A Safe Environment
- By Sarat Pratapchandran
- 12/01/11
In 1978, Young homemaker Lois Gibbs was struggling to raise a family near Niagara Falls, but
soon discovered that her home and those of her neighbors sat beside 20,000 tons
of toxic chemicals. The 99th Street School and the Love Canal neighborhood
incidents that led to the relocation of 900 families are synonymous with bad
school siting decisions.
Thirty-three
years later, the U.S. Environmental Protection Agency (EPA) has just released
the first-ever federal guidelines for locating school facilities. The 143-page
comprehensive School Siting Guidelines was launched on Oct. 1, 2011.
“We are very
excited that the EPA has finally launched the school siting guidelines. It all
began with the 99th Street School then, and it is fascinating to see that it
has taken 32 years or more to write these guidelines. We are happy that we got
it,” says Gibbs, now the executive director of the Center for Health,
Environment and Justice (CHEJ), a Virginia-based grassroots environmental
advocacy organization.
“This is a
victory for the faceless people out there who have worked hard,” Gibbs says.
Congress passed
the Energy Independence and Security Act (EISA) in December 2007 and asked the
EPA to work in consultation with the Departments of Education and Health and
Human Services to develop model guidelines for the siting of school facilities.
The act asked that the guidelines take into account broad categories dealing
with the “special vulnerabilities of children to hazardous substances or
pollution exposures,” modes of transportation available to students and staff,
efficient use of energy in transportation and the potential use of a school
site as an emergency shelter.
EPA worked
extensively with external stakeholders to develop the guidelines. They are
voluntary in nature and highlight the importance of meaningful public
involvement in the school siting process.
Addressing a
webinar organized by the National Safe Routes to Schools on Oct. 11, 2011,
Peter Grevatt, Ph.D., director, Office of Children’s Health Protection,
explains: “These guidelines focus specifically on environmental factors
concerned with school siting. There are many other considerations that local
jurisdictions need to consider when making school siting decisions."
The contents,
split into eight sections, give an overview of the process behind establishing
the guidelines and include topics like meaningful public involvement,
environmental siting criteria considerations, environmental review process,
evaluating impacts of nearby sources of air pollution, recommendations for
states and tribes, a quick guide to environmental issues and a “frequently
asked questions” section.
The guidelines
begin with highlighting the importance of community involvement in the school
siting process. They address steps communities can take before beginning the
school siting process and urge school districts to undertake an environmental
review, develop a school siting committee and communicate with the public and
other stakeholders about their plans for locating a school facility.
The guidelines
encourage districts to allocate resources for school siting and advocate
long-range facility planning. “Long-range planning is important because it
provides an opportunity for a school district to consider more than just its
immediate facility needs,” says Gary Marek, director of School Facilities,
Texas Education Agency (TEA).
The guidelines
encourage high-performance schools, stress the importance of locating schools
near populations and infrastructure and promote schools as diverse centers of
communities. They urge communities to consider children’s ability to walk to
school, access to public transportation and how to locate schools away from
potential environmental hazards. The frequently asked questions section at the
end provides clear, succinct answers for communities regarding environmental
factors affecting the school siting process.
Meaningful Community
Engagement Is Critical
EPA’s school
siting guidelines encourage meaningful public involvement at all levels of the
siting process. “The more involved the community is, the more supportive they
tend to be,” says Tracy Healy, REFP, president, DeJONG-HEALY, a firm that
provides planning services for school districts across the country.
Healy cited the
example of the Switzerland of Ohio Local School District, a rural district
where the firm “spent a few years with the community identifying potential facility
options for their aging school facilities and focusing on community
engagement.”
Another example
of active community involvement is Ohio’s Oletangy School District where
community members are part of committees that discuss what’s happening in the
district and provide recommendations and updates to the board of education.
In certain
instances, municipalities and school districts take decisions in isolation when
locating school facilities. According to Renee Kuhlman, director of Special
Projects, Center for State and Local Policy at National Trust for Historic
Preservation, “School districts and municipalities can start by sharing data —
both demographic data and land-use data (e.g., showing areas slated for
redevelopment or new housing, etc.) — this is a new process happening in
Billings, Mont., and it is yielding good results for both the district and
local government.”
