes in which knowledge about
institutions, policies and delivery systems at one sector or level of government is used in
the development of institutions, policies or delivery systems at another sector or level of
governance (Evans 2006, p. 480).
16
Dolowitz and Marsh (1996, p. 349) identified seven elements of transfer: policy goals,
structure and content, policy instruments or administrative techniques, institutions,
ideologies, ideas, attitudes and concepts, and negative lessons. This implies that the
elements being transferred could be macro-level ideologies such as communism,
capitalism, or socialism or it could be very specific and detailed-level items such as
handbooks and manuals teaching government officials how to improve customer service.
This definition implies that policy transfer study theoretically covers the entire process of
initial evaluation, brainstorming, selection and amendments of policy, negotiation,
implementation, and post mortem operational activities.
There are also six main categories of actors who conduct policy transfer, although in any
specific case of transfer more than one category of actor is likely to be involved: elected
officials; political parties; bureaucrats/civil servants; pressure groups; policy
entrepreneurs/experts; and supra-national institutions (Dolowitz and Marsh 1996, p. 345).
The first four categories are fairly straightforward in who they are referred to. Policy
entrepreneurs, according to Paul Krugman (1994) in Paddling Prosperity, refers to
individuals who are not academics, are sponsors of particular intellectual positions or
frames that define for some policy area what is wrong and how it could be corrected. In an
entrepreneurial fashion, they promote and disseminate their favored policy solutions
(Rein and Winship 1997, p. 18). An alternative name is economic snake-oil salesman8,
depending on whose boat a person is on. Supra-national organizations refer to
international organizations such as World Health Organization or United Nations where
exchange of ideas and teachings are encouraged.

8
See Amazon.coms website, Book Description, Peddling Prosperity: Economic Sense and Nonsense in an
Age of Diminished Expectations, Seattle. [Online] Available at: http://www.amazon.com/PeddlingProsperity-Economic-DiminishedExpectations/dp/0393312925/ref=sr_1_1?ie=UTF8&qid=1362219021&sr=81&keywords=peddling+prosperity (Accessed March 2, 2013)
17
This list of six categories of actors, however, missed out one form of powerful player in
policy transfers: Corporations. As far back as the 17th century, the East India Company
was already instrumental in establishing government institutions and offering trainings and
knowledge to various colonies. This spreading of institutional experience counted as a
form of policy transfer, though much blood was shed in the process. More recently,
powerful corporations such as Halliburton9 and Academi10 have been keenly involved in
setting up military and security frameworks and institutions at war-torn countries such as
Iraq and Afghanistan.
Policy transfers can be voluntary or coercive. Dolowitz and Marsh (1996) classifies them
into three types: voluntary, direct coercive, indirect coercive. Voluntary transfer refers to
the process whereby policy makers are free to make choices according to their wants, and
this category includes motivations ranging from dissatisfaction with current policy results
to simply the inherent drive for perfection. Direct coercive transfer occurs when one
government forces another to adopt or implement a policy. Indirect coercive transfer,
according Bache and Taylor (2003, p. 281), can arise from a range of factors:
externalities, technological change, global economic pressures and international
consensus. In this regard, Hoberg (1991) identified geopolitical influence as a factor,
using American influence on Canadian environmental regulation as a prime example.
Halliburton is one of the worlds largest oilfield services companies with operations in more than 70
countries with over 60,000 employees in businesses ranging from oilfield exploration and production to
construction and homeland security contracting services.
10
Originally known as Blackwater Worldwide, followed by Blackwater USA, and later changed its name to
Xe Services LLC, and finally Academi. It is a private military and security contractor, currently one of the
largest contractors to the U.S. State Department.
18
2.2.2 What is Lesson-Drawing?

Lesson-drawing refers to the process whereby actors evaluate the circumstances of a
program and determine whether that program can be effectively transferred to another time
or space. Rose (1991, p. 7) defines lesson as an action oriented conclusion about a
program or programs in operation elsewhere; the setting can be another city, another state,
another nation or an organizations own past. It is a deliberate process of learning where
research is often involved.
Lesson-drawing, however, has a few features that distinguishes it from policy transfer:
one, it is much more specific and excludes those big ideas that create a paradigm shift
(Rose 1991, p. 8), such as Keynesian revolution in economics and Green revolution in
environmental programs. Two, it is strictly voluntary. Three, Rose (1991) defined lessondrawing as an activity that is strictly not innovative. In this regard, policy transfer differs
from lesson-drawing because certain elements of innovation can happen in the process of
policy transfer11. ,
Rose (1991, p. 22) differentiates lesson drawing into five types: copying, emulation,
hybridization, synthesis, and inspiration. Copying refers to using practices elsewhere
wholesale. Emulation refers to adapting a certain program with some changes to fit into
the peculiar circumstances of a nation. Hybrid combines elements from programs in two
different places. Synthesis creates a distinctive program through combining elements from
programs in three or more places. Inspiration refers to using programs elsewhere as a form
of intellectual stimulus.

11
Based on Webster dictionarys definition of innovation: Introduction of something new into an

environment.
19
2.2.3 Section Conclusion

This paper does not use policy transfer and lesson-drawing interchangeably, because
while the two words have a lot of overlapping areas, there are also areas where the two
differ significantly. Similarly, researches on policy transfer sometimes appear under
different names, but point to a similar form of learning activity. For example, lessondrawing by Rose (1991) or Robertson (1991); comparative study by Wolman (1992);
influence by Hoberg (1991); or policy diffusion by Simmons and Elkins (2004) and
Meseguer (2005). In certain instances, policy transfer might be synonymous with
comparative study or lesson-drawing.
This paper uses policy transfer and lesson-drawing frameworks as learning guide for
Singapore through comparative study of other countrys brownfields eco-system.
2.3 Brownfields Redevelopment Framework

Oxford Dictionary defined framework as a basic structure underlying a system, concept,
or text. Brownfields redevelopment framework refers to the basic structure and
components underlying a network of inter-related programs or elements that facilitates
brownfields redevelopment activities.
A successful policy transfer or lesson drawing would not be possible without first
establishing a common or generic framework on which two different country or ecosystem could be compared against. In this section, we shall explore the essentials of a few
varieties of generic brownfields frameworks as developed by scholars and practitioners.
20
2.3.1 CABERNET Conceptual Models

Concerted Action for Brownfield and Economic Regeneration Network, hereafter referred
to as CABERNET12, is a multidisciplinary network of expert groups lead by the University
of Nottingham, United Kingdom (U.K.), to find new solutions for urban brownfield. The
group developed conceptual models to examine the underlying nature of brownfield
problems and attempt to describe the problems from stakeholders perspectives. These
models can be described as instructional in the principles of brownfields and are useful
philosophical guides for nations intending to approach their brownfields issues. Three
relevant models shall be discussed.
2.3.1.1 Cabernet Bath Model

The Cabernet Bath Model was developed to represent the dynamics of the system in the
context of urban land management (ERDU 2009, pp. 80-81).

12
See their website at: http://www.cabernet.org.uk/
21
Figure 1: Bath Model
It demonstrates that brownfields are a wider issue of land use and are constantly created
whenever industrial or pollutive activities are conducted. More importantly, this model
illustrates that the creation and cleaning activities of brownfields follow a lifecycle process
and flow. The rationale approach is to manage the cleanup process effectively so that the
problem does not get out of hand and overflows. This model also justifies setting up
country brownfields inventory database.
22
2.3.1.2 ABC Model

The ABC Model highlights the economic and funding aspects of brownfields
redevelopment (ERDU 2009, pp. 81-82).
Figure 2: ABC Model
The model classifies brownfields based on their economic value after taking into account
the remediation costs: Type A sites are usually taken up by profit seeking private
companies due to their high land value and lower remediation costs. Type B sites tend to
have correspondingly balanced risk and reward profile and are usually developed via a
public-private partnership. Type C sites are those that have lower land value relative to
their remediation costs and hence usually undertaken by a public agency.
The drawback to this model is that it assumed that all public funds are non-profit
motivated while all private funds are profit seeking. This assumption does not apply to
many countries as their governments could be more profit hungry than their private
23
enterprises. In such a profit driven political regime, those reserve sites would be
significantly under-developed.
2.3.1.3 Land Use Puzzle Model

The Land Use Puzzle Model shows the interconnected nature of brownfield with respected
to land development and the land use cycle (ERDU 2009, p. 83). The creation of
brownfields is part of the land use cycle and the challenge is in finding the right mix of
land use application to maximize the benefits of brownfields redevelopment.
Figure 3: Land Use Puzzle Model
The diagram above demonstrates that finding the optimal solutions to brownfields
redevelopment problems usually require moving several puzzle pieces. This model
highlights the importance of incorporating the land use planning aspect into the solution
equation for brownfields problems.
24
2.3.2 De Sousa Framework

De Sousa (2001) examined the brownfields redevelopment framework in Canada and
compared it against those of the US and Europe. He discussed five components in his
framework:
Regulatory Jurisdictional issues
Data sources
Clean-up criteria
Liability issues
Funding issues
De Sousa did not elaborate on the essences of the components, but discussed in details
about the weaknesses for Canada as compared to the US and Europe. He asserted that a
complex and uncertain regulatory system with variable policies, the lack of a systematic
and nation-wide approach to inventorizing brownfields, the confusing patch-works of
clean-up criteria, the uncertainty of liability issues, and the lack of formal federal
government funding programs for brownfields redevelopment hindered Canadian
brownfield redevelopment efforts.
2.3.3 Luo, Catney and Lerner Framework

Luo, Catney, and Lerner (2009) conducted a comparative study on the brownfields
framework between the U.K. and China, seeing this as an exercise for potentially useful
policy transfer for Chinas pollution problems. They identified four key components in a
framework:
Legislative and policy framework
Regulatory structure and capacity
25
Technical approaches
Incentives for reusing contaminated land.
In general, Luo, Catney and Lerner (2009) argued that Chinas environmental efforts are
not as effective as those of the U.K. They found that China has no dedicated legislative
and policy regime for contaminated land, though there exists legislation for water, air, and
agriculture. The government regulatory structure is also fragmented, with responsibilities
split across several departments. For technical approaches, site investigation and
environmental impact assessment are not required, and hence not a priority for developers.
Lastly, they found that no financial incentive schemes exist to stimulate remediation for
brownfields, unlike in the US where innovative funding schemes are offered.
2.3.4 CCLR-Lim Framework

Lim (2008) developed a generic model to describe the U.S. Brownfields Development
Framework with specific reference to California (for state law component) in a term paper
on Land Use Control. One of the objectives of the paper was to develop a generic
framework that could serve as a reference model for adoption by other developing
countries such as China to assist in their pollution control and brownfield development
efforts(Lim 2008, pp. 2-3).
The paper listed seven components within the original generic model: Brownfield site
dynamics, oversight agencies, contaminant framework, legal liability framework, site due
diligence options, risk control strategies, and public/private funding sources. The
framework references materials primarily from information compiled by the Center for
26
Creative Land Recycling in California (CCLR 2008). As such, it is referred to as the

CCLR-Lim framework.
This framework is revised in 2013 with one additional element: Principles. It is

recognized that underlying all the components and the framework are the moral and ethical
principles that give rise to their being. The purpose of adding this element is to help check
for consistencies between the various components.
As such, there are now eight components in the CCLR-Lim Framework:

1. Principles
2. Brownfields site dynamics
3. Oversight agencies
4. Contaminant framework
5. Legislation and liability framework
6. Site due diligence options
7. Risk control strategies
8. Public/private funding sources
Figure 4 outlines the relationship between the main components within the generic
framework.
27
Figure 4: CCLR-Lim Framework
The sections below provide a review of the framework components.

2.3.4.1 Principles
Ethical and moral values underlie the brownfields redevelopment framework. Moral
values such as compassion, goodwill, and sympathy transform into ethical concepts such
as fairness, integrity, and justice. These ethical concepts are then translated into guiding
principles such as human rights, environmental justice, or freedom of speech when placed
into the specific context of investigation.
Beder (2006) listed six principles as important guidelines for environmental policies:
Sustainability Principle, Polluter Pays Principle, Precautionary Principle, Equity Principle,
Human Rights Principle, and Participation Principle. The former three are environmental
principles while the latter three are social in nature.
28
Policy makers formulating environmental policies frequently find themselves in a

conundrum, torn between proponents of economic and business interests and those of the
environmental and social principles. They try to find a balancing point. In some cases
they can, but in most cases they cannot. Most environmental benefits and sufferings are
not monetize-able, and attempts to do that usually lead to unfortunate decision-making.
Beder wrote:
twelve million people die each year from contaminated water and inadequate
sanitation2 million die from air contamination800 000 from outdoor urban air
pollutionIt is clear from these statistics that environmental protection is essential to
safeguard human rights, and that human rights principles need to guide environmental
policy. (Beder 2006 p. 5)
Every country has its unique emphasis and approach in identifying suitable and feasible
guiding principles for their brownfield framework. It is the policy makers task to design
and implement policies that accurately and consistently follow the guiding principles. In
many cases, actual policies contradict stated principles and the gap between them could be
large. Careful considerations of the applicable principles and the resulting policies
therefore serve to remind us about our inherent consistency.
2.3.4.2 Brownfield site dynamics

The decision to develop a brownfield site often involves conflicting objectives and
dimensions that are difficult to measure with accuracy (Lim 2008):
Cleanup costs versus future land value
Private profits versus public goods
Negative versus positive externalities
29
Quantifiable versus non-quantifiable effects
However, regardless of the situation, key considerations can be distilled into the following
equation:
Table 2: Brownfield Site Dynamics Equation
[V]
Value of
[A]
Incremental
[B]
+
Benefits to
brownfield
value of land
community and
project/site
use ($)
environment ()
[feasible if
*Land use
>0]
change
[C]
- Costs of
[D]
- Risks and
cleanup ($)
liabilities ($)
*Social decision
*Function of
*Occurrence
whereby 1 1$
several
probability x
(exchange rate
factors and
(estimated cost
varies over time
net of public
or estimated
and space)
funding
health impact)
Source: Lim 2008
The value of a brownfield project [V] is an aggregate of the four variables A, B, C, D,

where:
A = Incremental value of land use
B = Benefits to community and environment
C = Costs of cleanup
D = Risks of uncertainties and liabilities.
The value of a brownfield project is feasible it is more than zero. However, the equation is
not easy to quantify due to diverse nature of the aggregates, with some variables
unquantifiable. In such cases, a good approach to move forward is to revisit the guiding
principles.
30
Key protagonists in this component include property developers, land use planners, and the
community. Property developers would be concerned about the value of potential land use
and the commercial feasibility. Land use planners would be concerned about creating an
optimal solution that balances multiple dimensional needs that have conflicting demands,
as illustrated in the Land Use Puzzle Model (ERDU 2009). The community, being the
ultimate end user for the remediated brownfield site, is intimately linked to the success of
the brownfield projects. As such, their concerns are comprehensive and include health and
safety risks, property value effects, community revitalization, and other intangibles such as
happiness and satisfaction.
Incremental Value of Land Use

The incremental value of land use [A] depends on a multiple of factors including
the location of site, the allowable developmental use, the value of surrounding
land, the purchasing power of the residents, and the general prosperity of the
city/countryside. This aggregate is generally considered to fall under the domain
of real estate development and with a mature realtor industry, is easily quantifiable
in monetary terms.
Benefits to Community and Environment

