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Frequent Questions About School Siting Guidelines

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Public Involvement

How do the Guidelines address community involvement in the school siting process?

The Guidelines emphasize the importance of meaningful public involvement throughout the school siting process. The Guidelines recommend that at the beginning of the school siting process, the local education agency (LEA) should create a public involvement plan and formalize the role of the public, including reviewing potential locations, environmental reports, cleanup plans and long-term stewardship plans. EPA recommends forming a school siting committee (SSC) that includes representatives from the community to make recommendations to the LEA throughout the siting process.

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Existing Schools

Do the Guidelines apply retroactively to previous siting decisions?

No. The Guidelines are not designed for retroactive application to existing school locations or previous school siting decisions, but rather to inform and improve future school siting decision-making processes. However, irrespective of these Guidelines, EPA recommends that districts periodically inspect existing schools for potential environmental health and safety risks. These inspections should use tools designed for that purpose, such as the NIOSH Safety Checklist Program for Schools. Where deficiencies are found, EPA recommends steps to reduce student and staff exposure to potential hazards be identified and implemented, to the maximum extent practical.

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Do the Guidelines address the retention and renovation of existing schools?

Yes. The siting decision often starts with evaluating existing schools and their suitability to be updated to meet the future needs of the LEA. The Guidelines recommend that communities consider renovation, repair and/or expansion options before deciding to build a new school. Many existing schools can be retrofitted with new technologies to expand their useful life, possibly at a lower cost and with fewer environmental impacts (e.g., energy savings, less impact on open space) than new construction. Renovating existing neighborhood school facilities can provide an impetus for community revitalization, have an impact on neighboring property values, encourage investment in schools by community members and preserve irreplaceable community assets.

EPA recommends that districts periodically inspect existing schools for potential environmental health and safety risks. These inspections should use tools designed for that purpose, such as the NIOSH Safety Checklist Program for Schools. Where deficiencies are found, EPA recommends steps to reduce student and staff exposure to potential hazards be identified and implemented, to the maximum extent practical.

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Will the Guidelines prevent pollution generating facilities from being built near existing schools?

Land use decisions are generally made at the local level, subject to the local jurisdiction's zoning and other land use policies. While many types of industries, commercial operations and transportation infrastructure projects are subject to state, tribal and/or federal environmental or other regulations, the requirements vary. However, the recommendations in these Guidelines can be used by planning and environmental agencies in land use and permitting issues to the extent applicable.

EPA recommends that states, tribes and communities evaluate siting and permitting processes that influence where potential sources of environmental pollution (see source categories identified in Exhibit 6: Screening Potential Environmental, Public Health and Safety Hazards (PDF) (12 pp, 284K) may be allowed to locate with respect to schools. While these land use decisions are highly complex and beyond the scope of these guidelines, states, tribes and communities should seek to avoid situations in which new nearby sources of potentially harmful pollutants are sited in such close proximity to schools that they may pose a potential hazard to the school occupants.

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What can I do to protect my child right now from environmental hazards at their current school?

There are many steps that parents can take to help promote healthy school environments. EPA has resources (see below) for parents in a number of programs that are designed to help schools and communities take action to protect children's health in one of the most important places - where children learn. EPA also encourages parents to partner with schools and local community planners to make school walking and biking routes safer for children. This encourages more active transportation choices which results in fewer vehicles on the road.

  • EPA Schools site - This site provides links to EPA and other programs addressing environmental health issues in schools, from air pollution and asbestos to chemical management, pesticides, water conservation, and more.

  • Reduce engine idling around schools, clean up old school buses and reduce other diesel emission sources in the community - School buses are a safe way for children to get to school. However, pollution from older diesel vehicles has health implications for everyone, especially children. The goals of the "Clean School Bus USA Campaign" are to reduce children's exposure to diesel exhaust and the amount of air pollution created by diesel school buses. Schools can also encourage the reduction of personal vehicle idling and overall use on campus. Get tips on how to reduce engine idling and diesel emissions around schools and in the community.

  • Protect indoor air quality at schools - Improving and protecting indoor air quality at schools is important to children's health. Indoor levels of air pollutants can be two to five times higher than outdoor levels. Sources of poor indoor air quality in schools range from inadequate ventilation systems to fumes from pesticides and cleaning agents. Many of the nation's schools are implementing indoor air quality management programs, most of which are based on EPA's voluntary Indoor Air Quality Tools for Schools Program, which helps schools identify, resolve and prevent indoor air quality problems using mostly low- and no-cost measures.

