Site Conditions and Feasibility
This information is intended for sites where the cleanup program, whether Federal, state, or Tribal, has been identified.
Site conditions, such as contamination location, topography, regulated flood zones, and parcel dimensions, will impact the developable area. Challenges such as environmental cleanup, flood risks, and other climate concerns should be considered during the planning process. Consider how your answers to the following questions will affect project viability:
Conduct site-specific assessment on renewable energy potential.
If the pre-screening process determines that a project merits a more serious investment of time and financial resources to attract renewable energy developers, conducting an in-depth, site-specific assessment is recommended.
For example, on-site sensors may be installed to gather data over a long period (approximately 1 year) to confirm wind resource availability or a local shading analysis could be performed for potential solar projects.
Is cleanup needed at the site?
Accidents, spills, leaks, past improper disposal and handling of hazardous materials and wastes have resulted in more than a hundred thousand contaminated lands in the United States. EPA and its partners work to address contamination where necessary and encourage the restoration of such land for community reuse.
Many potentially contaminated or underused properties will undergo an environmental assessment; the results of the assessment will demonstrate that no cleanup, minimal cleanup, or substantial cleanup is required before the site can be returned to productive reuse. A timeline and schedule of cleanup milestones are recommended for sites under consideration for redevelopment. The schedule can inform a development timeline for renewable energy and some initial and planning activities may begin while cleanup activities are ongoing.
If you are unsure of the cleanup status that is applicable to your site, contact a RE-Powering team member in your region or visit how to identify sites.
Am I liable for cleanup?
It is important to understand your responsibility for potential cleanup liability on contaminated sites and related costs. To promote the numerous environmental, public health, and economic benefits associated with cleanup and reusing previously contaminated properties, EPA, states, and Tribes have developed various environmental cleanup programs. For information on liability and cleanup programs. More information regarding EPA’s liability and cleanup programs.
Are site terrain conditions and climate concerns accounted for?
The site’s terrain can impact project timelines and costs if additional site preparation, such as extensive grading or leveling of the ground or mitigating shading, is needed before construction can begin. Additionally, any associated climate risk on the site that could compromise the infrastructure or long-term protectiveness of the cleanup, such as flood risk and onsite stormwater management, should be considered when planning renewable energy projects.
Is access to transmission or distribution line readily available?
The site’s location and distance to the nearest electricity transmission or distribution line can significantly affect overall project costs and timing. An initial screening can be performed with publicly available transmission or distribution line and substation hosting capacity information provided by utilities. Ideally, a site should be less than a mile from the nearest electricity line. In addition, it’s preferred that the site be clear of impediments (e.g., waterways, highways, etc.) between itself and the point of interconnection to limit costs for laying new lines and have other nearby electricity infrastructure to minimize upgrade costs. More information on renewable energy infrastructure needs.
Evaluating project economics
A renewable energy project’s economic feasibility can depend on many factors, including environmental conditions, permitting requirements, transmission or distribution interconnection locations, technology cost and complexity, local electricity prices, available financial incentives, and other local factors. More information on project financing.
Am I liable for cleanup?
If you are considering the use of a contaminated or previously contaminated property for a renewable energy project, it is important to understand your potential responsibility for cleanup and related costs. Contaminated properties are cleaned up under a wide variety of federal, state, Tribal, and local government cleanup programs, and legal authorities. Generally, only contaminated properties with significant actual or potential public health and/or environmental impacts or those needing immediate attention are likely to be of federal interest. Whether a federal, state, local, or Tribal law or policy applies to a purchaser or lessee will depend on the facts and circumstances of each case, including, among other things, the developer’s conduct with respect to any contamination on the property.