The incremental benefits to community and environment [B] are more difficult to
ascertain due to its complexity. Environmental economists would classify
brownfield remediation projects as having positive externalities. A related concept
is (utility) that measures satisfaction in human being. For many cases,
economists assume 1 = $x. Though this method has several potential drawbacks,
it is a relatively well-researched topic when compared to other methods of
31
measurement for the intangibles. In fact, actuaries use the utility function
frequently in measurements and risk modeling for incomplete market (Yu, et al.
2012, p. 101).
Benefits to community and environment are easier to quantify if the local or county
government keeps a good record of land use changes, has a comprehensive
database of contamination information, and when the community is well-informed.
Conversely, when there is less transparency or bad record keeping, the
quantification of benefits are more difficult.
Cost of Cleanup
Cost of cleanup [C] refers to the total costs involved in remediation of the
brownfield site. Schadler, et al. (2011) modeled the cleanup costs of a site as
including groundwater remediation costs, soil remediation costs, and building
deconstruction costs:
Total costs = CGW + CI + CS + BDC
Whereby:
CGW + CI = Groundwater remediation costs
CS = Soil remediation costs
BDC = Building deconstruction costs
Costs of remediation are usually straight-forward in its determination: the

developer will know the costs associated with the remediation early in the process
after the site assessment is completed. The key concerns would be the
32
effectiveness and choice of the technology: some technologies are ineffective and
could be more damaging to the environment (Lemming, et al. 2012).
Risks and Liabilities

Risks and liabilities [D] can be classified into two types: known and unknown.
Known risks can be quantified or estimated, while unknown risks cannot be
quantified. Examples of known risks include contaminant types and remediation
costs indentified via site assessments. Their potential financial and legal liabilities
can be calculated and incorporated into the sites financial dynamics by the
developers, and the potential health risks to the community can be mitigated.
Unknown risks are the main concern here: uncertainty implies potential liabilities
can loom large to developers and government agency, and also unexpected health
risks to the community. Examples of such risks include improper cleanup
workmanship, change of scientific standards, undisclosed contaminations, and
reopeners.
In general, a mature brownfield eco-system with experienced planners and developers,

supported by scientists and technicians, tends to be more capable in quantifying the
brownfields site dynamics equation. As such, a mature brownfield eco-system is more
desirable.
2.3.4.3 Oversight Agencies

Oversight agencies refer to the government authorities that are responsible for brownfields
issues. They can be classified into federal, state, and local levels. Alternatively, they can
33
be categorized according to functional areas such as environmental protection, land use

planning, or economic agency. Key success factors in a winning regulatory structure
include well-defined roles and reporting structures, clear responsibilities, and effective
policing system to ensure accountability.
In many cases, the regulatory structure is a reflection of the guiding principles that the
political process enables. In environmental regulation, there have been debates on whether
binding regulation or voluntary self-regulation is more effective in making business
entities meet their obligations to multiple stakeholders (Shamir 2004; Ferguson and Gupta
2002). Barkay (2009) argued that voluntary self-regulation, alternatively termed
regulatory capitalism, tends to allow corporations flexibility to employ the duo techniques
of decentralization of regulation and responsibilization (Parker and Nielsen 2009).
Decentralization of regulation refers to the dilution of regulatory power across several
agencies. This usually results in a weaker regulatory environment. Responsibilization
refers to the shifting of responsibilities and obligations to other parties, usually the public
or consumers, so that less performance is expected from the business association.
Through the duo mechanisms of decentralization of regulation and responsibilization,

regulatory capitalism creates the grave questions concerning the ability of organized
commercial interests to use it to shape regulatory frameworks in ways that may undermine
businesss own responsibility for public good (Barkay 2009, p. 370). As such, in
environmental regulations, binding regulatory structure is preferable.
34
2.3.4.4 Contaminant framework

Contaminant framework has three sub-components: contaminant definitions and cleanup
goals, medium of pollution, and remediation methods.
Contaminant definitions refer to the identification of natural occurring or man-made

materials that are deemed to pose health risk to human. In general, overexposure to any
type of chemical is toxic because of the disruption to body chemical balance. However,
some chemicals are more toxic than others due to their unique properties, such as arsenic
and dioxin, known for their carcinogenicity. Contaminants can include radioactive
compounds, such as uranium and plutonium, and emerging contaminants. Contaminant
cleanup goals dictate the maximum allowable level of concentration of contaminants in the
medium of pollution. Residential and commercial land uses usually have more stringent
goals than industrial uses.
Medium of pollution can be soil, ground water, and air, and is part of the Conceptual Site
Model used in Phase 2 Environmental Site Assessment. Medium of pollution dictates the
migration path of the contaminants.
Remediation methods refer to the various techniques used to cleanup the brownfield site.
Techniques include air sparging, soil removal, source control and containment,
nanoremediation, natural attenuation, electrokinetics, and phytoremediation (Maier and
Mendez 2008). Each method might entail a different cost structure or investment. All
remediation projects aim to obtain from the respective oversight agencies either a
Certificate of Completion letter or a No Further Action (NFA) letter.
35
2.3.4.5 Legislation and Liability Framework

Legislation and liability framework is one of the most contentious issues in brownfields
redevelopment: it specifies whether sites should be cleaned up and who is responsible for
the pollution. If multiple parties are involved, the legal framework provides a basis to
determine how the responsibilities should be split among the stakeholders.
In terms of assignment of liability, there are two general methods (De Sousa 2001, p. 139).
First is the joint and several liability system, where one party can be deemed liable for
the whole cleanup, though the party is only partially responsible for the contamination.
The second method is allocated liability system where different parties are liable only for
their allocated part in a pollution situation.
In general, the Polluter Pays Principle is applied within the country legal framework.
However, not all countries adopt this principle and in such instances, either the
government pays for the cleanup or the community pays. If the government or community
does no cleanup, the public users pay by absorbing the contaminants and experience health
impairment13. A contributing factor to such circumstances is ignorance of the brownfield
problem, and hence proponents of Sunshine Law would argue that transparency is a good
policy to maximize public wellbeing (Roesler 2012).
Further complications arise when the legal definition of contaminant changes over time.
This is the concern of retroactive liability. A chemical compound may be deemed
pollutive now but was not on the cleanup list five year ago when the remediation took

13
This could reflect in cancer statistics such as having a higher cancer death rate.
36
place. Should further cleanup be done? Who should pay for further cleanup? Should the
business or the government pays? These are questions to be addressed.
The purpose of having a clear and transparent legislation and liability framework is to
address the above complications and give all parties their fair rights and solicit fair take of
responsibility in managing and recycling brownfield sites. It gives all stakeholders a
platform for negotiation and cooperation so that an optimal solution can emerge.
2.3.4.6 Site Due Diligence Options

Understanding the site is fundamental to knowing what risks are inherent in a brownfield
project. Site due diligence options clarifies what are the steps that developer or
government agency can take to investigate whether a site needs to be remediated. It would
further define the types of environmental assessment and the estimated costs involved.
A clear and well-defined guideline to site due diligence options for developers and
government agencies expedites the remediation process by removing uncertainty. In
general, a more developed brownfields eco-system lowers the costs of site due diligence.
2.3.4.7 Risk control strategies

One of the biggest risks in brownfield projects is essentially the unknown, such as those
sites sitting on a contaminants migration path. As such, having a good understanding of
the tools and strategies to control the legal and financial exposures to such undesirable
occurrences is instrumental in a projects long-term success. Such risk control strategies
could be broadly categorized into two categories, the legal strategies and the financial and
others.
37
Legal risk control strategies refer to leveraging on legal agreements based on federal or
state legislations to minimize exposure to uncertain financial and legal liabilities.
Effectiveness of legal risk control depends on the clarity of the nations law: if the law is
clear and responsibilities clean cut, developers can assess their exposure to risks. Risk in
this case refers to uncertainty, and not the absolute amount of costs involved in
remediation. For example, a stringent remediation goal can have high costs, but if the law
is clear, the risk to developer is low. But if the law is ambiguous, risk can become very
high to developers.
Financial and other strategies refer to leveraging on financial tools to hedge against
uncertainty. Examples include environmental insurance, options, and contracts.
2.3.4.8 Public/Private Funding Sources

Public and private funding sources refer to the institutions that offer financial assistance
for brownfield revitalization projects. Funding could be applied for all stages of a project,
from initial site assessment, remediation, to tax incentives after commencement of
business.
In many cases, public funding is desirable because having the support of a public agency is
essential to the success of a brownfield due to the enormous financial resources and
technical capability embedded within the bureaucracy.
Private funding sources usually refer to bank loans and grants from non-profit
organizations with whose stated missions include assisting in brownfields cleanup.
38
2.3.5 Section Conclusion

This section reviews six brownfields models: three from CABERNET, one from De Sousa
(2001), one from Luo, Catney and Lerner (2009), and one from Lim (2008). The
conceptual models from CABERNET tend to be macro in perspective and limited in
details due to their principles-based nature. The frameworks by De Sousa (2001) and Luo,
Catney and Lerner (2009) provide great insights for cross-country comparative study.
However, there has been limited explanation of the individual components of the
framework.
The revised CCLR-Lim Framework is the most comprehensive model that encompasses
eight components, and allows a detailed comparison of key components between the
countries. In addition, it incorporates perspectives from various stakeholders including
property developers, planners, and the local community. This embedded multi-stakeholder
perspective within the framework components offers a balanced view of brownfields
issues and is crucial to the study of brownfields eco-system. Therefore the CCLR-Lim
Framework will be used as the core structure for comparative study between Singapore
and case country.
Given that CCLR-Lim Framework is developed based on the U.S. model, this paper will
use the U.S. as the case country for comparison with Singapore. There are several
advantages in using the U.S. as the case study: One, the U.S. is the acknowledged leader
in brownfields redevelopment and has been the role model for environmental policy
transfers for many countries such as Canada. Two, the U.S. system has been proven to be
effective in processing brownfield sites. Between 2006 and 2013, the U.S. EPA cleaned
39
up more than 68,800 sites and recycled over 644,000 acres for reuse under the CERCLA
funding alone (U.S. EPA 2013b). This is equivalent to more than four times the total land
area of Singapore. Three, the U.S. model is well researched and documented. This makes
the policy transfer and lesson drawing process efficient.
40
CHAPTER 3
RESEARCH METHODOLOGY
3.1 Research Design
The objectives of this paper are three-fold: one, to review and select a comprehensive
brownfields redevelopment framework as a blueprint for evaluating similar frameworks in
other countries. Two, to conduct a scan of the brownfields redevelopment framework in
the U.S. and Singapore and provide a descriptive account. Three, to compare the two
frameworks and offer recommendations.
The research design is therefore split into three stages: a.) Theoretical development; b.)
Field research; and c.) Conclusions. Figure 5 shows the research design.
41
Figure 5: Research Design
3.1.1 Theoretical Development Stage

The first step in theoretical development is to study international experiences in the U.S.
and Europe and conduct an initial query into Singapore experience. The initial research
objectives and questions are then developed. Activities at this stage include attending
42
industry conferences and reaching out to brownfields industry practitioners, government

officials, and other experts.
Appendix 6 shows the information collected during initial discussions with experts over
several occasions about the state of brownfields industry in Singapore and abroad. The
initial fact-finding discussions indicated that some industry practitioners were unaware of
any brownfields remediation projects being conducted prior to 2012. It should be noted
that these discussions were preliminary in nature and the limited number of practitioners
spoken to, being a small sample size, may not be representative of the actual state of
affairs.
Following the definition of research objectives and questions, literature review is

conducted to identify the appropriate areas of interest and the following academic areas are
related to the research topic: brownfields definition, lesson-drawing, policy transfer,
comparative study international experiences, and brownfield frameworks.
Brownfields definition literatures anchor the approach to the topic, while lesson-drawing
and policy transfer literatures illustrate methods of learning for Singapore. Comparative
study literatures, with emphasis on international experiences, are also practical guide on
how other countries learn from international counterparts, such as Canada and the U.S.
In terms of brownfields redevelopment framework, there is limited literature dedicated to

expounding this topic. As such, this paper draws on comparative study literatures from De
Sousa (2001) and Luo, Catney and Lerner (2009) to extract the key components from their
papers to form the respective frameworks. Another source of brownfields framework is a
43
term paper written by Lim (2008) for the Class of CP252: Land Use Control in UC
Berkeley, taught by Adjunct Professor F. Etzel. The term paper is dedicated to exploring
the brownfields redevelopment framework in California, U.S., in order to examine the
impact of emerging contaminants to the said framework. Some of the initial components
are referenced from Center for Creative Land Recycling (CCLR) materials. This CCLRLim framework has a few strengths: comprehensive coverage of key components and
embedded multiple-stakeholder perspectives. A revised version by the author in 2013 is
adopted as the core structure for brownfields redevelopment framework in this paper.
3.1.2 Field Research Stage

Following the selection of the CCLR-Lim Framework as the basic framework, the choice
for case country is the U.S. because the CCLR-Lim Framework is modeled on the U.S.
Framework.
The purpose of this field research is to collect data and information about Singapore and
the U.S. framework. Methods for Singapore case include primary sources, secondary
sources, and expert interviews. Primary sources include discussions and interviews with
experts and practitioners, researches on Singapore government published annual reports,
and government websites. Methods for the U.S. case include primary sources and
secondary sources. The data and information collected for both countries are then
analyzed and preliminary findings, evaluations, and critiques are conducted. In cases
where further questions arise, the iterative process includes going back to the data
collection stage and theoretical development stage to confirm the facts.
44
3.1.3 Conclusions Stage

In this stage, comparative analysis is conducted and lessons drawn. This is followed by
recommendations formulated based on the brownfields framework. Future research areas
are also outlined.
3.2 Research Methodology

The nascent nature of this topic in Singapore constraints the choices of research methods.
Given that research literatures on Singapore brownfields redevelopment framework is
limited, this paper attempts to conduct an initial situational analysis. Main research
methodologies used to scan the brownfields landscape in Singapore include comparative
case study, primary and secondary source research, and expert interviews.
3.2.1 Comparative Method

The dominant methodology for this paper is the comparative method using the U.S. and
Singapores brownfields structures as case study. Comparative method is defined by
Lijphart (1971, p. 682) as one of the basic methods the others being the experimental,
statistical, and case study methods of establishing general empirical propositions.
Skocpol and Somers (1980, p. 187) proposed that there are three main logics to
comparative methods: parallel theory comparative, contrast-oriented comparative, and
macro-analytic comparative. Case study method is closely related to the comparative
method, and while Campbell (1975, p. 185) recognized that single culture case studies
will continue to be the major form of comparative social science, Collier (1993, p. 116)
suggested that new perspectives on the case-study method have strengthened the validity
of that approach.
45
This paper combines the macro-analytic and contrast-oriented comparative for the
brownfields framework analysis. Macro-analytic examines the structures of the
brownfields framework while contrast-oriented comparative examines the differences
between the two countries.
3.2.2 Primary and Secondary Sources

Government agency websites, annual reports, and their publications are considered as
primary sources when investigating the respective agencys role and responsibilities.
Other primary sources include journal articles that published proprietary or scientific data
and information, new paper articles, and statutes. Secondary sources include journal
articles, newspaper articles, and any published paper that comments, analyses, and opines
on primary literature. In some cases, a journal paper can be primary source for one
framework component but secondary source for another framework component.
3.2.3 Expert Interviews