Communities Can
Show Metrics
“The EPA
guidelines lay a framework for evaluating environmental impacts associated with
school siting. That’s a great step forward compared to what was available
prior,” says Jeff Vincent, Ph.D., deputy cirector, Center for Cities &
Schools at the University of California, Berkeley.
According to
Vincent, the guidelines give states and school districts something that goes
beyond a useful tool. Communities can “show processes and metrics needed when
school districts are looking at siting a new school. This enables communities
to hold their institutions accountable on school siting issues.”
He adds that
“better guidance is needed on the other aspects of siting decisions, linked to
community connections and school design, which can complement the School Siting
Guidelines on environmental aspects.”
According to
Matthew Trowbridge, MD, MPH, assistant professor, Associate Research Director
at the University of Virginia School of Medicine, “The need for meaningful
community involvement is important. EPA guidelines are voluntary and do provide
a good framework for local and regional discussions that highlight the
complexity of this issue. Not every community can be expected to do all the
research.”
Guidelines
Encourage Environmental Assessment
The guidelines
strongly encourage environmental assessment of the potential site and outlying
areas. “In concept, it’s extremely practical because underlying the guidelines
is that there is better analysis for the various costs associated with school
site choices. Some of these are environmental and health, but they still can be
monetized. Some economic benefits will come to school districts, others to
families and communities and cities,” Vincent says.
Budgetary issues
sometimes make it tough for school districts to do an environmental assessment
“but makes it very important as they want it to be more protective of the
environment,” Healy says. “The will is there but time constraints do not get
much focus and more progressive school districts in Ohio, Virginia and
Pennsylvania are already doing this.”
The guidelines
also empower communities to seek environmental justice. Gibbs says CHEJ will
take a “pre-emptive” strategy at the grassroots level so that communities are
empowered with school siting guidelines even before they decide on locating
schools.
“We plan to get
this into areas even before schools plan to site areas and have stakeholders
understand the guidelines,” Gibbs says.
Renovation and
Upgrades Are Important
According to
Kuhlman, “The new federal guidelines can be used to help states and tribes put
in place policy and practices that encourage renovation of our existing
infrastructure.” She says it will help encourage more public participation in
the process.
“If the
community and district receives good guidance from the state, they can fairly
evaluate all of their choices — renovate versus replace. Often, it’s difficult
for localities to know what all of the costs will be including land
acquisition, renovation, new roads, sewers, etc. because those costs are often
borne by different agencies, but ultimately by the taxpayers.”
However, location will be a primary factor in
determining whether renovation and upgrades are needed. According to Gibbs,
“These guidelines will help in renovation or build out efforts, but how far
they will be needed will depend on the school location. For instance, if the
school is close to a refinery in Houston, it might be difficult to go in for a
full-fledged renovation, but a historic school in Quincy, Mass., could benefit
from an upgrade.”
In recent years,
the economic recession has prompted school districts to renovate and upgrade
existing facilities. According to Kuhlman, “The slowdown has, however, put the
emphasis back on ‘fix-it-first’ mentality, and we’re seeing some districts,
like Buffalo, N.Y., invest in their existing schools — in Buffalo’s case,
they’re renovating 40-plus schools to the tune of $1.2 billion dollars in a
five-phase project. School districts have also used the American Recovery Act
(ARRA) funds to modernize their facilities.”
California is
encouraging renovation of existing facilities, while in New Hampshire the
Department of Educational Facilities works with local school districts to not
only choose renovation as their first option but also to explore “joint use”
opportunities.
“School
renovations with public funding attract private investment. On the other hand,
schools built far away from the residents they serve tend to have unintended
consequences,” Kuhlman says.
According to
David C. Edwards, chairman, Council of Educational Facility Planners
International (CEFPI), “The decision to maintain or renovate an existing school
versus constructing new is influenced by a number of factors which have to be weighed
against each other. No two facilities, communities and specific sites or
educational program requirements are the same. Of key importance in the
decision process is to determine if the existing facility is capable of
accommodating the desired educational program in a healthy and safe
environment.”