  • Use integrated pest management - Integrated pest management (IPM) is an environmentally friendly, common sense approach to controlling pests and can provide safer, often less costly ways to control pests. IPM is not a single pest control method but rather involves integrating multiple strategies based on the site.
  • Ensure drinking water quality - Consuming enough fluids on a daily basis is important for children's healthy, and water is a healthy choice. Ensuring that children receive safe drinking water at their schools and child care centers is important because that's where children spend part of their day, and they are likely to drink water while they are there. Schools and child care centers can find on EPA's website information about lead in drinking water, source water protection, water conservation, cross-contamination, and other best management practices to assist schools and child care centers in providing safe drinking water to students and staff.
  • Manage chemicals safely - From elementary school maintenance closets to high school chemistry labs, schools use a variety of chemicals. When they are mismanaged, these chemicals can put students and school personnel at risk from spills, fires and other accidental exposures. EPA's school chemical cleanout campaign website gives K-12 schools information and tools to responsibly manage chemicals. Read more about Schools Chemical Management.
  • Protect students and staff from the sun - Too much sun can lead to heat stress and unhealthy exposure to UV radiation. EPA's SunWise program provides information and materials to schools, educators, and parents to help them prevent the cancer and blindness caused by UV.
  • Create Safe Routes to Schools - The U.S. Department of Transportation's Safe Routes to School program encourages schools and communities to improve infrastructures and educational programs to encourage more children to safely bike or walk to and from school.

Examples of EPA-funded projects in communities:

  • Community-Based Air Toxics Projects - EPA supports air toxics projects in about 30 communities across the nation to help inform and empower citizens to make local decisions concerning the health of their communities.

  • Make simple choices on the road - Doing your part to improve air quality and reduce traffic congestion around schools and in your community is easy. Incorporating even a few of the simple steps offered here can help clean the air and reduce traffic congestion.

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Environmental Hazards

Shouldn't schools be built as far away from major pollution generating sources as possible?

When acceptable alternative sites exist within the neighborhood(s) being served by the new school, the Guidelines recommend that the LEA and SSC seek to avoid sites that are either on or in close proximity to land uses that may not be compatible with schools during the initial screen of candidate sites. These include locations that have onsite contamination that has not been addressed, major pollution sources, clusters of industrial facilities or other potential hazards (see the Environmental Siting Criteria Considerations section). If no acceptable alternative sites exist, it is critically important for the LEA and SSC to fully explain the absence of alternatives in a transparent manner and fully engage the public in identifying and implementing both site-specific and community-wide exposure and risk reduction strategies.

High traffic roads can be a major pollution source that requires careful consideration and evaluation by the LEA and SSC because these sources are common and there is typically a direct relationship between the transportation system and the accessibility of the school for staff and students. The Guidelines recommend that when practicable, a chosen school site should be as far from high traffic roads as feasible. High traffic roads may include highways, local roads experiencing heavy congestion, local roads with significant stop and go activities, and roads with large numbers of trucks. Since high traffic roads are very common, especially in urban areas, it may be difficult to find locations away from these roads yet still be located within the community being served by the new school.

Under these circumstances, the LEA and the SSC should consider a number of factors in making the best choice for student health, safety and accessibility. These factors can include: 1) if the school site and design provide an opportunity to place classrooms, playgrounds, athletic fields and air intakes as far from the road as possible; 2) whether barriers (e.g., noise barriers, nonsensitive buildings) or natural features (e.g., vegetation, berms) are or can be located between the school and road to reduce air quality impacts; and 3) whether certain sites allow students to walk/bike to school compared with alternatives that require bus and personal vehicle travel. Because of all of these factors and the difficulty in comprehensively assessing the advantages and disadvantages of particular sites under these conditions, an environmental professional should be consulted to provide assistance. More information is provided in Quick Guide for Environmental Issues.

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Isn't an uncontaminated site always the best location for a new school?

The best school location will be one that provides a healthy and safe learning environment for children, while also meeting a diverse array of other community goals. For example, integrating community centered schools into existing residential neighborhoods often allows for better environmental, community, economic, educational and public health outcomes. The Guidelines are intended to help communities appropriately consider environmental health and safety in the context of this complex decision-making process.

Of course, if uncontaminated structures or sites are readily available in the community the school is intended to serve, and meet the community's other important educational, economic and community criteria, selecting an uncontaminated location would be the ideal choice. However, such locations are rare in many urban communities, and often the LEA is faced with choosing among locations that have some level of contamination from prior uses or are close to potential sources of contamination. Building schools on the undeveloped outer edges of communities - often called greenfields - creates other problems such as increased transportation risks, longer transportation times and increased traffic-related air pollution, while reducing opportunities for students, parents and staff to walk or bike to school in their community.