Expert interview method is used primarily to confirm or reject the initial findings from
primary and secondary source researches on the roles of government agencies and the
brownfield remediation process in Singapore. Government officials in charged of their
respective duties and industry practitioners are considered experts. For the case of the
U.S., expert interview is not possible due to financial and resource constraints. In any
case, the compilation of the U.S. framework was completed in 2008 with expert inputs
from CCLR, as such those facts are inherently validated.
The questionnaire format is semi-structured questions. For some topics, open-ended

questions are preferred as they can elicit stories from experts and help to uncover omitted
46
issues and concerns (Hollway and Jefferson 2008, p. 307-308). If the expert is available to
meet in person, a face-to-face meeting is scheduled. Alternatively, questions are emailed
to the respective government officials. If there is no reply, a follow up email and a phone
call is made. In cases where the expert does not respond to any email or phone calls after
three tries, the reach out effort is aborted. Appendix 7 shows the list of experts contacted
for interview and while Appendix 8 contains the interview questionnaires.
47
CHAPTER 4
THE U.S. BROWNFIELDS FRAMEWORK
4.1 Overview
The U.S. efforts to manage contaminated lands and brownfields went through three stages
of development. It started with the federal CERCLA legislation in 1980 to cleanup large
contaminated industrial sites, such as the Love Canal incident where numerous Niagara
Falls residents health were compromised by improper disposal of industrial wastes.
CERCLA was the worlds first nationwide toxic waste cleanup program. Between 1980
and 2004, CERCLA, with its state partners, investigated over 45,000 sites and cleaned up
more than 33,000 sites for reuse (U.S. EPA 2004a). The initial design of the program,
though, was dominated by public fear and faced enormous scientific uncertainty and hence
the implementation costs were enormous.
As the U.S. EPA gained more experience in toxic waste cleanup, two things occurred.
One, the state governments got increasingly involved in cleanup efforts as knowledge and
awareness of the danger of industrial contaminations improved. State governments
instituted their own legislations to better manage local problem sites while CERCLA
increasingly only concerned themselves with large and complex sites that required
sophisticated scientific skillsets that local governments did not have. State and local
governments initiatives complemented the federal cleanup efforts and gradually
accounted for an increasing percentage of the total efforts. Second, it was more effective
to cluster similar functions into one program to achieve economies of scale. Functional
programs, such as the Brownfields and Land Revitalization Technology Support Center
(BTSC), were formed. This increasing specialization improved the efficiency of land
recycling. This was the second stage of development.
48
The accumulation of cleanup experiences by the state and local governments opened the
door to the third stage of development, which brought two subtle changes in philosophy.
One, U.S. government realized the enormous economic potentials of land recycling and
the numerous benefits to the local community. Economic potential was intricately linked
to the real estate sector whereby land use determined the value of the cleaned up land. As
such, there is now a segregation of semantics between contaminated land and brownfields:
while contaminated land is single dimensional and based on public fear towards toxic
wastes, brownfields encompasses two additional dimensions, that of economic potential
and local community involvement. The set up of the Office of Brownfields and Land
Revitalization (OBLR) within the U.S. EPA was a reflection of this new understanding.
Two, the notion of sustainability gained wide acceptance within the bureaucracy, and led
to reevaluations of U.S. EPAs past policies and actions. This self-reflection culminated in
the U.S. EPAs adoption of the Principles of Greener Cleanups within its Office of Solid
Waste and Emergency Responses (OSWER) organizational processes and methodologies
(U.S. EPA 2009a). Remediation methodologies were reviewed for their environmental
discharges and secondary impacts and those with the best performances were selected as
best practices. In essence, a process of continuous self-improvement was engaged in the
treatment of brownfields revitalization projects to achieve beneficial reuse of resources for
economic, environmental, and societal purposes.
Figure 6 shows the schematics of the U.S. Brownfields Redevelopment Framework. In

this study, the state component is based on California legislation.
49
Federal Level
- Environmental Protection Agency (EPA)
State Level
- Department of Toxic Substances Control (DTSC)
- Regional Water Quality Control Board (RWQCB)
Local Level
- Certified Unified Program Agencies (CUPA)
- County and City Government
Federal Level
Environmental Protection Agency (EPA)
- Assessment Grants (up to $200,000 per site)
- Revolving Loan Fund Grants (up to $1 million cleanup)
- Cleanup Grants ($200,000 per site up to 3 sites)
Department of Housing and Urban Development (HUD)
- Brownfield Economic Development Initiative (BEDI)
Department of Commerce, Economic Development
Administration (EDA)
- No specific program but sees brownfield as priority ($900k)
Department of Transportation (TOD)
- Needs to link brownfield to transportation issues
Army Corp of Engineers (the Corps)
- Needs to link brownfield project to water issues
State Level (California)
California State Water Resources Control Board
- Underground Storage Tank Cleanup Fund (USTCF)
- Pays for petroleum UST cleanup
Office of the State Treasurer, California Pollution Control
Financing Authority (CPCFA)
- Cal ReUSE Forgivable Loan Program grants $300/500k in
forgivable loans for site assessments Phase 1 and 2 and
technical assistance (forgiven if project is cancelled)
- Cal ReUSE also gives up to $5 million in grants or loans for
clean up for infill residential or mixed-use projects
DTSC Targeted Site Investigation (TSI) Program
- Site investigation free of charged up to $100,000
Department of Housing and Community Development
- Transit Oriented Development (TOD) Housing Program at
max $17 million per site for housing development
- Infill Infrastructure Grant Program ($250k-$20 million) for
high density housing redevelopment on infill sites
Local Government Level
- Tax Increment Financing & Redevelopment Agencies
- General Obligation Bonds
- Mello-Roos Districts
- Revolving Loan Fund
Other Sources:
Continental Environmental Redevelopment Fund
- Private for profit company with public purpose
Center for Creative Land Recyclying (CCLR)
- Project learning program supports up to $25,000/project
Principles:
- Environmental Justice
- Equity Principle
- Precautionary Principle
- Sustainability Principle
- Polluter Pays Principle
- Participation Principle
- Right-to-Know Principle
Contaminant Definitions and Clean Up Goals

- Contaminant Candidate List (CCL) - Mandatory five year review to ensure regular update
- Applicable and/or Relevant and Appropriate Requirements (ARARs) or look up tables
o Regional Screening Levels (RSL) 2012 Tables Residential and Industrial
- Site Specific Risk Assessment expert opinions on maximum contaminant level (MCL)
Medium
- Soil, Outdoor air, indoor air, groundwater, surface water
Remediation Methods
- Soil removal, source control & containment, treatment, institutional controls, natural attenuation,
phytoremediation
1. Principles
4. Contaminant
framework
3. Oversight
agencies
2. Brownfield
site dynamics
8. Public/private
funding sources
5. Legislation and
Liability
framework
Federal Level
- Resource Conservation and Recovery Act of 1976 (RCRA)
- Comprehensive Environmental Response, Compensation &
Liability Act of 1980 (CERCLA)
- Brownfields Revitalization and Environmental Restoration
Act of 2001 (BRERA)
- Safe Drinking Water Act (SDWA)
- Emergency Planning and Community Right-to-Know Act
(EPCRA)
State Level
- Hazardous Substances Account Act (Californias Superfund)
- Hazardous Waste Control Act (Californias RCRA)
- Porter-Cologne Water Quality Control Act
- California Environmental Quality Act (CEQA)
- Common Law
6. Site due
diligence options
7. Risk control
strategies
Limited Site Assessment
- Does not provide federal liability defense protection
Legal
- Prospective Purchasing Agreement
- California Land Reuse and Revitalization Act (CLRRA or AB389)
- Unified Agency Review Program (AB206)
- The Polanco Redevelopment Act
- California Land Environmental Restoration and Reuse Act (CLERRA or SB32)
Financial and Others
- Environmental Insurance
- Contractual Buyer/Seller Agreement
Figure 6: The U.S. Brownfields Redevelopment Framework

Sources: Lim 2008; Authors Work 2013
Page 50
Phase 1 Environmental Site Assessment (ESA)

- ASTM E152701 qualify for federal liability protection and
certain state protection
- Costs $3,500 - $6,000
Phase 2 Environmental Site Assessment (ESA)
- Site Conceptual Model
- Intrusive sampling and analytical methods
- Outlines remediation or clean up process
- 6-8 weeks, costs upwards of $50,000
DTSC Program
- Preliminary Endangerment Assessment (PEA)
o Required if developing public school
- Environmental Risk Assessment
o Human Health Risk Assessment
o Ecological Risk Assessment
4.2 Principles in the U.S.

The U.S. EPA recognizes the following as their guiding environmental principles in
brownfields redevelopment:
Environmental Justice
Equity Principle
Precautionary Principle
Sustainability Principle
Polluter Pays Principle
Participation Principle
Right-to-Know Principle
As early as 1994, concerns about disproportionate pollution and environmental hazards

borne by the minority communities led to a Presidential Executive Order issued to federal
agencies to consider the inequity issue in their policies. In 1999, the California states
Office of Policy Research was tasked to develop Environmental Justice Guidelines for
Californias various agencies (Pastor, Sadd and Hipp 2001). The insistence on the Equity
Principle and other ethical concerns in policy treatment of politically weaker
constituencies culminated in the formal establishment of the Environmental Justice (EJ)
Program within the California EPA Office. The EJ Program is an extensive effort by the
California government to embed the spirit of environmental justice into the minds of all
state government departments officials.
In addition to the Equity Principle, the EJ effort embraces two other guidelines, the
Precautionary Approach and Cumulative Impacts, as defined below:
51
Precautionary Approach means taking anticipatory action to protect public health or the
environment if a reasonable threat of serious harm exists based upon the best available
science and other relevant information, even if absolute and undisputed scientific evidence
is not available to assess the exact nature and extent of risk.
Cumulative impacts means exposures, public health or environmental effects from the
combined emissions and discharges, in a geographic area, including environmental
pollution from all sources, whether single or multi-media, routinely, accidentally, or
otherwise released. Impacts will take into account sensitive populations and socioeconomic factors, where applicable and to the extend data are available. (U.S. EPA 2005,
p. 1)
Precautionary approach is a derivative of the Precautionary Principle and it is similar to the

lemon law in economics terms: in situations of information asymmetry, especially with
toxicology, the law sides with the less informed. The cumulative impact guideline looks at
environmental pollution from a Total Exposure perspective and ensures that those more
vulnerable, especially children, are well protected. In essence, the EJ program fused
several key principles, including equity principle and precautionary principle, and morality
dimensions into one active program for implementation.
The Sustainability Principle is adopted in the U.S. EPA through several initiatives such as
the Greener Cleanup Program and Green Chemistry Program. Greener Cleaner Program is
targeted at the remediation process of brownfields to ensure that secondary impacts to the
environment are less than the original contaminations. Green Chemistry Program
promotes the usage of green chemicals that have reduced waste, non-toxic components,
and more efficiency.
The Polluter Pays Principle seeks to ensure that those responsible for the pollution are
liable for the cleanup. The direct application is the legal requirement for polluters to
52
perform the remediation of brownfields, with continuing no cleanup violations liable for
US$25,000 fines per day (U.S. Senate 2002a, sec. 109, p. 563). The reverse of polluter
pays is non-polluters do not have to pay. As such, CERCLA has an Innocent
Landowner clause stating that no enforcement actions will be taken against innocent
landowners whose property is contaminated due to subsurface migration from other
sources (U.S. Senate 2002a, sec 107, pp. 557-559). The Prospective Purchaser Agreement
is another mechanism to indemnify innocent buyers from cleanup liabilities (U.S. Senate
2002a, sec 107, p. 559).
The Participation Principle refers to the rights of the public and community to be involved
in policy formulations that could potentially affect their livelihood, health, and safety.
This principle is well embedded into all the project plans for the U.S. EPAs brownfields
projects. For example, the action plan for the EJ Program pilot project listed three aspects
of public participation (U.S. EPA 2004b, p. 7): One, to conduct stakeholder meetings
throughout the two to three years process. Two, to establish local advisory groups (LAGs)
specific to the EJ program and the LAG has to be representative of the diversity of its
stakeholders. Three, establish on-going Stakeholders Forum for information exchange and
updates. These mechanisms work together to maximize community participation so that
local concerns can be incorporated into the final plan.
The Right-to-Know Principle is encapsulated in the Emergency Planning and Community

Right-to-Know Act of 1986 (EPCRA). It ensures that every person has the right to know
any information in a community that can affect his wellbeing, including brownfields and
contamination information.
53
4.3 Brownfield Site Dynamics in the U.S.

The brownfield site dynamics in the U.S. is generally considered favorable when
compared to other nations. This is because the U.S. has a well functioning brownfields
eco-system that include well laid out environmental principles, clear regulatory structure,
wide range of environmental insurance policies, and clearly defined process and standards
in achieving remediation. Table 3 shows the assessment on the desirability of the U.S.
brownfield site dynamics.
Table 3: The U.S. Brownfield Site Dynamics

Equation Variables
[A] Incremental Value of
Land Use
[B] Benefits to
Assessment
- Well-established realtor sector and information
availability
- Strong Public Participation and Marketing Program to
Community and
raise awareness and share knowledge within the
Environment
community
- Well established environmental and societal principles
- Right-to-Know legislation
[C] Costs of Cleanup
- Low due diligence fees

- Scientific leadership in toxicology and remediation
technology
- Public funding available
[D] Risks and Liabilities
- Clear legal framework on liability issues

- Availability of environmental insurance products
- Public funding available
The table above shows that the underlying dynamics for brownfields redevelopment are
well established and mature. It is easy for developers to acquire information on due
54
diligence costs and feedback from the local community regarding their concerns. The
clearly defined liability framework reduces the potential risks of acquiring a brownfield
site and hence encourages redevelopment. For example, an investigation into the U.S.
State Voluntary Cleanup Programs (VCP) reopener risk found that of the 11,497
brownfields cases examined, only 12 sites were reopened (Simons, Pendergrass and
Winson-Guideman 2003). The low VCP reopener risk of 0.1% implies a low long-term
risk for developers.
4.4 Oversight Agencies in the U.S.

The federal agent responsible for brownfield is the U.S. Environmental Protection Agency
(EPA). The department responsible for CERCLA and brownfields is the Office of Solid
Waste and Emergency Response (OSWER). The OSWER is organized into the following
offices (U.S. EPA 2013c):
Office of Superfund Remediation and Technology Innovation

This office implements the CERCLA legislation.
Office of Resource Conservation and Recovery

This office implements the RCRA legislation.
Office of Underground Storage Tanks (UST)

This office implements regulatory program for underground storage tank systems
storing petroleum and certain hazardous substances.
Office of Brownfields and Land Revitalization
55
This office implements the BRERA legislation.
Office of Emergency Management

This office administers the Oil Pollution Act and several other environmental
statutes such as the Clean Air Act (CAA), the Clean Water Act (CWA), and the
Emergency Planning and Community Right-to-Know Act (EPCRA).
Federal Facilities Restoration and Reuse Office

This office works with the U.S. Department of Defense (DoD), Department of
Energy (DOE), and others to develop solutions to their environmental problems.
Most projects now are managed by state or local agencies except for severe
contaminations or emergency cases where the U.S. EPA would be involved under the
CERCLA initiative.
State agencies include the Department of Toxic Substances Control (DTSC) and State
Water Quality Control Board (SWQCB). These departments are actively involved at the
state level to ensure that brownfield contaminations do not migrate and affect water
supplies. DTSC and SWQCB are part of California EPA.
Local agencies include Certified Program Agencies, which refers to those departments
delegated certain authority to oversee remediation. Such agencies could be City/County
Health Departments and Fire Departments. County and City governments are also
frequently involved in less complicated sites.
56
4.5 Contaminant Framework in the U.S.

