Contributed by Jenny Black, Brownfield Specialist, PPM Consultants
Everyone loves the idea of “free money.” After all, who wouldn’t want federal dollars to help clean up contaminated properties, revitalize tired neighborhoods, and spark community redevelopment?
But here’s the truth many communities don’t want to face: Brownfield Grants from EPA are not free. They are compliance-heavy, time-sensitive commitments that can either position your community for long-term success—or overwhelm you if you’re unprepared.
The question isn’t “Do we want the money?” It’s “Are we truly ready to manage it?”
The Myth of Readiness
As EPA gears up to release its new Brownfield Grant guidelines, you’ll see a wave of promotional trainings, webinars, templates, and fact sheets. These resources are valuable, but they often skim the surface.
What they rarely ask is the harder, less glamorous question: Does your organization have the internal systems and capacity to actually handle federal funding?
Take EPA’s Pre-Award Compliance Review (Form 6600-09). On paper, it looks like a formality. In practice, it’s a stress test of whether your house is truly in order.
What EPA Actually Asks
Form 6600-09 drills into the realities of federal grant management. For example:
- Can your accounting system track EPA funds separately from other revenues and produce accurate, timely financial reports?
- Do you have written policies on cash management, procurement, and property controls that align with federal requirements?
- Are separation of duties and safeguards in place to prevent fraud, waste, or abuse?
- Do you have current nondiscrimination and civil rights policies?
- Has your organization resolved any past audit findings?
- Do you have a federally approved indirect cost rate—or a plan to negotiate one?
These aren’t box-checking exercises. They are the foundation of whether your community is ready to not only win the grant, but to successfully manage it.
The Overlooked “Programmatic Capabilities”
Every EPA Brownfield Grant application also requires a section on Programmatic Capabilities. This section asks you to demonstrate:
- A history of successfully managing federal or state grants
- Qualified staff with experience in both environmental projects and federal compliance
- Procurement and contracting systems aligned with EPA rules
- Clear processes for reporting and maintaining compliance over the life of the grant
In other words, EPA isn’t just funding your cleanup plans. They’re funding your ability to manage the money responsibly. And no matter how compelling your site stories are—if your programmatic house isn’t in order, your application is at risk.
The Risks of Being Unprepared
Winning the award is just the beginning. Once funds arrive, the clock starts ticking, and compliance obligations come fast. Communities that aren’t ready can quickly find themselves facing:
- Disallowed costs because expenses weren’t documented properly
- Audit findings that jeopardize future funding opportunities
- Clawbacks of funds if requirements aren’t met
- Loss of credibility with EPA, local partners, and your community
We’ve seen this firsthand. Communities hire their first grants manager after receiving funds and scramble to catch up. Nonprofits discover their bookkeeping systems aren’t up to federal standards—only after they’re already on the hook. These aren’t minor roadblocks; they can derail entire projects.
Why Readiness Matters Now
EPA’s new guidelines are expected in the next 30 days. Many organizations wait for the Notice of Funding Opportunity before taking stock of their readiness. By then, it’s too late.
Readiness isn’t built in a month. It’s built on the systems you already have, the audit trails you can already produce, and the staff you already trust to manage compliance.
If you aren’t confident in those systems, the smartest move may be to sit out this cycle and use the year ahead to strengthen your foundation. That way, when the next round opens, you’re not just applying—you’re competing from a position of strength.
How PPM Helps
At PPM Consultants, we’ve spent decades helping communities across the Southeast navigate this very question: Are we really grant-ready?
Sometimes the answer is yes—and we guide clients through successful applications and award management. Other times, the most strategic advice we can give is to wait, build capacity, and come back stronger in the next cycle.
Because the true cost of chasing a grant you aren’t ready to manage isn’t just red tape. It’s the missed opportunity to transform your community when the timing is right.
Closing the Loop
Brownfield Grants are not free money. They are an invitation into a long-term partnership with EPA—one that demands accountability, transparency, and capacity.
So, before the guidelines drop, ask yourself the questions EPA will ask:
- Can we manage the dollars with precision?
- Are our systems audit-ready?
- Do we have the staff and policies to sustain compliance?
If the answer isn’t clear, now is the time to address it. At PPM, we help communities answer this question honestly, strategically, and with confidence. Because the difference between being “grant-hoping” and “grant-ready” could decide the future of your community’s redevelopment. Is your community ready?
If you have any questions about the upcoming grant cycle, please feel free to send those to me at jenny.black@ppmco.com.