Edwards adds,
“The current condition of the facility and site is also a major factor to be
considered in the decision, with respect to the amount of dollars invested in a
renovation, where the desired end product may have compromises versus the
amount of dollars invested to construct a new facility.”
Joint Use Is
Encouraged
The guidelines
encourage “joint use” facilities, which Vincent says “is a key concept for
ensuring that schools are centers of their communities — that is, that they are
seen as community assets and widely used and supported. They are publicly
funded, local places that should see widespread use by all kinds of residents,
young and old. But to do so, they need to be seen that way and funded in that
way, especially with regard to building upkeep and modernization.”
According to
Trowbridge, “The choice of where to put community resources is critical.
Schools need to be designed to be flexible and must be useful to the entire
community, and joint use is probably one good way to go.”
Community-Centered
Schools Sustain Historic Communities
Kuhlman
explains, “The greatest benefit of community-centered schools from the
perspective of the National Trust for Historic Preservation is that they help
sustain our older and historic communities. We believe there is no greater
public institution more important to the vitality of a neighborhood than
schools.”
Kuhlman believes
the guidelines will help communities locate schools “to meet a multitude of community
goals — including combating childhood obesity, improving air quality and
revitalizing older neighborhoods.”
The location of
a school has multiple influences on the community surrounding it. According to
Trowbridge, “Where you place your school has an influence on transportation
patterns and other issues that impact the whole community.” He says issues like
childhood obesity need to be addressed through environmental policies.
Gibbs thinks
that schools built based on these guidelines will enhance community pride.
“This helps more communities, especially of low wealth and color, to have a
decent place for kids.”
Green, Healthy
Schools for the Future
The guidelines
encourage building green, healthy schools and school districts in different
parts of the country have already started this initiative. In Ohio, for
instance, the Ohio School Facilities Commission (OHSFC) has started requiring
all schools in districts approved for funding after September 2007 to be at
least LEED Silver certified with a goal of meeting LEED Gold.
“Something like
this has never existed before,” says Dr. Trowbridge, highlighting the
importance of the newly released federal guidelines.
Download the
Report
The U.S. EPA’s
School Siting Guidelines can be downloaded at: http://www.epa.gov/schools/siting.
Sarat
Pratapchandran is a writer specializing in education, environment and
healthcare. His website is www.lettersnatcher.com.
In light of the recent
school siting guidelines from the US EPA, Sarat Pratapchandran talked to Renee
Kuhlman, director of Special Projects, Center for State and Local Policy at the
National Trust for Historic Preservation. Here is a transcript of the interview
that deals with several issues that impact school siting and beyond.
How do you develop
meaningful community involvement?
Question: EPA’s recently
released school siting guidelines emphasize the importance of meaningful
community involvement in different aspects of school planning. How do you think
that you can bridge the gap between “school districts and municipalities that
make plans in isolation?”
Answer: There are several
ways to bridge this gap. First, school districts and municipalities can start
by sharing data – both demographic data and land-use data (e.g., showing areas
slated for redevelopment or new housing, etc.) – this is a new process
happening in Billings, Mo., and I think it’s yielding good results for both
the district and local government.
They can also participate in
each others’ planning processes – such as developing master facility plans or
comprehensive plans for the city or county.
They could also be invited
and kept appraised of meeting agendas – for example, the Charlotte-Mecklenburg
Joint Use Taskforce invites all of the departments that manage facilities and
capital improvement funding to a quarterly meeting so they can explore
opportunities for sharing spaces – this helps with both operation and
construction/renovation costs and is a good value for taxpayers.
There’s also the option of
signing a Memorandum of Agreement to ensure a mutually-agreed upon school
siting process by all parties including municipal and school planning
entities. Florida actually requires this
type of cooperative planning – called “school concurrency” – see page 25 of
this publication for more details.
How has the recession
impacted community-centered schools?