The U.S. EPA is the world leader in toxicology research and brownfield remediation
technologies and provides funding to several leading researchers and universities on key
research projects. The U.S. Government Print Office (U.S. GPO) publishes the CERCLA
cleanup standard containing more than 3,500 contaminants and this serves as the basis for
determining contamination cleanup goals (U.S. GPO 2013).
For California, the authoritative definition source for contaminants is provided by U.S.
EPA Region 9, which provides the Regional Screening Levels (RSL) for chemical
contaminants (U.S. EPA 2012c). RSLs are developed using risk assessment guidance
from the CERCLA Program and can be used for Superfund sites. RSLs are generic
screening values and not de facto cleanup standards. In the initial site assessment, the RSL
tables provide initial screening levels and help to identify areas, contaminants, and
conditions that require further action. In general, sites where contaminant concentrations
fall below screening levels (SL) do not require further action. If the site chemical
concentrations exceed the SLs, it suggests that further evaluation is appropriate. Once the
Baseline Risk Assessment (BLRA) is completed, site-specific risk-based remediation goals
can be derived using the BLRA results.
According to the Safe Drinking Water Act of 1974 (SDWA), the U.S. EPA is required to
update the contaminant candidate list (CCL) every five years to make sure that health
hazards uncovered are regularly and properly accounted for. As such, the appropriate
cleanup goal for a brownfield site should adhere as close as possible to the most current
U.S. EPA standard. This is also known as the Applicable and/or Relevant and Appropriate
Requirements (ARAR) principle. For contaminations involving water, the ARAR is
57
usually the Maximum Contaminant Levels (MCL) contained in the Drinking Water
Standards and Health Advisories Table (U.S. EPA 2009b).
In terms of remediation methods, the U.S. EPA publishes their recommended technologies
according to site types and contaminant groups (U.S. EPA 2012d). For example, a typical
petrol kiosk site would usually be contaminated by four contaminant groups, fuel, metals
and metalloids, semi-volatile organic compounds (SVOC), and volatile organic
compounds (VOC), that consist of more than 180 compounds. SVOCs and VOCs migrate
to contiguous site via soil vapor. Recommended remediation methods include air
sparging, bioremediation, chemical treatment, and vitrification.
4.6 Legislation and Liability Framework in the U.S.

The federal legal liability framework was first put in place with the passage of the RCRA
in 1976 and the CERCLA or Superfund in 1980 by the Congress. The two Acts together
provided a comprehensive program for remediating hazardous-waste sites in accordance
with federal standards.
Resource Conservation and Recovery Act (RCRA) of 1976

This provides a regulation framework on underground storage tanks (UST)
containing petroleum or hazardous materials and permits lawsuits to be brought
against owners or operators of land
Comprehensive Environmental Response, Compensation & Liability Act

(CERCLA) of 1980
58
This act provides a clear liability framework that places most of the costs of
cleanup to those responsible for careless disposal practices. The courts have
interpreted CERCLA to impose full liability on covered parties regardless of fault
and regardless of the presence of other responsible parties
At the state level, the following laws are native to California:
Hazardous Waste Control Law (HWCL, Californias RCRA equivalent) &

Hazardous Substances Account Act (HSAA, Californias CERCLA equivalent):
The above acts are codified under chapter 6.5 and 6.8 of the California Health and
Safety Code. They are similar to federal counterpart except definitions of certain
hazardous contaminants and are carried out and enforced by Californias
Department of Toxic Substance Control (DTSC).
Porter-Cologne Water Quality Control Act

This is an important act and gives the California State Water Resources Control
Board (SWRCB) and the Regional Water Quality Control Boards (RWQCB) full
authority to set policies and develop regulations to ensure statewide water quality.
The Regional Boards also oversee the remediation of surface and ground waters
and the enforcement of corrective actions. SWRCB is a department under the
California EPA (Cal SWRCB 2011).
California Environmental Quality Act (CEQA)

CEQA requires state and local agencies to identify significant environmental
impacts of their actions and that Environment Impact Report (EIR) be conducted
59
for such public projects (Cal Gov 2012). It contains category exemption for certain
removal actions less than US$1 million and rarely challenges cleanup actions.
CEQA does not monitor whether its agencies follow the guidelines and relies on
the public to provide oversight through litigation or threat of litigation.
Common Laws
Common Laws refer to laws developed through prior cases or precedents. For
example, the case of Boomer vs Atlantic Cement Company established the rules of
compensation for environmental nuisance (Farber 2005).
For most brownfield sites, the rule of thumb is that planners and developers be more
concerned with state laws. Specific to California, the more important laws are hazardous
Waste Control Law, Hazardous Substances Account Act, and Port-Cologne Water Quality
Control Act.
4.7 Site Due Diligence Options in the U.S.

Understanding the site is fundamental to knowing what risks are inherent in a brownfield.
This section gives an account of the options available and the appropriateness of each
under different circumstances.
Limited Site Assessment (LSA)

LSA is used for preliminary review when the propertys history and conditions are
known. LSA does not provide liability defense protections under some state and
federal law.
60
Phase 1 Environmental Site Assessment (ESA I)

ESA I conducts record review, site reconnaissance, and interviews with owners and
occupants. A report and evaluation on the findings is then prepared. ESA I is
useful for liability defenses, site acquisitions, cost estimations, and identification of
potential legal risks. In some specific cases, ESA I is conducted to satisfy lenders
requests. When ASTM E1527-05 Phase 1 standard is met, ESA I gives the
landowner federal liability defense protections and certain state protections. For
small to medium sized sites, reasonable assessment costs range between US$3,500
to US$6,000.
Phase 2 Environmental Site Assessment (ESA II)

ESA II is the recognized industry approach to understanding the full extent of
environmental impact. It usually involves certain intrusive sampling and
analytical methods. It has three steps:
1. Site Conceptual Model development
2. Phase 2 Workplan. It usually includes cost estimations and expert opinions
on the potential presence of contaminants
3. Analysis of soil, gas, and water samples
Cost for ESA II ranges between US$10,000 to US$50,000, but for complex sites,
the costs could be more than US$100,000 (Lim 2008).
Preliminary Endangerment Assessment (PEA)

PEA is managed by DTSC and is required when developing public school sites. It
includes certain components of ESA Phase 1 & 2. This method examines potential
61
ecological impact, potential human health impact, potential risks of resource

degradation, and other gross contamination concerns. It has two sub-types:
Human Health Risk Assessment (HRA)
HRA is suitable for sensitive developments such as schools and hospitals.
Ecological Risk Assessment (ERA)
ERA is suitable if sensitive ecological habitats could be affected by large and
complex developments.
ESA Phase I & II are considered the most popular due diligence methods, while other
methods are used when specific conditions render those choices mandatory or more
economical. For example, in PEA (HRA) is mandatory for schools and hospitals.
4.8 Risk Control Strategies in the U.S.

Nanney (2001) noted that political and economic trends shape the availability of risk
control techniques. The U.S. governments attitude towards risk control moved from the
absolutist application of environmental regulation in the 1980s, which leads to
uncontrolled costs and liability, to the more reasonable balanced approach in the 2000s.
This change in attitude is impelled by the recognition that brownfields redevelopment offer
potential benefits also on the economic development and community revitalization fronts.
A range of legal and financial risk control strategies are available to assist developers and
community in their revitalization efforts.
Federal and State legal strategies include:
Prospective Purchaser Agreements (PPA)
62
In a PPA, the purchaser commits to a specific remediation plan to the regulatory

agency in return for a covenant-not-to-sue. A payment is usually part of the
condition. PPAs are obtainable from EPA, DTSC, and the RWQCB.
California Land Reuse and Revitalization Act of 2004 (CLRRA or AB389)

CLRRA allows innocent landowners, bona fide prospective purchasers, and
contiguous property owner to acquire limited liability associated with urban
brownfield if that person performs certain environmental assessment or cleanup
under regulatory supervision (Harris, Richards and Gershon 2004). The drawback
is that CLRRA does not provide full immunity to the landowners and the potential
liability has no true endpoint.
Unified Agency Review Program (UARP or AB2061)

UARP allows the cleanup party to select the oversight agency, which can be
DTSC, RWQCB, or a local health department. The lead agency will then consult
other agencies and implements its own final and binding cleanup and remediation
program. UARP provides Certificate of Completion, which gives limited
immunity to the cleanup party.
The Polanco Redevelopment Act (AB3193, Chapter 1113, Statutes of 1990)

The Polanco Redevelopment Act is part of the Community Redevelopment Law
and is codified in the Health and Safety Code Section 33459. Under this Act,
redevelopment agencies can actively pursue brownfield projects. The Act gives the
agencies the authority to obtain existing, non-privileged environmental
assessments, therefore avoiding duplicated environmental assessment costs and
63
efforts. This Act has the broadest immunity under California law, in terms of
further clean up requirements, when the project is completed. However, it does not
provide personal injury immunity.
The California Land Environmental Restoration and Reuse Act (CLERRA or

SB32)
CLERRA is modeled after Polanco Act but provides only limited immunity.
Financial and other strategies include the following:
Environmental Insurance
Environmental insurance is usually customized and caters to specific site
conditions. It usually offers protections against remediation risks, property value
impairment risks, business risks, and personal injury risks. Some policies also
provide cost-overrun coverage if the site owner is dealing with complex industrial
sites with long history of operations. The broadest coverage policy available is the
Real Estate Pollution Legal Liability Coverage, which can include business
interruption costs, cleanup costs after No Further Action letters, bodily injury,
and property damages.
Contractual Buyer/Seller Agreement

This is the contractual allocation of liabilities, warranties, and indemnities between
the buyer and seller. It could be modeled for seller or buyer to assume allocated
risks. For example, the seller could assume known risks while the buyer could
assume unknown risks.
64
The most popular strategy for California is to use the Polanco Redevelopment Act and the
purchase of an environmental insurance. Such a combination provides comprehensive
coverage for most risks.
4.9 Funding Sources in the U.S.

Several sources of public funding are available to assist in the execution of a brownfield
project. Fundings are available for the full spectrum of brownfield cleanup activities,
including initial site assessment, site remediation, and site structure construction. In
certain states, landowners can obtain tax incentives after commencement of business or
when they sell their properties. This section classifies these public incentives into federal,
state, local, and other sources.
At the federal level, several agencies provide grants and assistance to brownfield projects:
U.S. Environmental Protection Agency (U.S. EPA)

The U.S. EPA provides several grants including: i.) Assessment Grants provide
the cleanup party maximum of US$200,000 per jurisdiction or site; ii.) Revolving
Loan Fund Grants provide the cleanup party maximum of $1 million in grants.
40% of the total amount must be for cleanup purposes; iii.) Cleanup Grants provide
the cleanup party maximum of US$200,000 per site, up to 3 sites. But this grant
requires the project to have ESA II underway or completed in order to qualify; iv.)
Some other grants target specialist job training and research projects.
U.S. Department of Housing and Urban Development (U.S. HUD)
65
The U.S. HUD provides funding under the Brownfield Economic Development
Initiative (BEDI), but it must be used together the Loan Guarantee Program from
Section 108.
U.S. Department of Commerce, Economic Development Administration (U.S.

EDA)
The U.S. EDA has no specific program targeted at brownfields, but it sees
brownfield as a funding priority. Some applicable grants include Local Technical
Assistance, Public Works, Economic Adjustment, and Partnership Planning. The
average grant value is usually around US$900,000.
U.S. Department of Transportation (U.S. DOT)

The U.S. DOT has no specific brownfield program. However, if communities
could link transport funding to brownfield activities, the U.S. DOT can provide
support to the project.
U.S. Army Corps of Engineers (the Corps)

The U.S. Corps plans and develops large-scale water resource projects nationwide
and has enormous body of specialist technical knowledge. If a brownfield project
is tied to water or water quality, the Corps can provide supports such as site
technical assessment.
At the state level, several agencies provide grants and assistance to brownfield projects.
This paper uses Californian agencies as examples:
66
California State Water Resources Control Board (SWRCB)

Cal SWRCB provides UST Cleanup Fund. It was created under Barry Keene
Underground Storage Tank Cleanup Fund Act of 1989. Its objective was to
provide funding support for petroleum UST owners/operators to meet mandated
federal and state requirements.
Office of the State Treasury, California Pollution Control Financing Authority

(CPCFA)
CPCFA offers Cal ReUSE Forgivable Loan Program that provides the cleanup
party forgivable loans for site assessments, including ESA I and II, and technical
assistance. Maximum loan amount is US$500,000. This loan is repayable at
LIBOR rate if the project proceeds, but would be forgiven if the project is
cancelled. Another grant offered is the Cal ReUSE Program that assists the
cleanup party in brownfield cleanup for infill residential or mixed-use projects.
Maximum grant or loan amount is US$5 million. Center for Creative Land
Recycling administers these grants.
Department of Toxic Substances Control (DTSC)

Cal DTSC offers Targeted Site Investigation Program that provides site
investigation services, free-of-charge up to a maximum of US$100,000. This
service is a no-risk option and encourages environmental assessment projects.
Department of Housing and Community Development (HCD)

Cal HCD offers Transit Oriented Development Housing Program that provides
funding up to US$17 million per eligible residential or mixed-use site. For
67
municipalities, grants are offered for infrastructure support and brownfield cleanup
projects. For developers, loans are offered for building rental units. Another grant
available is the Infill Infrastructure Grant Program that provides developers,
municipalities, and redevelopment agencies maximum of US$20 million for
infrastructural costs that are related to residential or mixed-use projects. The
projects are usually within an urbanized area on a site developed previously.
Brownfield cleanup and site preparation costs are qualified activities for the grant.
At the local level, local and district governments provide grants and assistance to
brownfield projects:
Local government tax authorities or Redevelopment Agencies

Local tax authorities or Redevelopment Agencies offer Tax Increment Financing
for cleanup parties. Tax Increment Financing is a powerful tool for cleaning up
difficult properties if combined with Polanco Act. Another funding is the General
Obligation Bonds issued by a communitys taxing authority to assist brownfield
activities undertaken within the community boundary.
Mello-Roos Districts
Mello-Roos District is a mechanism for public entities to finance the construction
or acquisition of facilities to provide approved services. Cleanup parties can apply
for funding support via the local district in order to increase the chances of success.
For example, the U.S. EPA provides no-interest loans for cleanup activities through
the Revolving Loan Fund via the Mello-Roos District mechanism.
68
Some other Sources of financing includes:
Continental Environmental Redevelopment Fund

This is a for profit entity with public purpose that provides a wide range of
remediation and related financing, up to a maximum of US$15 million.
Center for Creative Land Recycling