These programs may provide liability protection for parties that did not cause the contamination at the property. These protections may be applicable to address the potential liability concerns of a developer of renewable energy on contaminated property. EPA has also developed a variety of mechanisms, including policy and guidance and property-specific documents, to address potential liability concerns and uncertainty, including:
- Liability Reference Guide for Siting Renewable Energy on Contaminated Properties
- The Revitalization Handbook—Revitalizing Contaminated Lands: Addressing Liability Concerns
- Comfort/Status Letter Guidance
- Guidance: Superfund Liability Protections for Local Government Acquisitions
For more information regarding EPA’s cleanup policy and guidance, models, and publications, see the Agency’s website Addressing Liability Concerns to Support Cleanup and Reuse of Contaminated Lands.
Infrastructure for Renewable Energy
EPA’s RE-Powering America’s Land Initiative has developed discussion papers that explore topics related to creating successful renewable projects on contaminated lands, landfills, and mine sites. The topics include:
The Value of Existing Infrastructure for Renewable Energy Development
Many formerly contaminated sites have existing infrastructure such as connections to the power grid, sewer lines or roads. In this paper you will learn about how to consider the economic value of existing infrastructure that may be available at the site. Find out more about the main types of existing infrastructure on RE-Powering sites and why they are valuable for renewable energy development.
RE-Powering Critical Infrastructure
Extreme weather events and natural hazards that can cause long-term power outages for critical infrastructure also create vulnerabilities for renewable energy installations. Location and building standards and best practices should be applied to protect renewable energy installations. Renewable energy in combination with a decentralized electricity grid can make communities more resilient.
To demonstrate how RE-Powering projects could be a part of a community’s energy resiliency portfolio, RE-Powering developed a methodology that can be used to evaluate the potential for RE-Powering sites to support critical infrastructure assets, including in emergency situations, and to identify specific EPA-screened sites with the best potential for supporting wastewater treatment infrastructure.
The study evaluated over 80,000 RE-Powering sites and nearly 17,000 wastewater infrastructure units. This methodology can be applied at national or local scales to other infrastructure (e.g., hospitals, schools, emergency centers, cell towers, fire stations, natural gas distribution centers, and others) if needs information can be calculated.
Interconnection: Plugging RE-Powering Sites into the Electric Grid
Are you a developer or local planner who wants to better understand the interconnection process for connecting renewable energy projects to the electric transmission and distribution systems? This discussion paper will help you understand the factors that influence cost and review cycles for interconnection.
How can I finance a project?
Renewable energy financing options vary by project size, ownership models, the type of power sales involved, and available incentives and programs. While there is no one-size-fits-all solution, there are two actions common to all financing decisions:
- Selecting the right combination of ownership and power sales for the project
- Identifying financial incentives and programs available for the project
How do I Select among Ownership and Power Sales Options to Finance my Project?
Financing options are driven by who is the primary user or "offtaker" of the electricity produced and sold by the project. The four most common types of ownership and power sales options are discussed below.
1. Self-Ownership (of project) & On-Site Consumption of Power
For smaller projects, it is common for the site owner to use the electricity produced by the project to reduce the owner’s electric utility bills. In these cases, the site owner can pay for site redevelopment and construction and then own the energy system outright. Examples of this financing option include:
- Dayton, OH: The site owner constructed a geothermal heating and cooling system to serve a new business technology campus on a former GM thermal systems facility with contamination.
- Richmond, VT: The site owner was able to achieve net zero energy usage through the inclusion of on-site rooftop and parking canopy solar arrays on a mixed-use redevelopment at the site of a former dairy factory with contamination.
In some cases, battery storage is added to a renewable project to provide resilience against grid power outages and/or reduce the site owner’s peak demand and time-of-use utility charges. If so, for this option and the option below, the battery storage can typically be financed together with the renewable system.
2. External Ownership & On-Site Purchase & Consumption of Power
Alternatively, to avoid the need for upfront capital expenses, site owners can retain ownership of the land while financing the renewable system. Under a lease, power purchase agreement (PPA), energy savings performance contract, or energy-as-a-service contract, a renewable energy firm can construct, own, operate, and maintain the system. This is also called “third-party ownership” because neither the site owner nor the utility owns the system. Third-party ownership is allowed for solar projects with the site owner as offtaker only in certain states [(click on "Third-Party Solar Power Purchase Agreement Policies" at DSIRE® Detailed Summary Maps for a list of state policies)]. Examples of this financing option include:
- Northeast of Las Vegas, NV: Working with the local utility and a private renewable energy firm, Nellis Air Force Base has a 20-year power purchase agreement for solar electricity from a 140-acre solar project that covers 33 acres of a capped landfill at its site.