Question: In a two-percent growth
economy, we’ve seen lots of “middle class” movement – across states, schools
etc. How has this shift impacted community-centered schools? Has the slowdown
led to a call to maintain existing structures?
Answer: Although there are
always cyclical demographic shifts that need to be taken into account because
of the aging of school-age population in a neighborhood, the economic recession
has also encouraged other demographic shifts. Because schools receive most of
their money from local property tax revenues and state governments, and because
in most instances these sources of funding are currently shrinking, school
districts are examining their school facility costs. Many school districts – even in those with
growing population centers like Charlotte, N.C. – have to increase class size and
temporarily shutter some of their schools. The slowdown has, however, put the
emphasis back on “fix-it-first” mentality and we’re seeing some districts like
Buffalo, N.Y., invest in their existing schools – in Buffalo’s case, they’re
renovating 40-plus schools to the tune of $1.2 billion dollars in a five-phase
project. Also, in many instances, these school districts used American Recover
Act (ARRA) funds to modernize their facilities (see
http://www.ncef.org/school-modernization).
What is the greatest benefit
of community-centered schools?
Question: What is the
greatest benefit that community-centered schools bring in? And, how do you
think these federal guidelines can be used to leverage policy decisions?
Answer: The greatest benefit
from the perspective of the National Trust for Historic Preservation is that
they help sustain our older and historic communities. We believe there is no greater public
institution more important to the vitality of a neighborhood than schools.
Others such as the Robert Wood Johnson Foundation to Prevent Childhood Obesity
and the American Academy of Pediatricians would say that where we locate our
schools is important because it helps our children either get in or not get in
their daily recommended 60 minutes of exercise. Others like U.S. Environmental
Protection Agency would say that the travel implications of school siting
decisions are critical to reducing greenhouse gas emissions.
I think the new federal
guidelines can be used to help states and tribes put in place policy and
practices that encourage renovation of our existing infrastructure. These federal guidelines will also encourage
more public participation in the process. If the community and district
receives good guidance from the state, they can fairly evaluate all of their
choices – renovate vs. replace. Often,
it’s difficult for localities to know what all of the costs will be including
land acquisition, renovation, new roads, sewers, etc. because those costs are
often borne by different agencies but ultimately by the taxpayers.
Also, 21st century
technology can help older schools become as energy-efficient as possible while
their central location means they offer transportation efficiencies and I
believe the guidelines help point that out.
Examples of states
encouraging preservation and renovation of schools
Question: Can you cite some
examples of states where the emphasis is on preserving or renovating existing
schools compared to states that call for building new schools?
Answer:
- The Department of School Facilities at the California
Department of Education is currently looking at how they can encourage more
renovation – by changing the guidance they provide local school district and/or
their funding formulas.
-
Staff at the New Hampshire Department of Educational Facilities works
with local school districts to not only choose renovation as their first option
but also to explore “joint use” opportunities with local parks and rec
departments, libraries, etc. Senate Bill
59, which passed in 2010 and was championed by Sen. Martha Fuller-Clark, an
advisor to the National Trust for Historic Preservation, will mean a) more
public discussion, b) more cooperative planning between municipal and school
district planners and c) fair consideration of rehabilitation of existing
school facilities as part of the decision-making process.
Role of deferred maintenance
of schools: What is the impact?
Question: What role does
deferred maintenance play?
Answer: Deferred maintenance of
schools is not a new problem, but it is a growing problem. The economic recession has left school
districts scrambling to find money for teacher salaries, which means even less
funding is being allocated to maintain school facilities. As needed repairs stack up, districts have to
make tough choices about where to allocate their shrinking resources. According
to a recent report, the percentage of school districts predicting that they
will defer maintenance continues to rise: from 18 percent in 2008‐09
and 36 percent in 2009‐10 to more than half (55 percent) in 2010‐11. It is often difficult for school officials
to gauge how much they should be spending on maintenance and repair. However, industry experts often state
maintenance and repairs expenses as a percentage of the construction cost of
the building and typically recommend that 2 to 4 percent of the current
replacement value of a building should be spent every year on maintenance.