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Can schools be safely built on sites with residual soil or ground water contamination?

Schools can be safely located on sites where all waste and contaminated media have been removed, as well as those with residual contamination, provided that the location is carefully managed over time to ensure that no exposure to the contamination can occur. In cases where complete removal of contamination is not feasible, exposures can be prevented through the use of engineering controls and/or institutional controls. For example, vapor intrusion from soil or ground water contaminated with certain chemicals can pose a risk to the people who use buildings that are located above the contamination. Engineering controls can be used to alter the flow of contaminated air or restrict land use in a specific area so that contaminated air does not enter the building's indoor air. The use of engineering and institutional controls can prevent exposures, but only if effective systems are in place to maintain and enforce them, such as periodic monitoring to ensure their continued protectiveness and safe operation. Nationwide, brownfields and other formerly contaminated lands, including those with residual contamination, now safely support housing, schools, clinics, hospitals and other reuses that meet community needs.

Criteria for establishing the degree of cleanup needed should be based on state or tribal cleanup rules or guidance, where they exist. The environmental standards used for determining the appropriate level of cleanup should be based on either 1) standards developed for schools or residential use, or 2) risk-based levels set for residential use. If the site will have residual contamination at concentrations above these levels after the cleanup has been completed, engineering and/or institutional controls will be needed to ensure no exposure occurs. As part of their review of the cleanup plan, state, tribal and local regulatory agencies should consider the ability of the LEA and other governmental bodies to effectively maintain those controls. In the event that there is concern that these controls cannot be effectively and reliably managed, then the LEA may need to clean the site to residential levels, or select another location.

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In cases where the best available location for a school relies on engineering and/or institutional controls to prevent potential exposures, how can the community work with the LEA and other responsible entities to ensure that those controls are effective for the life of the school?

Communities have an important role to play in ensuring that engineering controls and institutional controls remain in place and are effective in preventing potential exposures. Through the community involvement and planning process, the community can become familiar with the nature of residual contamination, engineering and institutional controls and any restrictions on how the land can be used. They can assist LEAs and help them meet their obligations by reporting actions in conflict with those land use restrictions to LEA management and state environmental regulatory authorities. The LEA and the SSC can also continue to play a role in updating the community about inspection, monitoring and maintenance over time, with the assistance of state technical oversight, as appropriate.

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What cleanup or remediation of contamination at a school site should be completed before the school is occupied?

Before a school or portion of a school is occupied, all contamination that could pose a risk of harmful exposure to students and staff should be removed or controlled. In cases where there is residual contamination, any necessary engineering controls and/or institutional controls should be in place and the site certified by the state or tribal regulatory agency as suitable for occupancy. For example, occupation of a school above a ground water plume that is undergoing remediation to clean the ground water should not pose a threat to students, faculty, staff or others unless there is a threat of vapor intrusion from the ground water. If the contaminated ground water poses a threat of vapor intrusion, any institutional or engineering controls should be in place at least for any portion of the school where there is a potential for exposure.

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To what cleanup standard should school sites be remediated?

Criteria for establishing the degree of cleanup needed should be based on state or tribal cleanup rules or guidance, where they exist. The environmental standards used for determining the appropriate level of cleanup should be based on either 1) standards developed for schools or residential use, or 2) risk-based levels set for residential use. If the site will have residual contamination at concentrations above these levels after the cleanup has been completed, engineering controls and/or institutional controls will be needed to ensure no exposure occurs. As part of their review of the cleanup plan, state, tribal and local regulatory agencies should consider the ability of the LEA and other governmental bodies to effectively maintain those controls. In the event that there is concern that these controls cannot be effectively and reliably managed, then the LEA may need to clean the site to residential levels, or select another location.

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Distances for Evaluating Environmental Hazards

Does EPA recommend buffer or exclusion zones (also sometimes called distance criteria or separation distances) to make sure schools aren't built close to major sources of pollution?

No, the Guidelines do not include distance-based buffer or exclusion zones for potential school locations. EPA's approach to the Guidelines is to encourage and promote an integrated and holistic evaluation of a wide range of community and location-specific criteria in selecting the best location for a new school. The distance between a school location and a major source of pollution is only one of many complex factors that influence whether that source poses risks of concern to students and staff (such as those included in Exhibit 5: Factors Influencing Exposures and Potential Risks).