- Wise, VA: The Mineral Gap Data Center has electricity supplied from a solar project on an adjacent, former coal mine site. Construction and operations of the solar project is led by a private renewable energy firm.
In the examples for financing options 1 and 2, the site owner is the offtaker. The site owner must retain the renewable energy certificates (RECs) or energy attributes produced by the renewable project to credibly claim it is consuming green power.
3. External Ownership & Off-Site Power Sales (without Community Solar)
In another financing option, the local utility or a renewable energy firm is responsible for financing, construction, ownership, operation, and maintenance of the renewable project on a potentially contaminated site. Instead of selling power to the on-site customer, the utility or renewable firm produces wholesale power and supplies it to off-site customers or sells it into the broader market. The site owner usually receives ongoing land lease payments during project operations as part of this financing option. Examples of this financing option include:
- Lackawanna, NY: A former Bethlehem Steel mill was redeveloped following RCRA Corrective Action/Brownfields cleanup into wind farms (Steel Winds I and II) with total capacity of 35 megawatts (MW) and which sell their output into the regional wholesale market under a long-term contract.
- DePue, IL: A brownfield was repurposed into a 27 MW solar project that sells its output to local utilities.
4. External Ownership & Community Solar
In many states, the financing option with external ownership and power sales covers renewable energy projects on contaminated lands projects that are part of community solar programs. Such programs enable renewable firms or utilities to partner with business and residential consumers, who subscribe to purchase local power for a given period. Depending on state utility rules and the details of community solar programs, the projects can be owned by the local utility, a renewable energy firm, or the local community. The site owner usually receives ongoing land lease payments during project operations as part of this financing option. Examples of this financing option include:
- Fort Collins, CO: The Coyote Ridge community solar project covers a landfill buffer area and is managed by the local utility, Poudre Valley Rural Electric Association.
- Eagan, MN: The Seneca community solar project provides subscribers, including local government agencies, with power from an array atop a landfill holding incinerated ash from an adjacent wastewater treatment plant. The project is owned by a renewable developer.
- Washington, DC: The Oxon Run community solar project provides members of the surrounding community with power supplied from a brownfield previously contaminated with petroleum residues from nearby gas stations. The project is owned by the District of Columbia government.
As of 2024, the RE-Powering Tracking Matrix shows wholesale power sales (the third of four options above) as the approach used by more than 50% of the 624 completed RE-Powering projects that have been tracked nationwide, with community solar and site owner offtaker arrangements representing 70 or more completed projects each. Community solar (the fourth of four options) is the fastest-growing approach among RE-Powering projects.
The table below summarizes the factors that can affect whether a financing option is applicable to a given site. The site owner retains ownership of the land in all of these options.
Ownership and Power Sales Option | Project Size Minimum | Project Size Maximum | Site Owner Capital for Project | Available Nationally |
---|---|---|---|---|
1. Self-Ownership (of project) & On-Site Consumption of Power | No minimum | Limited by on-site power needs | Required | Yes |
2. External Ownership & On-Site Purchase & Consumption of Power | No minimum (but small projects will have higher per-kilowatt financing costs) | Limited by on-site power needs | Not required | No (because some states have third-party ownership PPA or system lease restrictions) |
3. External Ownership & Off-Site Power Sales (without Community Solar) | Typically 5 acres | No maximum | Not required | Yes (the types of transactions available for this option vary by region) |
4. External Ownership & Community Solar | Typically 2 to 5 acres | Typically 25 acres; varies state-by-state | Not required | No (requires state or local community solar program) |
The types of transactions covered by the third financing option (external ownership & off-site power sales) in the table above include:
- Long-term PPA solicited by a vertically-integrated utility.