Below are some steps that
states have used:
-
Set aside two percent to four percent of
replacement cost for maintenance. Iowa requires school districts to allocate two percent
of the replacement value annually for building maintenance. The Maine Department of Education has
established a benchmark of two percent of the current replacement value of the building
and schools are advised but not required to appropriate this amount annually
for building maintenance.
- Keep maintenance funding
separate from operations funding. With
shrinking budgets, districts often face tough choices between facilities versus
instructional programs. But whenever possible, money set aside for maintenance
should not use for other purposes.
- Provide funding to address
the backlog. In Hawaii, a concentrated effort since 2001 has cut in half the
original $720 million dollar backlog of school maintenance. Annual funding by
the legislature has ranged from $35 to 150 million.
- Use federal funds when
available. Montana Reinvestment Act
(HB645), which implements the federal American Recovery Reinvestment Act (ARRA)
of 2009, has made $20 million available to school districts via the Quality
Educator Formula. This money may be used for deferred maintenance and energy
improvements and must be spent by September 30, 2010.
- Get creative with
financing. In Hawaii, grants to schools
that match funds with volunteers and private donations from a nonprofit whose
mission is to “Repair, Remodel and Restore” schools have saved the state more
than $22 million since August 2001.
- Establish a Revolving Loan
Fund. Maine’s School Revolving Renovation
Fund makes loans for projects that contribute to safe, healthy and adequate
school facilities. First priority
projects include repair or replacement of roofs, bringing a school into ADA
compliance, improving air quality, removing or abating asbestos and other
health, safety and compliance repairs. Second priority projects are those not
related to health, safety and compliance and are limited to school buildings,
windows, doors and water or septic systems. The maximum loan for a school building to meet priority and other
projects is $3 million. Each project must be designed and constructed with
materials that provide long-term durability and meet energy efficiency
standards as defined in state statue .
- Offer matching grants. In
2009, California provided $255 million in state matching funds, on a
dollar-for-dollar basis, to assist school districts with expenditures for major
repair or replacement of existing school building components through its
Deferred Maintenance program.
- Weigh applications for
building aid based on past maintenance efforts.
The Alaska Department of Education’s application for capital improvement
projects assigns points based on the percentage of total maintenance
expenditures relative to the building’s replacement value. Maximum points are
given when the percentage is five percent or greater.
- Provide information for
preventive maintenance. Alaska’s
Department of Education published a handbook that offers a framework for
developing and implementing a maintenance program. Maryland offers guidelines for maintenance
that includes life expectancies of different systems and best practices for
training and scheduling repair work. The
Maine Department of Education provides districts with a capital asset
management tool and data to help districts annually appropriate resources for
the preservation of their schools.
- Provide specific guidance
for maintaining historic schools. Colorado’s Office of Archaeology and Historic Preservation developed a
Universal Conservation Maintenance Plan that summarizes historic building
systems and maintenance principles.
- Include maintenance in the
long-range plans made by the school district, such as master plans.
- Survey and assess existing
schools. This first step in the planning
process is often overlooked. Components such as ADA access and historic
significance should be included. In
2009, Portland Public Schools (PPS) surveyed its 100 facilities throughout the
city to gain “an understanding of the historical significance of its existing
properties so that a planning process can begin for future building
rehabilitations and renovations.”
- Other suggestions from the
Helping Johnny Walk to School publication developed through a cooperative
agreement between the U.S. Environmental Protection Agency and the National Trust
for Historic Preservation include:
- Reward districts with good maintenance with additional
funding or faster project review.
- Prioritize state funding to help address inequitable
maintenance of schools in low-income communities (e.g., basing on Title 1
criteria).
- Carefully define in administrative rules or legislatively
what maintenance means.
- Subsidize retrofits of older schools with energy-saving
technologies to extend their life-span.
- Create special funding to help districts replace large
systems (e.g., HVAC, boilers, etc.) with higher energy-efficient models.
What is the link between
school renovation and residential development?
Question: The guidelines
state that “additional school capacity and location of new schools influence
the location of residential development.” What is the tie-in between renovating
existing schools and residential development?
