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Public Involvement in the Development of the School Siting Guidelines

In July 2009, EPA convened a special School Siting Task Group under the existing Children's Health Protection Advisory Committee (CHPAC) to provide early input to EPA on the content of the siting guidelines. The School Siting Task Group was composed of representatives from a wide range of national, state, tribal and local organizations.

The School Siting Task Group reviewed an initial draft and provided comments in April 2010 to EPA. EPA appreciates the work of the School Siting Task Group and the contributions made by all of its members. EPA incorporated many of the recommendations from the CHPAC letter and School Siting Task Group report into the guidelines.

Summary of Public Comments

The draft Siting Guidelines were posted for public review and comment for 90 days from November 2010 to February 2011. The issues raised in public comment are summarized below. During the public review comment period, EPA received valuable input and feedback from the general public, governmental and non-governmental organizations. All comments were considered in developing the final Siting Guidelines. Although this is not an all-inclusive list of each comment received, the following synopsis addresses many of the key issues and significant concerns that were expressed in the public comments.

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ISSUE: Accessibility and format of the guidelines.
Some commenters expressed concern that the format of the guidelines was not sufficiently user friendly and did not provide readers with an overarching understanding of the goals and the siting process in its entirety. These commenters recommended that EPA make the guidelines more user friendly by providing a sequential set of guidelines, including more cross-referencing of sections, and that EPA publish a hard copy version of the School Siting Guidelines in a traditional report format. Other commenters liked the Web format because a website can be readily updated, but agreed that a hard-copy version would also be helpful for those users who prefer a sequential "report" format.

RESPONSE:
The final guidelines are published as PDF for online viewing, downloading, or printing, and with website components to provide access to school siting related resources. The PDF includes a detailed table of contents and many cross-links and linked references to websites to allow for easier navigation and improve ease of use. The Web-based component provides direct access to the many resources beyond the guidelines themselves, which will help users make the best use of the guidelines, and this component can be readily updated as new information becomes available. The final guidelines include a new "Overview of the Siting Process" section with a chart outlining key components of the process for evaluating environmental considerations as part of the school siting process.

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ISSUE: Tracking, periodic review and updating of the guidelines.
Some commenters requested that EPA provide a timetable for periodically reviewing and updating the guidelines. Commenters also suggested that EPA track and analyze school siting practices in school communities and provide a national resource center or database of those practices.

RESPONSE:
EPA recognizes that information pertaining to school siting policies and decision-making is dynamic and will change on a regular basis. EPA will do its best to maintain and update the information on the website as appropriate. While EPA does not currently track school siting policies or decisions on a national basis, the Agency will explore options for doing so in the future.

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ISSUE: Applicability of the guidelines to existing schools.
Some commenters noted that the statement in the guidelines that the guidelines do not apply to existing schools could push districts to only consider new construction rather than renovation options. Other commenters thought that the scope of the guidelines should be expanded to address potential environmental health issues in existing schools.

RESPONSE:
If an existing school or other existing structure is being considered as the location for a school, these guidelines are applicable to that decision-making process. EPA’s statement that the guidelines do not apply to existing schools is intended only to clarify that the information in the guidelines is designed to improve the school siting decision-making process rather than call into question previously made school siting decisions. There are approximately 135,000 public and private schools in the United States, and it is likely that some existing schools may be located in proximity to one or more of the potential hazards discussed within the guidelines (U.S. Department of Education). However, due to many factors that affect exposure to environmental hazards (such as those included in Exhibit 5: Factors Influencing Exposures and Potential Risks and based on the regulations and protective measures that can be applied, proximity of a school to nearby sources of environmental contaminants may not pose unacceptable risks.

EPA has a considerable body of guidance and regulations that are specifically geared toward existing schools. EPA recommends that districts periodically inspect existing schools for potential environmental health and safety risks from both onsite and nearby hazards using tools designed for that purpose, for example 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. In some cases, school specific improvements can reduce potential hazards; in other cases, such as widespread air pollution or water quality issues, a community wide approach may be called for.

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ISSUE: Impact on jurisdictions with existing siting laws and procedures.
One major urban school district commented that the extensive public engagement and environmental review process outlined in the guidelines is not consistent with well-established state and local laws and policies that govern school siting in its jurisdiction. This commenter recommended that EPA abandon the structure of the guidelines and instead present a more flexible set of guidelines that can be considered within the context of existing state and local processes.