- Qualifying Facilities contract (under the Public Utility Regulatory Policies Act) with an electric utility.
- PPA with a competitive generation retail supplier or a community choice aggregator.
- Virtual PPA with a corporate end-use electricity customer.
- "Merchant" transaction (i.e., direct electricity sales into a wholesale power market without a long-term sales agreement with specific offtakers).
RE-Powering, with support from the U.S. Department of Energy’s National Renewable Energy Laboratory, developed the Economic Feasibility Tools Training Webinar to summarize how projects are typically developed and highlight various tools that support financing decisions and other aspects of early-stage renewable energy project development.
For additional information on financing-related resources and tools, see:
How do I Identify Available Incentives and Financing Programs?
This question is typically answered after selecting the appropriate ownership and power sales model (How do I Select among Ownership and Power Sales Options to Finance my Project) for a project. To lower the net costs of project development and improve access to funding, the federal government, many states, and other jurisdictions offer incentives and financing programs applicable to renewable energy projects in general. A growing number of jurisdictions also have incentives specifically applicable to renewable projects on "RE-Powering sites" (i.e., landfills, mines, and formerly contaminated sites). Other non-financial incentives, such as streamlined environmental permitting, are available for renewable projects on RE-Powering sites in some areas (e.g., Massachusetts, New Jersey, New York, and Virginia) and reduce time to development.
Incentives affecting renewable energy development may be available at various levels of government as well as from electric utilities. See the Database of State Incentives for Renewables & Efficiency® (DSIRE®) for information on federal, state, local, and utility incentives and other policies available for renewable energy and other types of clean energy. The DSIRE® website includes incentives and other policies without regard to their siting on potentially contaminated or non-contaminated lands. See the State Energy Loan Fund Map from the National Association of State Energy Officials for additional state financing information.
Incentives and financing programs with specific provisions applicable to renewable projects on RE-Powering sites or that may be relevant to RE-Powering sites are described below.
Federal Tax Incentives
As part of the 2022 revisions to renewable energy tax credits under the Inflation Reduction Act, there is an "energy community" production tax credit bonus and an investment tax credit bonus for installing wind, solar, and other qualifying renewable technologies at eligible brownfield sites; in communities with a coal mine closed after 1999 or a coal power plant closed after 2009; and in qualifying former oil and gas communities. Bonus values of up to 10% (for the production tax credit) or up to 10 percentage points (for the investment tax credit) are available for qualifying energy community projects. Depending on the technology, a given renewable energy project may have the ability to choose between receiving the production tax credit or the investment tax credit.
Please note: (i) the "energy community" brownfield definition relevant to the production and investment tax credits and the brownfield definition used to determine eligibility for federal brownfields funding are different; and (ii) EPA cannot make brownfield designations for tax credit purposes. The Internal Revenue Service-not EPA-has authority to administer these tax credits. For more information, see EPA Brownfields Program: Energy Community Tax Credit Bonus for brownfield sites and The Interagency Working Group on Coal and Power Plant Communities and Economic Revitalization (Energy Communities IWG) for a clearinghouse of information on ways to qualify as a production or investment tax credit energy community.
EPA Brownfields Grants and Loans for Site Assessment and Cleanup
EPA Brownfields grant and loan financing programs support environmental assessment, cleanup, and other pre-development activities for contaminated sites that are being considered for renewable energy development and many other types of reuse. Completed renewable projects that accessed EPA Brownfields funding and financing programs include:
- Charles Town, WV: A metal salvage yard was converted into a high-tech campus for the American Public University System containing rooftop and parking canopy solar arrays using several EPA assessment and cleanup grants.
- Ambler, PA: An EPA Revolving Loan Fund grant supported the redevelopment of a boiler house of a former asbestos manufacturing plant into office space with a geothermal heating and cooling system.
- Windsor, VT: A former Goodyear rubber manufacturing plant utilized an EPA Revolving Loan Fund grant to remove asbestos-contaminated debris as part of its clean up and now hosts a ground-mount solar project with output sold into the local market.