CCLR provides Project Learning Program that offers direct grants, up to a
maximum of US$25,000, to support highly desirable and innovative land recycling
projects.
4.10 Further Discussions

The U.S. brownfields redevelopment framework has several thriving support industries
that provide key tools such as environmental insurance, site assessment, and remediation
to assist in brownfield management. The U.S. also has a sophisticated legislative system
to address the issue of liability allocation. However, the U.S. framework is not without its
critics:
First and foremost, there has been criticism regarding the efficiency of CERCLA. Many
critics have voiced their concern since this law was enacted three decades ago: reliance on
a fault-based system to assess legal and financial responsibility leads to a process where
complex and costly litigation is common. An alternative no-fault system focused on
prompt remediation might be a better and more effective use of finite resources (Frank
2010).
69
Second, even though there is the EPCRA that upholds the communities right-to-know,
businesses can circumvent this right under the trade secret claim where information
requests could be denied (Roesler 2012, p. 22). For example, Oil and Gas companies keep
the chemical compositions of hydraulic fracturing liquids from public knowledge under
trade secret claims.
There exist several other shortcomings and the U.S. Framework is far from perfect. There
have also been several cases whereby public opinions were ignored in favor of corporate
interests. Nonetheless, the U.S. framework is inherently self-corrective. For example,
though CERCLA was originally criticized as been unfair to innocent landowners who did
not contaminate the land but were made liable for cleanup costs under the joint and
several liability provision, this unfairness was rectified in subsequent statute BRERA.
70
CHAPTER 5
SINGAPORE BROWNFIELDS FRAMEWORK
5.1 Overview
Significant industrialization in Singapore started in the 1960s to achieve three objectives:
first, to create jobs for the unemployed; second, to achieve high GDP and per capita
growth; three, to reduce Singapores dependence on entrepot trade as sole economic pillar
(Lee 1973). As such, Singapores history of industralization is short when compared to
other countries such as the U.S., U.K., and Japan.
When CERCLA was first passed in the U.S. in 1980, the world then did not have a
comprehensive legislature to deal with legacy industrial brownfields sites. In addition,
commercial contracts had not then given much thought on the segregation and placement
of cleanup responsibilities between the contracting parties. As such, JTCs contracts with
its commercial partners then did not contain clauses specifying cleanup responsibilities by
the land user.
An expert interviewed cited the British Petroleum (BP) Refinery located at Pasir Panjang,
nearby Labrador Mass Rapid Transit (MRT) Station, as a case example. Refinery is a
pollutive activity and contamination is unavoidable. The lease with BP has ended and the
site is returned to JTC. However, the leasing contract between JTC and BP was signed
several decades ago and did not contain clauses requiring cleanup by the tenant. This is a
legacy issue leftover from a time when the detrimental effects of brownfield sites were not
known. In this case, if remediation were required, the government would have to pay for
it. However, Singapore does not have special purpose funds allocated for brownfield
cleanups (as in CERCLA). After the site is returned, URA will rezone it for residential
71
use. An environmental baseline study will be conducted, though this study is voluntary
and not a legal requirement. After the rezoning, the land is packaged as ready to build to
developers. One potential risk is the contaminants that are embedded in the land and the
potential health risks to the public if they were not cleaned up.
In 2001 and 2002, JTC implemented the Environmental Baseline Study (EBS), based on
Dutch Standards, as a tool to monitor the contamination situation at its tenants sites (JTC
2001; JTC 2002). Leasing contracts now contain clauses requiring tenant to clean up to
the standard established in the baseline scenario. However, EBS does not require the
tenant or government to cleanup the land to levels cleaner than the established baseline.
It should be noted that the adoption of EBS is not equivalent to the total management of
brownfields redevelopment process. EBS addresses parts of the brownfields
redevelopment framework components, and not all of the components. EBS is also
primarily designed for industrial sites only.
In addition to not addressing legacy issues, the legislature in Singapore does not mandate
public agencies to be responsible for their pollutive activities. One case is the Kallang
Gasworks located close to Levandar MRT Station and beside Riverine by the Park, a
private condominium. Kallang Gasworks is a state organization and there is no legislation
requiring mandatory brownfield cleanup by public agencies. Therefore no remediation is
conducted.
Figure 7 shows the schematics of Singapores Brownfields Redevelopment Framework.
72
Pollution Control Oversight Agencies

- National Environment Agency (NEA)
Lead agency for contaminated land
Also of air, water, and noise pollution
- Public Utility Board (PUB)
Drinking Water
Principles:
- Sustainability Principle
- Precautionary Principle
- Polluter Pays Principle
- Participation Principle
All listed standards are acceptable:

- Dutch Guidelines for Soil Protection
- ASTM International Framework (same as U.S. EPA)
- New Zealand Guidelines for Petroleum Contaminated Sites
Land Use and Economic Agencies

- Urban Redevelopment Authority (URA)
Land Use Planning
- Singapore Land Authority (SLA)
State Land Agent
- JTC Corporation (JTC)
Industrial Land Agent
- Housing Development Board (HDB)
Public Residential Land Developer
1. Principles
4. Contaminant
framework
3. Oversight
agencies
2. Brownfield
site dynamics
NA
8. Public/private
funding sources
5. Legislation and
Liability
framework
6. Site due
diligence options
7. Risk control
strategies
Legislations
- Environmental Protection and Management Act, Cap 94
- Environmental Public Health Act, Cap 95
- Code of Practice on Pollution Control 2004
All listed options are acceptable:

- Dutch Guideline for Soil Protection
- ASTM E1527-00 Phase I Environmental Site Assessment
Process
- ASTM E1903-97 Phase II Environmental Site Assessment
Process
- New Zealand Guidelines for Petroleum Contaminated Sites
Contractual Buyer/Seller Agreement
Figure 7: Singapore Brownfields Redevelopment Framework

Page 73
5.2 Principles in Singapore

In general, Singapore government follows a market-based approach towards managing its
affairs. For example, if traffic were congested, apply targeted road tax (Electronic Road
Pricing) for use of road and Certificate of Entitlement (COE) for car number control.
Economics principles and calculations are one of the key considerations in political and
policy debates.
The nature of monetary and economics principles, in many cases, contradicts

environmental principles. The challenge is to find a balance between the various
principles such that optimal utility can be achieved. The Land Use Puzzle Model (Section
2.3.1.3) is a conceptual framework to guide policy-makers in this aspect.
There is one strong form of environmental principle in Singapore: The Sustainability

Principle. Sustainability is delivered by different agencies within their domain: The
Public Utilities Board (PUB) ensures water sustainability; the National Environment
Agency (NEA) is responsible for environmental sustainability; the Building and
Construction Authority (BCA) promotes GreenMark as a green building standard in
Singapore. This various agencies adopted and promoted the accompanying programs
successfully. Given that brownfields redevelopment is inherently a most sustainability
approach to land resources, that is, cleanup and reuse, it is curious that this practice has not
been harnessed sufficiently in Singapore.
Other principles such as Precautionary Principle, Equity Principle, Polluter Pays Principle,
and Participation Principle exists within the bureaucratic structure, but have not been
74
codified as specific bureaucratic programs or laws. There is also no Singapore law that is
similar to the Right-to-Know Act in the U.S. for environmental or brownfields issues.
5.3 Brownfield Site Dynamics in Singapore

This section examines the brownfield site dynamics in Singapore. Table 4 shows the
assessment of the desirability of the brownfield site dynamics equation variables in
Singapore.
Table 4: Singapore Brownfield Site Dynamics

Assessment
[A] Incremental Value of
Land Use
- Well-established realtor sector and land value

information availability
[B] Benefits to
- Less transparency in contamination information
Community and
- No Right-to-know legislation
Environment
[C] Costs of Cleanup
- No experience in remediation
- No public funding
[D] Risks and Liabilities
- Legal framework unclear on cleanup liability

- No brownfield insurance products
- No public funding
Singapore has a mature realtor sector and land value information is easily available.
However, there is a lack of supporting infrastructure such as environmental insurance
provider, technical expertise in remediation, and transparency of information. These could
mean that Singapores effectiveness in managing brownfields and maximizing their
economic and community potential is low.
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5.4 Oversight Agencies in Singapore

The oversight agency for contaminated land in Singapore is the National Environment
Agency (NEA). NEA was set up under the National Environment Agency Bill 2005 as an
enforcement agency through a merger of the Environmental Public Health Division and
the Environmental Policy and Management of the Ministry of the Environment, and the
Meteorological Service Department of the Ministry of Transport (Singapore Parliament
Report 2005).
NEA is responsible for the brown issues, referring to pollution control, as opposed to green
and blue issues, where green refers to nature conservation and biodiversity and blue refers
to marine life and marine diversity. As then Minister of Environment Mr Lim Swee Say
noted:
But, here, I want to point out that any land-based pollution, any activities on land that
may lead to pollution in the water, will continue to come under NEA and ENV. There is
therefore no gap in our responsibility. (Singapore Parliament Report 2005, column 2324)
However, NEAs role is limited to being a facilitator, and does not have budget to support
basic environmental science research14 (Singapore Parliament Report 2005). The basic
science research budget is managed by the Agency for Science, Technology, and Research
(A*STAR). A*STAR is not compelled to conduct basic research in environmental
science. The Singapore National Research Foundation (NRF) sets Singapores research
directions and the vision is to develop Singapore as a Science and Technology hub, with
R&D contributing significantly to a knowledge-intensive, innovative and entrepreneurial
economy (NRF 2013). In essence, the goal of NRF is primarily economic maximization
via funding R&D activities.

14
It should be noted that there is fundamental difference between basic research and applied
research.
76
For drinking water quality and sewerage system management, the Public Utilities Board
(PUB) is the lead agency. NEA, together with PUB, are the two statutory boards under the
Ministry of Environment and Water Resources (MEWR). For marine-related pollution,
the Marine Port Authority (MPA) is the lead agency. As such, in terms of pollutionrelated oversight, three different agencies are in-charged of different territories. This set
up is different from the U.S. EPA, who is also in charged of marine pollution and drinking
water quality standards.
The Singapore Land Authority (SLA) is in charged of all state land in Singapore, while
JTC Corporation (JTC) is the agent for industrial land. JTC is a government entity with an
economic mission: promotion of the industrial sector, including Oil, Gas, and Chemical,
via comprehensive services and prepared land. Housing Development Board (HDB) is the
public residential housing provider.
The Urban Redevelopment Authority (URA) is the state sales agent for commercial and
residential land use. URA is also the planning agent and prepares the Land Use Master
Plan. URA does not have brownfield program and relies on NEA to monitor
contaminations. In cases of rezoning from industrial use to residential use, the lands
custodian duty is transferred from JTC to URA.
In conclusion, the regulatory structure in Singapore tends to be pro-business and some of

its government agencies are set up to promote economic objectives. This form of structure
is similar to regulatory capitalism (Barkay 2009). As such, the authority and power for
environmental pollution control is decentralized among several agencies (refer to Section
77
6.3), and in many cases, voluntary self-regulation among the corporations is the preferred
policy.
5.5 Contaminant Framework in Singapore

The NEA leverages on the World Health Organization and other nations capabilities and
standards and do not conduct its own basic research in bownfields (Singapore Parliament
Report 2005). The contaminant framework in Singapore allows many different standards
(NEA 2004, sec. 7.3, p. 22):
1. Dutch Guidelines for Soil Protection
2. ASTM International Framework (same as the U.S. EPA Federal Standards)
3. New Zealand Guidelines for Petroleum Contaminated Sites (adapted from the U.S.
EPA Standards)
4. Or any other standards acceptable to NEA
It should be noted that the Dutch Guidelines, the ASTM (U.S. EPA) Framework, and the
New Zealand Guidelines vary significantly in terms of their philosophy, methodology,
process, and regulatory structure.
For example, the New Zealand Guidelines tests for significantly less contaminants than the
U.S. EPA Standards. New Zealand Guideliness Screening Level (SL) tests for
approximately 40 contaminants, while U.S. EPAs RSL tests for approximately 750
contaminants, of which petroleum-related accounts for approximately 180 contaminants
(See New Zealand MOE 2011; U.S. EPA 2012c; U.S. EPA 2012d). New Zealand
Guidelines tests for significantly less contaminant and include only a sub-fraction of U.S.
EPAs required test for fuel compounds. It omitted carcinogenic contaminant groups such
78
as metal and metalloids that include cadmium, vanadium, mercury, selenium, and
beryllium. Metal and metalloids are commonly found at UST and petroleum sites.
Omitting these contaminants reduces the SLs effectiveness in protecting public health and
safety.
Similarly, Dutch Guidelines tests for approximately 110 contaminants in total,

significantly less than the 750 tested in the U.S. EPA Standards. In general, SLs serve as
the first casting of fishing net, and should include as many potential contaminants as
possible15. The contaminant list would then be withered down based on site-specific riskbased approach.
5.6 Legislation and Liability Framework in Singapore

The legislation on pollution control is contained in the Environmental Protection and
Management Act Chapter 94A, hereafter known as EPMA, original enactment in 1999,
last amended in 2002. This Act contains regulations on Air Pollution Control (Part IV),
Water Pollution Control (Part V), Hazardous Substances Control (Part VII), and Noise
Control (Part VIII).
Regulation on Land Pollution Control is covered under EPMA Part VI:

Pollution of Land:
20. The Agency may, with the approval of the Minister, make regulations to control the
pollution of land whereby the condition of the land is so changed as to make or be likely to
make the land or the produce of the land obnoxious, noxious or poisonous. (AGC 2013,
Part VI)

15
Current testing technologies are very efficient. For example, spectrophotometers can test for multiple
contaminants in one instance.
79
This clause contains the entire legislation on contaminated land and is unclear on the
following:
Joint and Several Liability versus Allocated Liability
Retroactive Liability
Disclosure Responsibilities
Impact Assessment and Cleanup Responsibilities
The guide for NEA on enforcement is the Code of Practice on Pollution Control (COPPC),
last amended 2004. COPPC outlined that:
When a site that is used for pollutive activities is to be redeveloped, rezoned or reuse for a
non-pollutive activity, a study shall be conducted on the site to assess extent of land
contamination. If the site assessment study shows that the site is contaminated, the
contaminated site shall be cleaned up to standards acceptable for the intended use. (NEA
2004, sec. 7, p. 21)
Similarly, the COPPC does not specify the liability framework and the liability allocation
method to be used in cases of ambiguity such as retroactive liability.
Another important legislation is the Environmental Public Health Act, Cap. 95, hereafter
known as EPHA. EPHA contains regulations on Toxic Industrial Waste (Regulation 11),
Drinking Water (Regulations 2008), and others.
5.7 Site Due Diligence Options in Singapore

Several due diligence options are available (NEA 2004):
1. Dutch Guideline for Soil Protection
80
2. ASTM E1527-00 Standard Practice for Environmental Site Assessments: Phase I

Environmental Site Assessment Process
3. ASTM E1903-97 Standard Guide for Environmental Site Assessments: Phase II
Environmental Site Assessment Process
4. New Zealand Guidelines for Petroleum Contaminated Sites
5. Or any acceptable standards to NEA
Similar to the contaminant framework, due diligence options in Singapore are based on
three different country standards: Dutch, the U.S., and New Zealand. New standards can
be proposed to NEA.
5.8 Risk Control Strategies in Singapore

