Indiana Brownfields Program
Overview of Indiana's Brownfields Program administered by the Indiana Finance Authority. Assessment assistance, comfort letters, and redevelopment incentives.
Overview
The Indiana Brownfields Program is administered by the Indiana Finance Authority (IFA), not by IDEM. This is a significant structural difference from most states, where brownfield programs are housed within the environmental agency. The Indiana General Assembly charged IFA with implementing the program in 2005 under Public Law 235-2005 (Senate Enrolled Act 578), reflecting the program’s emphasis on economic development and community investment rather than regulatory enforcement.
The program assists communities and eligible private entities in addressing environmental concerns at abandoned, inactive, or underutilized commercial or industrial properties where actual or potential contamination complicates their expansion or reuse. The primary goal is to identify and mitigate environmental barriers that impede local economic growth by offering government assistance for site assessment and cleanup activities as an incentive for brownfield redevelopment.
Some IDEM project managers are housed within the Brownfields Program to provide environmental technical support. This hybrid structure - financial authority administration with embedded environmental agency staff - is intended to combine development expertise with technical environmental knowledge.
Key Distinction from VRP
The Brownfields Program and the Voluntary Remediation Program serve complementary but different purposes, and they frequently work together on the same properties:
- The VRP focuses on environmental cleanup and liability release. It typically works with owners, operators, or parties responsible for contamination who want to clean up the property for environmental and legal closure. The VRP endpoint is a Certificate of Completion and Covenant Not to Sue.
- The Brownfields Program focuses on redevelopment and community investment. It typically works with parties who are not responsible for causing the site contamination but are interested in assistance with reusing or redeveloping the property. The Brownfields Program provides financial, legal, and technical tools to overcome the barriers to redevelopment.
In practice, many brownfield sites use both programs. A property may receive assessment assistance through the Brownfields Program to characterize contamination and estimate costs, then enter the VRP to complete the formal investigation and remediation required for a Certificate of Completion and Covenant Not to Sue.
Program Services
Environmental Site Assessments
The Brownfields Program provides environmental site assessments to units of government to evaluate environmental issues that may be encountered during redevelopment. These assessments help characterize the type and extent of contamination, identify potential exposure pathways, estimate cleanup costs, and inform decisions about whether to proceed with redevelopment. The assessment work follows the RCG framework and is conducted by environmental consultants working for the program or by IDEM project managers embedded in the program.
Comfort and Site Status Letters
Fear of environmental liability is one of the primary barriers to brownfield redevelopment. Prospective purchasers are often unwilling to assume the risk of undetermined cleanup costs because the potential environmental liability at these properties is unknown, leaving properties idle.
The Brownfields Program has developed Comfort and Site Status Letters (under IDEM Nonrule Policy Document W-0051, issued April 18, 2002) to reduce this barrier. These letters describe the environmental status of a property and IDEM’s intentions regarding the site. They are designed to limit the liability of past actions by previous owners and provide prospective purchasers or developers with a degree of regulatory certainty.
Comfort letters do not provide the same level of liability protection as a VRP Covenant Not to Sue, but they can be sufficient for many brownfield transactions where full VRP closure is not required or is not yet complete.
Financial Assistance
The Brownfields Program offers financial assistance for brownfield redevelopment through several mechanisms:
- State grants and low-interest loans administered by IFA in conjunction with IDEM
- Federal EPA Brownfield Assessment Grants for site characterization and planning
- Federal EPA Brownfield Cleanup Grants for remediation at eligible properties
- LUST Trust Fund monies for petroleum cleanup at eligible LUST sites (the Brownfields Program has administered LUST cleanup funding on behalf of IDEM’s LUST program, including approximately $4 million in ARRA funding)
IFA evaluates its brownfield incentives on an ongoing basis to assist communities in leveling the playing field between developing brownfields and greenfields (previously undeveloped land).
Technical Support
IDEM project managers embedded within the Brownfields Program provide technical guidance on investigation and cleanup requirements. The RCG framework (WASTE-0046-R2) applies to brownfield sites in the same way it applies to other contaminated properties, ensuring consistent risk-based standards regardless of the program administering the cleanup.
Community Outreach
The Brownfields Program has conducted workshops across Indiana to inform stakeholders about available resources for brownfield redevelopment. IFA also organized the Interagency Brownfields Task Force, which brings together representatives from state agencies to collectively share and present resources for brownfield redevelopment.
Institutional Controls
The Brownfields Program maintains records of institutional controls (environmental restrictive covenants) required at program sites. The program site list, updated periodically, serves as the public record of these institutional controls.
The IDEM Institutional Controls Registry provides a broader listing of sites with institutional controls across all IDEM cleanup programs, sorted by county. This registry includes sites from the Indiana LUST program, VRP, Indiana State Cleanup Program, RCRA Corrective Action, federal programs, and the Brownfields Program.
Program Site List
IFA maintains a public list of sites where the Brownfields Program has provided financial, legal, or technical assistance. The list is updated periodically (most recently February 2026) and includes planned response actions. This list is not an inventory of all brownfield sites in Indiana - it reflects only sites where the program has been directly involved.
The site list includes properties across various IDEM cleanup programs, since brownfield properties may also be enrolled in the LUST program, VRP, State Cleanup Program, RCRA Corrective Action, or federal programs simultaneously.
Cleanup Standards
Brownfield site cleanups follow the same Remediation Closure Guide (RCG, WASTE-0046-R2) and Published Level Tables used by all IDEM cleanup programs. The 1E-05 cancer risk level and HQ of 1 apply uniformly, and the same Published Level Tables are used regardless of whether the cleanup is being managed through the Brownfields Program, VRP, or another program.
This unified framework simplifies the process for consultants working on brownfield sites - the investigation methods, screening levels, and closure criteria are identical to any other IDEM cleanup project.
Comparison to Ohio Brownfield Redevelopment Program
- Administrative structure: In Indiana, the Brownfields Program is administered by IFA (a finance authority), emphasizing the economic development focus. In Ohio, the Brownfield Redevelopment Program (BRP) is administered by Ohio EPA’s Division of Environmental Response and Revitalization, the same division that handles enforcement-driven cleanups.
- Financial tools: Indiana’s approach couples financial incentives through IFA with technical environmental support through embedded IDEM staff. Ohio’s BRP operates within the same agency that handles enforcement, with financial assistance available through state brownfield grants and the Clean Ohio Fund.
- Cleanup framework: Indiana brownfield cleanups follow the unified RCG at 1E-05 risk level. Ohio brownfield cleanups may follow VAP rules (OAC 3745-300) or DERR guidance, depending on the specific program track.
- Voluntary program coordination: Both programs coordinate closely with their respective voluntary cleanup programs (Indiana VRP and Ohio VAP) for formal liability protection through Certificates of Completion/No Further Action letters and Covenants Not to Sue.
Source
Public Law 235-2005 (Senate Enrolled Act 578). IDEM Nonrule Policy Documents: Brownfields Program Comfort and Site Status Letters (W-0051, April 18, 2002), Remediation Closure Guide (WASTE-0046-R2). Indiana Finance Authority Brownfields Program.