A Safe Environment

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?


  1. 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.
  2. 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 200809 and 36 percent in 200910 to more than half (55 percent) in 201011.  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:

  1. 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.
  2. 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.
  3. 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.
  4. 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.