The most common form of risk control strategy for brownfields in Singapore is primarily
embedded in commercial contracts. Other forms of risk control strategies are either
limited or unavailable. For example, the environmental laws in Singapore, such as EPMA
and COPPC, did not specify procedures for innocent landowners and lenders to acquire
immunity. Interviews with insurance professionals and insurance company website
searches also suggested that no insurance company in Singapore offers environmental
insurance to business entities for brownfield transactions.
5.9 Funding Sources in Singapore

There is no public funding sources for site due diligence or remediation. For private
funding, there are no non-profit organizations with funding dedicated to this mission in
Singapore.
81
5.10 Chapter Conclusion

The Singapore bureaucracy is efficient in managing several aspects of pollution including
air pollution, water pollution, and noise pollution. For land pollution control, current
method adopts the Environmental Baseline Study as the major tool. However, EBS does
not address legacy pollutions and is limited in its scope of considerations when compared
to the U.S. brownfields redevelopment framework.
The author of this paper considers Singapores framework as a good work-in-progress in

managing contaminated land. Possible areas of improvements include environmental
principles, legislation and liability framework, risk control strategies, and contaminant
framework. There are several lessons that we could learn from the U.S. framework in
order to improve and safeguard Singapores environment and public health.
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CHAPTER 6
FURTHER DISCUSSIONS
6.1 Principles
Principles are derived from moral and ethical values. They provide guidelines to system
set-up, decision-making, operations, and expected delivery of a legislation, project, or
program. Comparison of the Principles component between the U.S. and Singapore yield
several observations.
One, the U.S. legal and bureaucratic framework incorporated strong forms of the various
principles into their organization and operational protocols. For Singapore, the
incorporation of environmental and social principles into the legal and bureaucratic
structure is less pervasive.
Two, Singapore does not have Environmental Justice initiative or program to promote
environmental equity. EJ as an ideology promotes equitable distribution of environmental
benefits or pollutions among the population with no discrimination based on income level,
age, racial factor, or gender.
Three, Sustainability Principle is strong in both the U.S. and Singapore. However, though
brownfields site redevelopment is inherently an activity that conforms to the Sustainability
Principle, Singapore has not placed as much emphasis and investment into developing it as
the U.S. does.
Four, the Polluter Pays Principle exists in a strong form in the U.S. It exists in a weaker
form in Singapore legislation. The legal liabilities and fines for environmental law
83
violations are much higher in the U.S. than in Singapore: a no cleanup violation will cost
a polluter US$25,000 per day (up to US$75,000/day for subsequent offense) in the U.S.
(U.S. Senate 2002a, sec. 109, p. 563), while costing a polluter upwards of S$2,000 per day
in Singapore (AGC 2013, sec. 67-1a/b). The penalty to pollute in the U.S. is at least ten
times higher than in Singapore.
Five, the Participation Principle exists in a strong form in the U.S., but either in weak form
or non-existence in Singapore. Public participation process in the U.S. is an involved
process that often takes several months, where the public is involved from the start to end
of the project, and with opinions from communities carefully considered before policies
are implemented. The U.S. bureaucracy, imbued with a strong form of Participation
Principle, treats affected communities as stakeholders and partners in policy formulation.
In contrast, Singapore tends to have public consultation processes that are less involved.
In many cases, Singapores public opinions carry less weight than those in the U.S. One
recent example is the Bukit Brown Cemetery land use plan. Environmental activists
protests against developing the site, on grounds of heritage preservation and ecological
benefits, were dismissed under developmental and economic principles.
Six, the Right-to-Know Principle exists in a strong form in the U.S., but weak form in
Singapore. For example, all information about the CERCLA administration, including the
list of brownfields and participants, are on public domain in the U.S. Comparatively, land
plot information in Singapore, especially with respect to real or suspected brownfields,
whether it is petroleum related or otherwise, are not available in the public domain.
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6.2 Brownfield Site Dynamics

Brownfield site dynamics refer to the forces that stimulate growth or development for
brownfield redevelopment projects within a community or country. Key factors include
incremental value of landuse after remediation, the health and economic benefits to the
community and environment, the costs of cleanup, and risks and liabilities related to the
site (Refer to Table 2: Brownfield Site Dynamics Equation).
Determinants to brownfield site dynamics are important for planners and developers to
gauge the value of a site after remediation. In general, the dynamics are considerably
more favorable for planners and developers in the U.S. than in Singapore. There are two
main reasons: one, the U.S. has a well-developed brownfield eco-system with good
supporting infrastructure and professional services. Singapore does not have such an
infrastructure. Two, there is more clarity in the U.S. legislation framework on liability
concerns such as the innocent landowner clause and prospective purchaser agreement
(Refer to Table 7 part (b): Liability Allocations).
6.3 Oversight Agencies

Oversight agencies refer to the government institutions responsible for overseeing
pollution control, urban planning, land agency, or any function related to brownfield
redevelopment projects.
The U.S. EPA is the undisputed go-to agency in the U.S. for pollution control and
environmental related issues. U.S. EPA is also the world leader in toxicology research and
has enormous budget for supporting basic research projects. For Singapore, NEA is the
lead agency for pollution control, but the responsibility and authority is split among
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several other agencies, including PUB and MPA. The decentralization of functions and
duties imply that NEA is comparatively a weaker regulator than U.S. EPA in authority,
power, and expertise. Table 5 below shows a comparison of authority and responsibility
for the oversight agencies on different aspects of pollution.
Table 5: Comparison of Oversight Agencies

U.S.
Singapore
Soil Pollution
U.S. EPA
NEA
Air Pollution
U.S. EPA
NEA
Water Pollution
U.S. EPA + SWQCB
NEA/PUB
Marine Pollution
U.S. EPA
MPA
U.S. EPA + Others
A*STAR + NRF
U.S. EPA
NEA
U.S. EPA + local
SLA + JTC + HDB +
government department
URA
U.S. EPA + local
URA
Basic Research Mandate

Brownfield (contamination/public
health aspect)
Brownfield (economic aspect)
Brownfield (land use/community
revitalization aspect)
government department
Brownfield is a three-dimensional concept: it encompasses public health and safety aspect,

economic aspect, and community revitalization aspect of land use. From this perspective,
a comparison between the U.S. and Singapore yields a similar conclusion: the U.S. EPA is
an active participant for all three dimensions of brownfield redevelopment, while the NEA
is largely limited to only the public health aspect.
86
6.4 Contaminant Framework

Contaminant framework refers to the system of knowledge that identifies the substances
considered harmful to human health and the environment. It includes the classification of
contaminants, the testing methods and standards, and remediation technologies.
The U.S. contaminant framework is well established and provides clear guidance to the
contaminant definition and cleanup goals. Singapore does not publish a definitive list of
contaminants and cleanup goals and is open to several standards. Table 6 below shows a
comparison.
Table 6: Comparison of Contaminant Framework

U.S.
Singapore
Contaminant
U.S. EPA Standards,
1. Dutch Framework
Definitions and
including ARAR.
2. U.S. EPA Framework
Cleanup goals
3. New Zealand Framework

4. Others
Medium of pollution
Soil, water, air
Soil, water, air
Remediation
U.S. EPA recommendations
Open to proposed methods
Methods
Singapores contaminant framework allows many different definitions and cleanup

process. This is a major concern because multiple testing and cleanup standard is a
potential source for future litigation. In lieu of an official sanctified standard, multiple
cleanup standards being implemented at different land parcels could lead to varying levels
of pollutant cleanup. This non-standardization could also be detrimental to public health
and safety and could contradict the Sustainability Principle.
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6.5 Legislation and Liability Framework

Legislation and liability framework refers to the legal framework that specifies the
regulatory structure and allocation of responsibilities on cleanup duties. Table 7(a.) shows
the laws and legislations related to controlling land pollution in the U.S. and Singapore
respectively:
Table 7: Comparison of Legislation and Liability Framework

The U.S.
a.) Land Pollution Legislation
Singapore
Federal:
- EPMA, part VI
- CERCLA
- EPHA, reg. 11
- RCRA
- COPPC, sec. 7
State (California):
- CEQA
- HWCL
- HSAA
b.) Liability Allocations:
Innocent Landowners
Yes
No
Lender Liability
Yes
No
Retroactive Liability
Yes
Yes
Site Assessment
Yes
Yes
Oversight on government projects
Yes
No
Table 7(b.) shows the liability allocation of the U.S. and Singapores legislation on five
important issues: innocent landowners, lender liability, retroactive liability, site
assessment requirement, and government project oversight. The U.S. framework
addressed all five issues. Singapore framework addresses two issues, retroactive liability
88
and site assessment, under the Environmental Baseline Study program, though the exact
requirements and processes are different from the U.S. framework.
6.6 Site Due Diligence Options

Site due diligence options refers to the investigation options available to a developer or
community to determine the status of a brownfield site. A well-designed system offers
choices that cater to a variety of user needs.
The U.S. due diligence options has two categories: voluntary and mandatory. Voluntary
due diligence options are classified based on needs. For example, LSA is usually used for
preliminary screening before a real estate transaction negotiation. It does not provide any
federal or state liability protection but it is fast and low cost and gives the transaction
parties a quick idea on the extend of the environmental problems. ESA I and II are for
progressively more thorough investigations, usually dependent on the transaction
negotiation progress and LSA result. ESA I and II also provides federal and state liability
protection such as Innocent Landowner, Loaner, and Prospective Purchaser Agreement.
Voluntary due diligence options are usually based on ASTM guidelines.
Mandatory due diligence option, PEA, is used when oversight agency is involved for
special projects such as school sites. In California, the oversight agency is DTSC. Both
voluntary and mandatory due diligence options are based on the U.S. EPA framework.
In comparison, Singapores due diligence options are less comprehensive and also unclear
which option should be used under what conditions. This limitation is due to the lack of
clarity of Singapores legislative framework on brownfields and contaminated sites.
89
Table 8 below shows a comparison in the design of due diligence options available for
developers and government agencies.
Table 8: Site Due Diligence Options

Design Considerations
Transaction stages
The U.S.
Singapore
Yes. Segregation based on
No
transaction stage.
Compatible with risk
Yes
control strategies
No. Due to limited risk

control strategies
available.
Meet legislation liability
Yes
protection requirements
Cost scaling depending
Legislation is unclear on
this issue.
Yes
Yes
Yes
No. Allows three different
on requirements
One contaminant
standard
Public funding co-pay
standards.
Yes
No
As shown, the U.S. due diligence options system is designed to allow selection of different
options with considerations depending on the user and transactions needs. A preliminary
inquiry option could be a low cost US$3,500 LSA for parties who are interested in the
transaction and just wanted a general idea of the site condition and history. More in-depth
inquiries that offer legal protections and conform to risk control strategies ranges from
US$3,500 to US$6,000 for ESA I for reasonable sized quality sites to US$10,000 to
US$100,000 for ESA II for large complex sites.
90
On the other hand, Singapores due diligence options does not offer low cost pretransaction screening option and the options are disconnected from the legislation and
liability framework. There does not seem to be difference between choosing one option
over the other. Cost scaling of due diligence option is also unclear due to the adoption of
three different contaminant standards.
6.7 Risk Control Strategies

Risk control strategies refers to the legal and financial tools available to a developer or
community to mitigate the risks and liabilities in a brownfield project. Table 9 below is a
comparison between the U.S. and Singapore.
Table 9: Risk Control Strategies

Risk control strategies
The U.S.
Singapore
Yes
No
Yes
No
Environmental Insurance
Yes
No
Contractual Allocation
Yes
Yes
Legal tools available to government

agency
Legal tools available to private
developers
Comparison shows that the U.S. framework provides a multi-faceted risk control options
for government agencies and private developers, ranging from government legal tools such
as CERCLA and The Polanco Redevelopment Act to environmental insurance and
contractual allocation of risks (Refer to Figure 6: The U.S. Brownfields Redevelopment
Framework Risk Control Strategies). In contrast, Singapore framework provides only
91
contractual allocation as a risk control option Refer to Figure 7: Singapore Brownfields

Redevelopment Framework Risk Control Strategies).
6.8 Public/Private Funding Sources

Public/Private funding sources refers to the availability of external sources of funding to
assist the developer or community to execute the brownfield redevelopment project.
Table 10: Funding Sources

Sources of fund for:
The U.S.
Singapore
Site due diligence
Yes
No
Remediation
Yes
No
Specific landuse purposes for
Yes
No
Yes
No
vulnerable population
Brownfields knowledge
transmission
Table 10 shows a comparison between available funding sources in the U.S. and
Singapore. The U.S. framework has a healthy selection of public funding available to
developers and communities for site due diligence and remediation. In addition, various
agencies allocated fund for cleanup according to their specific agency mission. In
contrast, Singapore does not have funds to help with site assessment or remediation.
6.9 Chapter Conclusion

The comparisons show that Singapores brownfield redevelopment framework has several
improvement opportunities. For example, the lag in adopting cutting-edge environmental
92
principles in Singapores legislative system led to a less than desirable approach to

managing environmental issues; the decentralization of authority could lead to a weaker
oversight regime over corporations (Barkay 2009); the acceptance of multiple contaminant
standards could mean that varying levels of pollutions exists within Singapores land
parcels legally; and the limited availability in risk control strategies and public funding
mechanisms might not encourage corporations to actively conduct cleanup projects. BP
Refinerys planned rezoning to residential use is one case in point.
93
CHAPTER 7
CONCLUSION AND RECOMMENDATIONS
7.1 Conclusion
This paper reviews the U.S. and Singapore brownfields redevelopment framework. It is
found that the U.S. brownfields redevelopment framework is sophisticated in its
philosophy and composition. Its components are built on a multiple-dimensional
definition of brownfields and seek to achieve three objectives: contamination control for
public health, land use for economic potential, and public participation for community
welfare. It has also evolved and matured over the past decades in its ideologies, principles
of operations, methods, partnership engagements, and also addressed several legislation
and liability issues. Being the worlds innovator in brownfields philosophy, technologies,
and policy, the U.S. has developed an efficient mechanism in maximizing brownfields
value.
In contrast, the Singapore framework is built on a two-dimensional premise, primarily

public health and economic concerns of contaminated land. The multiple-dimensional
nature of brownfields as a discipline is less recognized within the bureaucratic structure.
Within the framework to manage contaminated land, the legal and liability framework is
unclear and risk control options are not available. Individual government agencies, being
dedicated and competent, see the shortcomings and repercussions of the legacy
framework, and attempted to address the issues within the system. JTCs adoption of EBS
to address industrial site pollutions is such an effort in good faith.
However, given the multi-disciplinary nature of brownfields redevelopment, each

government agency is only able to offer an internally generated solution within its
94
functional domain. The result is a patchwork of policy emulations from different

countries, including the Netherlands, the U.S., and New Zealand. This is similar to the
case of Canada, whereby a confusing patchwork of cleanup criteria leads to an ineffectual
system (De Sousa 2001).
Given that the challenge facing Singapore is a systemic issue, functional patchworks do
not solve the problems. Rather, the patchworks leave gaps in management practices and
legislative frameworks leading to potential future liabilities, disputes, and litigations.
Therefore, any policy emulation from the U.S. has to be systematic. To enable systematic
overhaul, the initiative has to come from visionary political leaders. Top-down approach
is the fastest and most effective means of enabling a successful brownfields redevelopment
framework in Singapore.
One of the biggest obstacles to successful policy transfer is that existing governance
philosophy has a huge emphasis on economic calculations. In a bureaucratic structure
where economics principles reign supreme, regulatory capitalism is frequently the norm.
Regulatory capitalism essentially means that the private corporations take up the
responsibility to self-regulate. Indeed, Adam Smith (1776) noted the precariousness of
having businessmen take up the regulators role:
The proposal of any new law or regulation of commerce which comes from this order [of
businessmen], ought always to be listened to with great precaution, and ought never to be
adopted till after having been long and carefully examined, not only with the most
scrupulous, but with the most suspicious attention. It comes from an order of men, whose
interest is never exactly the same with that of the public, who have generally an interest to
deceive and even to oppress the public, and who accordingly have, upon many occasions,
both deceived and oppressed it. (Smith 1776, Book I, Chapter XI, Part iii, Conclusion of
the Chapter, p. 339)
95
The misalignment of business interests versus public interests in a regulatory capitalism

regime, when applied to the domain of pollution control, carries grave consequences to the
community and the nation. As such, any policy emulation from the U.S. without a
rethinking of regulatory regime and environmental principles would be ineffective.
In conclusion, there are several lessons that Singapore can learn from the U.S. brownfields
framework. A systematic approach is more desirable than a piecemeal approach.
However, the ultimate intention of the lesson-drawing has to be clear: the purpose of
having a well-developed brownfields redevelopment framework in Singapore is to bring
about the fair treatment of people through reductions in land pollution exposure,
improvements in economic prospects, and community satisfaction.
7.2 Recommendations
This section provides recommendations based on the comparison between the U.S. and
Singapore brownfields redevelopment framework components.
Adoption of Environmental Principles