These factors can only be effectively evaluated on a case- and location-specific basis and require consideration of the extent to which a specific source raises a concern for a potential school location, as well as the degree to which any risk can be reduced or eliminated. Some states and local governments have developed distance-based requirements or guidance for schools and other locations that may have sensitive receptors, and while EPA does not believe that establishment of buffer or exclusion zones at a national level is appropriate, this should not be construed as a criticism of those jurisdictions that have adopted or are applying buffer or exclusion zones as a useful tool. (Links to state regulations and guidance are available in the Resource page.)

EPA believes that establishing national distance criteria is likely to result in a variety of negative unintended consequences. For example, use of national distance criteria as the basis for selecting locations that are farther away from the children they serve, without careful consideration of location-specific factors, could create less healthy environments for students and staff through increased transportation risks, reduced opportunities for walking and biking and increased traffic-related air pollution.

EPA recommends that sound technical assessments of both onsite and nearby potential hazards be undertaken to determine whether such potential hazards might pose a threat to students or school staff. Locations should be excluded from further consideration if nearby or onsite hazards pose unacceptable risks that cannot be eliminated or reduced to an acceptable level.

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What is the difference between "screening perimeters," which are included in the Guidelines, and "buffer" or "exclusion" zones?

EPA has included some distance-based screening recommendations in the Environmental Siting Criteria Considerations section of these Guidelines under Exhibit 6: Screening Potential Environmental, Public Health and Safety Hazards. The screening perimeter distances are approximate distances for use in the initial screening process.

During this initial screening process, an environmental professional, the LEA and the SSC should identify all potential hazards that are within this distance of a prospective school location and determine those that need further evaluation. The screening distances included in the Guidelines are based primarily on existing state or local rules, laws, ordinances, policies or guidance and are intended as general rules of thumb. Potentially important sources that may be outside the recommended screening perimeters may also be appropriate for further evaluation. Screening distances, alone, may not be predictive of the actual potential for elevated exposures and risks from that source. Exposure to contaminants from a source could be non-existent, or could be significant.

To determine the potential for exposure, an assessment should be performed as part of the school siting screening and evaluation process. In contrast, buffer or exclusion zones are based on a presumption that there is a high potential for significant exposures from a source located within that zone. LEAs should work with the appropriate state response or tribal regulatory program in assessing school locations within the screening perimeter to determine if facilities pose a risk sufficient to influence siting location decisions or require alternative site selection. In the event that a facility poses a potential risk to students, staff, parents or others, the resolution of any unacceptable risk associated with that facility should be addressed before the decision to site a school.

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States and Tribes

The Guidelines place a lot of emphasis on state and tribal involvement in evaluating and approving siting decisions where environmental contamination is present. At a time of shrinking state and tribal budgets, how are states and tribes to meet the anticipated demand for more involvement?

EPA recognizes that elements of the recommended environmental review process may be beyond the current capacity of some LEAs and other participants in the process to fully implement with existing authorities, expertise and resources. All state and most tribal environmental regulatory agencies have programs in place to evaluate and approve cleanup plans for specific types of sites or projects. EPA encourages LEAs, states, tribes, communities and other interested organizations to work collaboratively and with EPA to identify opportunities to leverage these and other existing resources.  EPA also encourages them to identify and work toward fulfilling needs for improving local and state capacity to conduct as rigorous a process of site evaluation as possible.

EPA recommends that LEAs work directly with the state and tribal environmental response program regarding the needed evaluation and approval of cleanup plans. EPA also recommends that LEAs seek advice from state and tribal environmental response programs to ensure that long-term stewardship responsibilities are effectively met. See Recommendations for States and Tribes for more information. The Resources page of the Guidelines website contains potentially helpful funding and capacity building resources.

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Other Child-Occupied Facilities

Do the Guidelines apply to child care centers or other facilities where children spend time?

While the Guidelines are primarily intended to be used by local education agencies in evaluating and selecting locations for K-12 schools, EPA believes that the recommendations in the Guidelines represent a set of best practices that may inform and improve the evaluation and selection of locations for a wide range of settings where children spend time. However, EPA recognizes that there are many differences across the types of child-occupied facilities.

For example, most K-12 schools generally have a clearly identifiable central authority and significant (though not necessarily plentiful) resources, while many child care centers are small businesses with extremely limited resources and subject primarily to state licensing authorities. Nevertheless, the siting criteria considerations, environmental review process and public involvement practices recommended within the Guidelines may be applied, with appropriate adaptation, to a wide range of school-related institutions.

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