Interested in learning practical insights about how to apply for an EPA Brownfield cleanup grant with a solar as an intended reuse? Read a Q&A recap with Pittsburgh’s Urban Redevelopment Authority (pdf) here.
See How to Develop Sites for Renewable Energy to identify where assessment and cleanup activities often occur in the renewable project development cycle.
Greenhouse Gas Reduction Fund
The Inflation Reduction Act authorized the EPA to create and implement the Greenhouse Gas Reduction Fund, a historic $27 billion investment to combat the climate crisis by mobilizing financing and private capital for greenhouse gas- and air pollution-reducing projects in communities across the country. Together, the Greenhouse Gas Reduction Fund’s National Clean Investment Fund, Clean Communities Investment Accelerator, and Solar for All programs will finance clean technology deployment nationally, finance clean technology deployment in low-income and disadvantaged communities while simultaneously building the capacity of community lenders that serve those communities, and spur adoption of clean distributed solar energy that lowers energy bills for millions of Americans in low-income and disadvantaged communities.
The Greenhouse Gas Reduction Fund represents financing and funding opportunities for RE-Powering projects, such as grants and loans for project development. The Solar for All (SFA) program will provide nearly 1 million low-income households across the country with access to the benefits of solar energy generation and storage. To find information on SFA funding opportunities, contact the SFA recipient serving your geography directly; a list of all recipients, and contact information, is on the EPA SFA webpage. The National Clean Investment Fund (NCIF) and Clean Communities Investment Accelerator (CCIA) programs will finance tens of thousands of projects, especially focused on three high-impact sectors: renewable energy generation, deep energy retrofits of buildings and construction of new net zero buildings, and zero-emissions transportation. NCIF will have a national scope, while CCIA funding will be deployed to low-income and disadvantaged communities through a network of hundreds of local community financial institutions such as credit unions, minority depository institutions, and community development finance institutions. To learn more about potential opportunities for NCIF and CCIA, contact the recipients directly. Contact details on the eight grant recipients and their respective programs – including final program workplans and contact information for each – can be found on EPA’s NCIF and CCIA webpages.
Climate Pollution Reduction Grants and Other Federal Programs
EPA’s Climate Pollution Reduction Grants (CPRG) Implementation Grants program awarded grants to implement renewable development on brownfields, landfills, and other types of RE-Powering sites in several locations including Michigan, Nebraska, and Cuyahoga County, Ohio. There may also be redevelopment measures identified in Priority Climate Action Plans developed as a deliverable under the CPRG Planning Grants where other funding opportunities can be used for implementation.
There are additional federal financing programs that address renewable energy without components specific to RE-Powering sites, including the Empowering Rural America Program that provides loans and grants to rural electric cooperatives for renewable energy projects or to support various other energy infrastructure upgrades and projects. The Inflation Reduction Act Guidebook contains a broader list of relevant programs.
State Incentives and Financing Programs
As of 2024, at least 12 states have direct financial incentives or procurement preferences specifically directed at renewable projects on contaminated lands. The design of these programs varies widely from state-to-state based on the characteristics of the local power market and available sites as well as existing energy policies in the jurisdictions. Examples of state programs include:
- Illinois’ requirement that at least 3% of new solar RECs from utility-scale projects must be obtained from brownfield sites (inclusive of landfills) and closed coal mines.
- Virginia’s requirement that at least 200 MW of new, utility-procured renewable generation from the state’s largest utility be located on previously developed sites including, but not limited to, brownfields, landfills, and coal mines.
- Bonus incentives for brownfield or landfill solar projects that are added to statewide solar policies in Massachusetts and New York.
The federal funding provided by the Greenhouse Gas Reduction Fund and Climate Pollution Reduction Grants may lead to additional RE-Powering-focused programs administered by states and other jurisdictions in the future. However, each state program has unique rules, including if and how various federal and state incentives can be combined.
For information on program specifics and the positive effects of existing state-level programs supporting renewable development on RE-Powering sites, see Impacts of State Incentives and Policy.