Principles decide how a brownfield redevelopment framework operates, what form
it takes, and its efficiency level. It is recommended that the following
environmental and social principles be formally introduced into the Singapore
legislature and bureaucratic framework:
1. Environmental Justice
2. Equity Principle
3. Polluter Pays Principle
96
4. Participation Principle
5. Right-to-Know Principle
Issues of principles are decided at the Parliamentary level and therefore belong to
the political domain. The introduction of environmental principles into
parliamentary debates brings attention to issues of great importance the efficient
and effective use of limited land resources in Singapore.
Set Up Brownfield Site Database

Brownfield site database is a fundamental building block for brownfields ecosystem. It is recommended that a brownfield site database be established. There
are two types: first is a general land use database where all land use and building
uses were recorded. The second type is dedicated to potential and identified
brownfields. Combined, the two databases serve several functions: One, as an
administrative tool to keep track of brownfields inventory and their status. Two, as
a due diligence tool for prospective buyers and sellers to study the land use history
of the particular land plot so as to indentify any potential contaminations. This
background check is usually conducted as under Limited Site Assessment or
Environmental Site Assessment Phase 1. Brownfields are added or deleted from
the database depending on the status. Three, as part of the government program to
have public participation where information is open to access by the community
and other stakeholders. Transparency ensures efficiency.
Centralize Pollution Control Authority in NEA
97
The regulatory structure for brownfields in Singapore is closer to regulatory

capitalism. Regulatory capitalism frequently leads to decentralization and
responsibilization of pollution control, both effects detrimental to environmental
and community health and safety. In addition, such form of governance usually
leads to a fragmented regulatory structure where policy implementations are
hindered by government bureaucratic procedures, which impedes proper response
to brownfield cleanups, as in the case of China (Luo, Catney and Lerner 2009).
As such, binding regulatory structure is recommended. Given that current

pollution control authority in Singapore is decentralized among many agencies, it is
recommended that pollution control authority be consolidated under one
organization, the NEA. An alternative structure is consolidation under one
ministry, the Ministry of Environment and Water Resources (MEWR), with PUB
in drinking water and NEA in other mediums, including marine. This
centralization of enforcement power will enhance the authority of MEWR and
NEA in policing and ensuring environmental safety for Singapore.
Set Up Coordinating Brownfield Office

Brownfield redevelopment is a multi-disciplinary subject. It is recommended that a
Brownfield Office be set up to coordinate activities between URA, NEA, SLA,
JTC, and PUB. The Brownfield Office can be an independent agency, or
alternatively, it can reside within NEA or URA. NEA is suitable because it is the
gatekeeper for land pollution control issues, while URA is suitable because of its
planning function brownfield is as much about land use revitalization as it is
about environmental health and safety. The Author is of the opinion that the end
98
goal should be having Brownfield Office as an independent agency, but in the

interim it can be housed in both NEA and URA. A third possibility is to incubate
the Brownfield Office within the Prime Ministers Office.
Basic Research in Environmental Science

The mandate that NEA should not be involved in basic environmental science
research should be reviewed (Singapore Parliament Report 2005). PUB invests
heavily into its technological competency and can be a good model for NEA to
emulate. U.S. EPA is also another policy emulation candidate.
One Contaminant Framework

It is recommended that Singapore adopt only one contaminant framework. This
provides clarity for all stakeholders and reduces litigation potentials. Of the three
current standards, it is recommended that the U.S. EPA standard be adopted as they
are the undisputed leader in basic brownfields science.
Set Up National Generic Soil Profile

It is recommended that NEA should investigate and set up nationwide generic soil
profile. This will form the basic scientific database for comparison, especially with
respect to investigations into possible contaminant migration via groundwater. It
will also form the foundation to risk-based site-specific assessment.
Adopt Singapores form of CERCLA & CEQA Legislation

It is recommended that Singapore adopt a similar legislation to CERCLA and
Californias CEQA. CERCLA sets the legal requirement for land tenants and
99
owners to monitor and cleanup contaminated land. As such, it sets the legal
foundation to protect public health and safety against corporate deviant behaviors.
Most importantly, it allocates fund and gives authority to clean up legacy
brownfield sites polluted under previous legal regime. CEQA requires all
government agencies to conduct ESA and monitor the level of contaminants for
public projects. CEQA therefore also sets the legal basis to protect public health
and safety against governmental deviant behaviors. It provides the basis for public
and community oversight.
One System of Due Diligence Options

It is recommended that NEA design its due diligence options according to the
following dimensions: transaction stage, cost scaling, legislation requirements, and
risk control strategies. A public funding co-pay would be an advantageous
investment into knowing the extant of pollution that is happening on Singapores
soil. The best designed due diligence options system is in the U.S. and hence it is
also suggested that Singapore adopt the full U.S. practice. However, this policy
transfer is possible only if the legislation framework on brownfields in Singapore is
updated and improved first by the Singapore Parliament.
Provide Risk Control Strategies

It is recommended that a comprehensive review on the availability of
environmental risk control strategies be conducted. The review should include
legislation, financial, and contractual aspects. For example, the government could
adopt a multi-prong approach to managing environmentally hazardous projects,
including environmental insurance policies and appropriate contractual clauses.
100
Public Co-Pay for Site Assessment/Remediation

Singapore could allocate fund for site assessment and remediation. These are
investments that will improve the natural wealth of Singapore. The coordinating
agency could be NEA, working with various other agencies including HDB, JTC,
URA, SLA, PUB, and NParks to design specific program for different types of
landuse.
Set Up Non-Profit for Publicity of Knowledge on Brownfields

Singapore could set up an organization that is similar to CCLR to promote
knowledge on brownfields to the public, private enterprises, and government
sector. This keeps all stakeholders in-sync.
7.3 Research Limitations

This paper has several limitations.
One, this paper is conducted under limitations in time, financial, and manpower resources.
As such, much of the research would benefit if more expert inputs and brownfields data
were available.
Two, there is a limitation on availability of actual data in Singapore. Though this paper
received expert opinions from government agencies, in-depth data regarding specific
projects were not available. This could be due to the confidential nature of such
information.
101
Three, researches on policy transfers are frequently speculative in nature and this paper is
no exception. Singapore and the U.S. exist under different states of technology and
ideology, and though this paper extracts common elements for comparison, subtle
differences within the framework components can weaken the basis of comparison.
Four, the effectiveness of recommendations depends on several factors. Chief among

them is the moral and ethical principles inherent in the bureaucratic and social structures
within the nation. A successful policy in one country could become a loophole for
corruptive activities in another.
Five, each of the eight framework components is itself a complex and profound subject.
This paper is only able to investigate each component in a superficial manner.
Six, this study is conducted with Singapores case in mind. In Singapore, JTC is the
government agency that manages most of the industrial land. However, the author is
unable to secure experts from JTC to assist in this study. As such, the viewpoints
expressed by the other experts only represent part of the full picture. All conclusions in
this study are to be examined critically with this limitation in mind.
Seven, one key weakness and limitation of this study is that it attempts to explore a
complex topic across two very different countries, the U.S. and Singapore. As the two
countries have very different legal, social, and cultural compositions, such a comparison
runs a risk of generalization.
102
7.4 Future Research Directions

There are several possible future research topics. One, there can be an in-depth
investigation into the rising cancer rate in Singapore and its correlation with environmental
factors such as brownfields and industrial land. If location and workplace data is
available, this can reveal whether land contamination is a contributing factor to cancer
rates in a community. Two, each of the eight framework components are candidates for
future research topics. Three, there can be more policy comparison researches between
Singapore and other countries such as Japan, China, and European countries.
103
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Appendix 1: List of Brownfield Projects in Europe

Projects Name
(Abbreviation)
BERI
BERISP
BUUF
CABERNET
CONVERNET
EUGRIS
HERMES
HYGEIA
INCORD
INCORE
INTEGRA SITES
LNET
LUDA
MAGIC
MASURIN
NICOLE
NORISC
PROSIDE
RARE
RECORE
RECULA
RELEMCOM
RESCUE
REVIT
SAUL
SEBCO
SNOWMAN
SULFANET
SURE
VISP
WUD
Full Projects Name

Brownfield European Regeneration Initiative
Breaking Ecotoxicological Restraints in Spatial Planning
Balitic Univeristy Urban Forum
Concerted Action of Brownfield and Economic Regeneration
Network
Developmnent of a Central/Eeastern European Conversion
Network
European Groundwater and Contaminated Land Information
System
Hotspot Eurosystem Research on the Margins of European Seas
Hybrid geophysical technology for the evaluation of insidious
contaminated areas
Integrated Concepts for Regional Development
Integrated Concept for Groundwater Remediation
Integrated Management and Revitalisation of Contaminated
SITES Country: France
The European Learning Network
Improving the quality of life in the Large Urban Distressed Areas
Management of Groundwater in Industrially Contaminated Areas
Management of Sustainable Revitalisation of Urban Industrial
Sites
Network for Industrially Contaminated Land in Europe
Network Oriented Risk assessment by Instu Screening of
Contaminated sites
Promoting Sustainable Inner Urban Development
Rhetoric And Realities: Analysing Corporate Social
Responsibility in Europe
Regenerating Europes Coalfield Regions
Restructuring Cultural Landscapes
Reclaiming Land Empowering Communities
Regeneration of European Sites in Cities and Urban
Environments
Revitalising Industrial Sites
Sustainable and accessible urban landscapes
City-hinterland cooperation as motor for regional development in
the South Eastern Baltic
Sustainable management of soil and groundwater under the
pressure of soil pollution and soil contamination
Sustainable Use of Former and Abandoned Landfills Vitalizing
City Centres through Integrated Spatial Planning
A Time Oriented Model for Sustainable Urban Regeneration
Vitalizing City Centres through Integrated Spatial Planning
Waterfront urban development
Source: ERDU 2009
Appendix 2: Singapore Land Use Master Plan 2003 & 2008
Source: URA 2013
Appendix 3: Brownfield Definitions by European Countries

Country
Austria
Denmark
Brownfield definition
No official definition. Understanding similar to
CABERNET definition recognising potential for
reuse and with less focus on contamination.
Wallonia: Sites previously dedicated to economic
activities and where the current condition is
contrary to efficient land use (Sites dactivit
economique dsaffects SAED)
Flanders: Abandoned or under used industrial sites
with an active potential for redevelopment or
expansion but where redevelopment or expansion is
complicated by a real or perceived environmental
contamination (legislation including a definition is
in the process of approval).
Contaminated sites areas where previous activities
have ceased but are still impacting on neighbouring
areas.
Sites that have been affected by the former uses of
the site and surrounding land; are derelict and
underused; may have real or perceived
contamination problems; are mainly in developed
urban areas; and require intervention to bring them
back to beneficial use (CABERNET definition).
Land affected by contamination.
Finland
No recognised definition.
France
Space previously developed that are temporarily or

definately abnadoned following the cessation of
activity and need to be reclaimed for future use. Can
be partially occupied, derelict or contaminated.
Inner city buildings not under use. Inner city areas
for redevelopment and refurbishment.
Belgium
Bulgaria
Czech Republic
Germany
Greece
Hungary
Ireland
Italy
Latvia
Netherlands
No information.
No information.
Derelict land: Land which detracts, or is likely to
detract, to a material degree from the ammenity,
character or appearance of land in the
neighbourhood of the land in question because of
ruinous strcutures, neglected condition or presence
of waste.
Contaminated site: site that shows levels of
contamination or chemical, physical or biological
alteration of soils, sub soils and of superficial or
underground water in a way to determine danger for
public health or for the natural or built environment.
The site must be considered contaminated if the
presence of only one of the values of contaminant
in soils, sub soils, superficial or underground water
is higher than the permitted values of the law.
A place that has been previously used or built up,
but currently is derelict or abandoned - can also be
contaminated (adapted CABERNET definition).
No commonly recognised definition. Obsolete
Data Source
Umweltbundesamt Wien
(2004)
Direction Generale des
Ressources Naturelles et de
lEnvironment (DGRNE)
Openbare
Afvalstoffenmaatschapp ij
voor het Vlaamse Gewest
(OVAM)
University of Mining and
Geology, Sofia
Czech Brownfield
Regeneration Strategy,
Progress Report
(Czechinvest)
Danish Environmental
Protection Agency
Finnish Environment
Institute
Ministere de
lEnvironnement
Umweltbundesamt
Berlin
Environmental
Protection Agency
Italian National Law

426/98 and Italian
National Law 471/99
Riga City Council

Ministry Economic Affairs
Poland
Portugal
Romania
Slovak
Republic
Slovenia
Spain
Sweden
United
Kingdom
industrial sites defines data listed in table 2.