Answer: School renovations
with public funding attract private investment. On the other hand, schools
built far away from the residents they serve, tend to have unintended
consequences. The Michigan Land Use Institute in the report entitled “Hard
Lessons” concluded that “new school construction is raising tax, economic and
community stability issues with long-term consequences.” Among their findings:
- New school construction
is dramatically raising property taxes for Michigan homeowners and businesses
and has tripled related debt from $4 billion to $12 billion since 1994.
- Since 1996, our research
indicates that districts built at least 500 new schools in Michigan and closed
278 older ones while the school-age population grew by just 4.5 percent. Even
though southeast Michigan will lose 1.5 percent of its school age population
within 30 years, according to the Southeast Michigan Council of Governments,
that region recently spent $6.2 billion on expanding or building new schools in
the last eight years.
- Building new facilities
to combat overcrowding can accelerate development that prices young families
out of the market, which can lead to declining enrollment. Okemos had 401
seniors in its 2003 graduating class, but just 224 children in kindergarten.
- Our preliminary research
suggests that keeping an existing school open increases home values in
surrounding neighborhoods and helps stabilize the area and its business
activity, while closing them slows the rise of home values.
How will schools look
in future?
Question: What is your
prediction on how schools will look like in the future? Will we see large
numbers of environmenally friendly “community hubs,” being built? Will we see a
rapid surge in the number of schools within one mile of where people reside?
Answer: Over the past 40
years, we have engineered our built environment to be less supportive of
sustaining of our older and historic neighborhoods. We’ve run highways through the middle of our
downtowns and split entire neighborhoods in half; we’ve made it difficult, if
not impossible, for many students to walk or bike to school; and we’ve made it
difficult for our municipal and school districts to work together on school
facilities. However, I think this trend
is on the wane – we’re seeing more emphasis on how schools can be located to
meet a multitude of community goals – including combating childhood obesity,
improving air quality and revitalizing older neighborhoods.
Schools, zip codes and
developers
Question: Schools are
identified by zip codes where they exist and several demographic factors play
an inherent role in locating a school. During the building boom, residential
developers played an influential role in segregating schools based on a host of
parameters. What are your views in this regard?
Answer: I think an open,
transparent planning process where all stakeholder opinions are considered
helps ensure schools are diverse. I think land-use planning and school facility
planning needs to be closely aligned to ensure there are diverse neighborhoods
that in turn support diverse school populations. Interestingly, older
neighborhoods tend to have a diverse range of housing stock – typically in the
same couple of blocks you’ll see large houses, rentals, condos, etc. – these
range of housing types lead to economically diverse school populations as well.
I also think school districts and communities need to understand that when
developers offer land for schools at a “free” or “reduced price” that there are
associated costs that also need to be calculated into their decision-making
process – such as new roads, new sewer and the possibility that this may lead
to decline of another existing neighborhood and its infrastructure.
How useful will the EPA
guidelines be?
Question: School districts
do not have a uniform character across different areas including construction
of facilities. In this context, how useful will EPA’s guidelines be, especially
when they are “voluntary” in nature?
Answer: The National Trust
believes that states, tribes and local education authorities should ensure an
inclusionary, transparent planning process for school facilities. Technology
allows us to encourage public participation in ways we didn’t have available to
use 10 or even five years ago. Therefore,
because the new federal guidelines encourage meaningful public participation,
we think they will be especially useful.
Also, states, tribes and
local education authorities have the ability to adopt those portions of the
guidelines that will be most useful to their particular circumstances because
they are voluntary in nature.
We also believe that the
over 50 recommendations in the Helping Johnny Walk to School publication offers
school districts, states, and tribes some great options for encouraging
community-centered schools.
Question: With several
non-profit agencies and public advocacy groups focusing on different aspects of
school siting, is there information overload on this topic for communities
seeking basic guidance?
Answer: I don’t think you
can ever have access to too much information. School districts and their local
citizens need to understand their options and the consequences (intended or
unintended) of their siting decisions.