Degraded areas due to diffuse soil contamination high density of landfill sites.
No information.
Polluted lands (soils).
Ministry of Environment
Ministry of Waters and

Environment
No information.
Degradated / abandoned building land usually
inside urban areas.
Basque Country only: Potentially contaminated
sites / Industrial ruins.
No official definition commonly understood as
formerly used land which needs revitalisation (or
remediation before going back to the nature).
England and Wales: Previously developed land
land which is or was occupied by a permanent
structure (excluding agricultural or forestry
buildings), and associated fixed surface
infrastructure.
Scotland: Vacant and derelict land.
University of Ljublijana
IHOBE
C. Egelstig (JMAB)
Planning Policy Guidance
Note No 3: (PPG3) Housing
DETR (2000); Welsh
Assembly
Scottish Executive
Source: Oliver, et al. 2005
Appendix 4: Selected Variations in State Definitions of Brownfields (the U.S.),

from Brownfields State of the States (Northeast-Midwest Institute, 2001)
State
Arkansas
Delaware
Illinois
Nevada
New Hampshire
New Jersey
Ohio
Oklahoma
Oregon
Rhode Island
Washington
Definition
An abandoned or underutilized industrial, commercial or agricultural property,
the redevelopment of which has been complicated by known or perceived
contamination and for which no responsible party can reasonably be pursued
A vacant or unoccupied site with respect to any portion of which the taxpayer has
reasonable cause to believe may, as a result of any prior commercial or industrial
activity by any person, have been environmentally contaminated by the release or
threatened release of a hazardous substance as defined under 7 Del C. c. 91 in a
manner that would interfere with the taxpayers intended use of such site (Title 30
2010)
A parcel of real property, or a portion of the parcel, that has actual or perceived
contamination and an active potential for redevelopment
Defines an eligible property in its Voluntary Cleanup Program as real property
not listed on the National Priority List, owned by anyone under current
investigation with respect to the property, and containing the probable site of a
release of a hazardous substance
In statute: . . . properties which have been environmentally contaminated,
subject to limitations of R.A. 147-F:4, II. These limitations include requiring
that the property be in compliance with any corrective actions or compliance
orders and the property can not be eligible for cost reimbursement from the oil
discharge and disposal cleanup fund, the fuel oil discharge fund or the motor
oil discharge cleanup fund unless it receives substantially less than full
reimbursement from these funds. In addition, the state uses the US
Environmental Protection Agency definition as its working definition for
broader brownfields redevelopment efforts
Any former or current commercial or industrial site that is currently vacant
or underutilized and on which there has been, or there is suspected to have
been, a discharge of contamination
Former/current industrial or commercial property with real or perceived
contamination
An abandoned, idled, or under-used industrial or commercial facility or other real
property at which expansion or redevelopment of the real property is complicated
by environmental contamination caused by regulated substances
Oregon defines brownfields in statute ORS 285A.185 ( brownfield means real
property where expansion or redevelopment is complicated by actual or
perceived environmental contamination), but uses the following working
definition: . . . a vacant or underutilized commercial or industrial property where
environmental, economic and social obstacles hinder use and redevelopment
Vacant or underutilized properties with contamination or suspicion of
contamination which hinders redevelopment
Properties that are abandoned or under-used because of environmental
contamination from past industrial or
Sources: Northeast-Midwest Institute, 2001
Appendix 5: The U.S. EPA Brownfields Definition (Legal)

Brownfields
With certain legal exclusions and additions, the term "brownfield site" means real
property, the expansion, redevelopment, or reuse of which may be complicated by the
presence or potential presence of a hazardous substance, pollutant, or contaminant.
Definition Source:
The Brownfields Site definition is found in Public Law 107-118 (H.R. 2869) - "Small
Business Liability Relief and Brownfields Revitalization Act" signed into law January 11,
2002.
"DEFINITION OF BROWNFIELD SITE- Section 101 of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (42 U.S.C. 9601) is amended by adding
at the end the following:
(39) BROWNFIELD SITE(A) IN GENERAL- The term "brownfield site" means real property, the expansion,
redevelopment, or reuse of which may be complicated by the presence or potential
presence of a hazardous substance, pollutant, or contaminant.
(B) EXCLUSIONS- The term "brownfield site" does not include-(i) a facility that is the subject of a planned or ongoing removal action under
this title;
(ii) a facility that is listed on the National Priorities List or is proposed for
listing;
(iii) a facility that is the subject of a unilateral administrative order, a court
order, an administrative order on consent or judicial consent decree that has
been issued to or entered into by the parties under this Act;
(iv) a facility that is the subject of a unilateral administrative order, a court
order, an administrative order on consent or judicial consent decree that has
been issued to or entered into by the parties, or a facility to which a permit
has been issued by the United States or an authorized State under the Solid
Waste Disposal Act (42 U.S.C. 6901 et seq.), the Federal Water Pollution
Control Act (33 U.S.C. 1321), the Toxic Substances Control Act (15 U.S.C.
2601 et seq.), or the Safe Drinking Water Act (42 U.S.C. 300f et seq.);
(v) a facility that-(I) is subject to corrective action under section 3004(u) or 3008(h) of
the Solid Waste Disposal Act (42 U.S.C. 6924(u), 6928(h)); and
(II) to which a corrective action permit or order has been issued or
modified to require the implementation of corrective measures;
(vi) a land disposal unit with respect to which--
(I)
(II)
a closure notification under subtitle C of the Solid Waste

Disposal Act (42 U.S.C. 6921 et seq.) has been submitted;
and
(II) closure requirements have been specified in a closure
plan or permit;
(vii) a facility that is subject to the jurisdiction, custody, or control of a

department, agency, or instrumentality of the United States, except for land
held in trust by the United States for an Indian tribe; (viii) a portion of a
facility-(I)
(II)
at which there has been a release of polychlorinated

biphenyls; and
(II) that is subject to remediation under the Toxic Substances
Control Act (15 U.S.C. 2601 et seq.); or
(ix) a portion of a facility, for which portion, assistance for response activity
has been obtained under subtitle I of the Solid Waste Disposal Act (42 U.S.C.
6991 et seq.) from the Leaking Underground Storage Tank Trust Fund
established under section 9508 of the Internal Revenue Code of 1986.
(C) SITE-BY-SITE DETERMINATIONS- Notwithstanding subparagraph (B) and on
a site-by-site basis, the President may authorize financial assistance under section
104(k) to an eligible entity at a site included in clause (i), (iv), (v), (vi), (viii), or (ix)
of subparagraph (B) if the President finds that financial assistance will protect human
health and the environment, and either promote economic development or enable the
creation of, preservation of, or addition to parks, greenways, undeveloped property,
other recreational property, or other property used for nonprofit purposes.
(D) ADDITIONAL AREAS- For the purposes of section 104(k), the term
"brownfield site" includes a site that-(i) meets the definition of "brownfield site" under subparagraphs (A) through
(C); and
(ii)
(I) is contaminated by a controlled substance (as defined in section
102 of the Controlled Substances Act (21 U.S.C. 802));
(II)
(aa) is contaminated by petroleum or a petroleum product
excluded from the definition of "hazardous substance" under
section 101; and
(bb) is a site determined by the Administrator or the State, as
appropriate, to be
(AA) of relatively low risk, as compared with other
petroleum-only sites in the State; and
(BB) a site for which there is no viable responsible
party and which will be assessed, investigated, or
cleaned up by a person that is not potentially liable
for cleaning up the site; and

(cc) is not subject to any order issued under section 9003(h)
of the Solid Waste Disposal Act (42 U.S.C. 6991b(h)); or
(III) is mine-scarred land."
Appendix 6: Initial Fact Finding Forum and Initial Discussions with Experts
Fact Finding Event Attended:
CH2M Hill Technical Forum Series
Remediation of Industrial Sites: Technology Selection
Date: October 11, 2012
Initial Discussions with Experts:
HT2M Hill
Gary Hirst, Senior Technologist
Hong Sze Yunn, Senior Engineer
Key Finding:
No brownfield remediation projects in Singapore.
There are some remediation projects in Malaysia,
Indonesia, and Thailand.
JTC
Corporation
Tang Pei Luen, Assistant Chief Civil Engineer, Engineering Planning

Division
Sandy Loo, Senior Manager, Chemicals Department, Biomedical and
Chemicals Cluster
Key Finding:
Explained the Baseline Study approach. Works with
each tenant to establish the baseline scenario. Usually
based on Dutch standard, but other standards from
New Zealand and the U.S. also acceptable.
National
University of
Singapore
Rick Reidinger, Environmental Assessment Lecturer

Key Finding:
There is no notion of brownfield in Singapore. Mr
Reidinger is not aware of any remediation projects
done in Singapore.
City
Development
Limited
Christina Chia-Lim, Project Manager

Key Finding:
CDL has not done any brownfield project. All land
prepared by government and delivered ready to use.
Land is assumed to be clean.
Appendix 7: Expert Interviews

Organization
Name
Designation
National
Environment
Agency
Koh Min Ee
Chief Engineer,
Pollution Control
Department
Engineer, Pollution
Control Department
Engineer, Pollution
Control Department
Chief Scientist
Pierre Ng
Public Utilities
Board
Quek Yong
Seng
Lim Mong Hoo
Singapore Land
Authority
Leong Kuo
Sam
Housing
Development
Board
Urban
Redevelopment
Authority
City
Developments
Limited
Prudential
Insurance
Marc Wong
Jacob Tan
Chua Boon Bee
Lim Szer Khee
Interview
Type
In-Person
Interview
Status
In-Person
Interview
In-Person
Interview
In-Person
Interview
OK
Manager, Land Asset

Management
Services
Deputy Director,
Industrial Lands
Maintenance Section
Executive Planner
Interview over
phone
OK
-Email
Responded
but unable to
fix interview
OK
Senior Manager,
Environment Health
and Safety
Financial Advisor
--
No response
Email
OK
OK
OK
OK
Appendix 8: Interview Questionnaires

URA
1. Which definition of Brownfield does Singapore use? Does it only include
industrial land (contaminated sites)? Or does it also include non-industrial land being
redeveloped (urban infill)? Or maybe Singapore does not use the word/concept of
Brownfield?
2. Does Singapore maintain a database of brownfield sites?
3. Does Singapore foresee the occurrence of more redevelopment of brownfield sites?
Perhaps as part of a package for a more compact city or due to adjustments in
economic components?
4. As we understand, petrol kiosks are considered brownfield because of the
underground storage tanks. Are such land parcels contaminant migration paths
being accessed and remediated (if necessary) prior to conversion to new uses?
5. Is there a lead or coordinating agency for brownfield related issues?
PUB
1. PUB is in charged of water quality. But water quality is affected by several factors,
including soil conditions and stormwater runoff. Given that water quality is affected
by soil quality, ie., if soil is contaminated, it will affect water. How is this issue
addressed? [NEA in charged of soil contamination]
2. Industrial sites storm water runoff can contaminate our water supply. How is this
issue addressed?
3. What is the working relationship between NEA and PUB on contamination issues?
Who is in charged of maintaining and updating contaminant standards and list?
4. Understand that Singapore adopts a variety of contaminant standards for soil, from
USA, Dutch, and New Zealand. Why? Would this not create potential legal disputes
due to interpretation differences among parties?
5. Theres no concept of brownfield in Singapores legal statue framework in
environmental protection. Why?
6. In the US, Regional Water Boards (PUB counterpart) are actively involved in
brownfield remediation, and have dedicated programs to monitor and encourage
remediation, what is the role of PUB in remediation?
7. PUB did the first brownfield remediation project at Lorong Halus. What are the
challenges? How does PUB work with other agencies? How are the responsibilities
split among the agencies?
8. International standard on green building, LEED, has a brownfield and site selection
component but Singapores GreenMark does not. Why?
NEA
1. Understand that Singapore adopts a variety of contaminant standards for soil, from
USA, Dutch, and New Zealand. Why? Would this be a source of legal disputes due
to interpretation differences among parties?
2. Are there brownfield insurance providers in Singapore?
3. In the US, a Phase 1 due diligence includes checking land ownership and land use
records to identify potential brownfield. Does Singapore/NEA have a similar
database?
4. Are there cases of industrial brownfields being converted to commercial or residential
uses? Would doing this help to preserve more nature space? Does NEA see more
cases of brownfield remediation?
5. NEA did the first brownfield remediation project for the Lorong Halus Landfill. How
does NEA work with other agencies?
6. NEA is in charged of soil contamination standards in Singapore. But land is owned
by SLA and other agencies such as JTC and PUB. What is the working relationship
with these agencies when a brownfield occurs?
7. Singapores legal framework has limited mention of brownfield. Why?

SLA
1.
2.
3.
4.
5.
Can you give me a brief description of SLAs roles?

Have there been instances of industrial land converted into other uses?
What is the process that SLA uses to monitor environmental pollutants?
How does SLA deal with contaminated land?
Has SLA or JTC conducted any remediation projects in Singapore?
Prudential
1. Does your company provide any environmental insurance products in Singapore?
2. Do you know of any insurance companies providing environmental insurance
products in Singapore?

Brownfields Redevelopment Framework - Comparison Between The US and Singapore

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Brownfields Redevelopment Framework - Comparison Between The US and Singapore

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BROWNFIELDS REDEVELOPMENT FRAMEWORK:

THE U.S. AND SINGAPORE

LIM KOK CHING

A DISSERTATION SUBMITTED FOR THE DEGREE OF

SCHOOL OF DESIGN AND ENVIRONMENT

CHAPTER 2: LITERATURE REVIEW ....................................................................10

CHAPTER 3: RESEARCH METHODOLOGY ........................................................41

CHAPTER 4: THE U.S. FRAMEWORK ..................................................................48

4.9 Funding Sources in the U.S........................................................................................... 65

CHAPTER 5: THE SINGAPORE FRAMEWORK ...................................................71

CHAPTER 6: FURTHER DISCUSSIONS ................................................................83

CHAPTER 7: CONCLUSION AND RECOMMENDATIONS ................................94

Applicable and/or Relevant and Appropriate Requirements

Maximum Contaminant Level

List of Brownfield Projects in Europe

Singapore Land Use Master Plan 2003 & 2008

Brownfield Definitions by European Countries

Selected Variations in State Definitions of Brownfields

The U.S. EPA Brownfields Definition (Legal)

Initial Fact Finding Forum and Initial Discussion with

CABERNET Bath Model

Land Use Puzzle Model

The U.S. Brownfields Redevelopment Framework

Singapore Brownfields Redevelopment Framework

Comparison of the U.S. Definitions against Landuse Lifecycle

Brownfield Site Dynamics Equation

The U.S. Brownfield Site Dynamics

Singapore Brownfield Site Dynamics

Comparison of Oversight Agencies

Comparison of Contaminant Framework

Comparison of Legislation and Liability Framework

Comparison of Site Due Diligence Options

Comparison of Risk Control Strategies

Comparison of Funding Sources

In Europe, the European Regional Development Fund, hereafter referred to as ERDU,

1.2 Singapore Context

Proportion of industrial value-add (including manufacturing activities) accounted for

1.2.2 Land Use

In essence, land lifecycle can be described in the following stages:

1.3 Potential Risks of Brownfields

brownfield research projects in Europe. In comparison, brownfield research is relatively

1.4 Research Intent

This research intent would be achieved by answering the following questions:

Appendix 3 shows a list of brownfields definitions used by European countries (Oliver, et

The table below compares the two definitions:

Table 1: Comparison of the U.S. Definitions against Landuse Lifecycle Stages

Included (all land uses, as

long as there is potential

Included (but only for land

Land abandoned, idled,

with prior industrial or

Analysis of this proposed universal definition showed that it excluded contaminated

Application of Alker et al.s brownfields definition into practice would place

Secondly, from a management perspective, the first step of setting up a brownfields

2.2 Policy Transfer and Lesson-Drawing

2.2.1 What is Policy Transfer?

2.2.2 What is Lesson-Drawing?

Based on Webster dictionarys definition of innovation: Introduction of something new into an

2.2.3 Section Conclusion

2.3 Brownfields Redevelopment Framework

2.3.1 CABERNET Conceptual Models

2.3.1.1 Cabernet Bath Model