Other commenters felt that EPA overemphasizes the voluntary nature of the guidelines and that the disclaimer in the guidelines substantially diminishes their value in improving state and local processes.

RESPONSE:
The Energy Independence and Security Act of 2007 directs EPA to develop voluntary guidelines for siting schools. In developing the guidelines, EPA took into consideration the fact that there are many jurisdictions that make school siting decisions under existing state or local laws or regulations. EPA attempted to address this issue in several ways in the guidelines, including the following statement in the Limitations of the Guidelines section at the beginning of the document:

"The guidelines are designed to support state, tribal and community decision makers in evaluating their existing school processes and policies to address environmental factors in school siting and construction decisions, especially when the presence of contamination may pose a threat to a safe learning environment. These guidelines do not impose legally binding requirements on EPA, states, tribes, local governments, LEAs or the regulated community and may not apply to a particular situation based upon the circumstances. These guidelines do not pre-empt, supersede, or serve as a substitute for state, tribal or local school site or location selection policies or requirements.”

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ISSUE: The environmental review process is unrealistic and will hinder the selection of locations for schools.
A large school district was concerned that the process outlined in the guidelines would impose a confusing and cumbersome set of practices that would be both impractical and infeasible. This commenter also argued that the guidelines would likely discourage interest from private property owners to sell their properties for public school redevelopment because of the potentially lengthy and uncertain process of site evaluation and potential cleanup described in the school siting guidelines.

RESPONSE:
The environmental review process, as included, is illustrative. It provides a general, stepwise process for a local education agency to work with its local or state health department or environmental regulatory agency and existing legislative or policy frameworks to support school siting decision-making. Such a review helps to ensure that a prospective school site does not pose unacceptable health and safety risks to students and staff. EPA recognizes that an environmental review can be costly and time-consuming. For this reason, it may be desirable to try to avoid sites that have onsite contamination or are in very close proximity to pollution generating land uses at the initial stage of identifying candidate sites if other acceptable locations exist in the community that may pose fewer environmental challenges.

In the example environmental review process, EPA recommends that all sites under serious consideration undergo an initial screen and preliminary environmental assessment. If no environmental concerns are found in the preliminary assessment, no further assessment is needed. If potential environmental concerns are found, the local education agency (LEA) should select a different site or perform a comprehensive environmental assessment to ensure that environmental concerns are identified and remediated (i.e., cleaned up) or mitigated, as appropriate.

While EPA encourages communities to consider these guidelines in a comprehensive manner, communities may select key components of the guidelines to adopt or adapt to meet their existing planning needs, environmental regulations or public health rules and regulations. As noted earlier, these guidelines are voluntary.

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ISSUE: Long-range School Facilities Plan.
Several commenters urged EPA to expand the discussion of long-range school facility plans, to include the following recommendations:

  • School districts should examine the complete costs associated with all available options, including a new location, renovating an existing school and/or expanding an existing school;
  • Municipalities and planning departments should play active roles in long-range facilities planning from the very beginning of the school siting process;
  • Long-range plans should include a discussion of school transportation, specifically related to the anticipated percentage of students who would walk and/or bike to school and the resulting estimated cost and mileage of busing the remaining students; and
  • Long-range plans should identify community needs for sports and recreation.

RESPONSE:
The final voluntary school siting guidelines include an expanded discussion of the important role that long-range facilities plans can play in the decisions that local communities must make regarding plans for the renovation and construction of schools. While the development of long-range facilities plans is outside the scope of these guidelines, they present an important opportunity for meaningful public involvement on community decisions regarding schools, which can contribute to sound decisions regarding the locations for future school facilities.

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ISSUE: The guidelines should provide more emphasis and information on reuse of existing schools.
A significant number of commenters urged EPA to promote retention, renovation and reuse of existing schools in preference to new construction. These commenters described a wide range of community benefits that accrue from preserving existing schools whenever possible. Some commenters requested that EPA provide a wide range of tools to help districts analyze the complex factors that go into making the decision of whether to reuse an existing school or structure or build an entirely new structure. Several organizations encouraged EPA to place additional emphasis on the recommendation that communities consider whether an existing school or structure could be renovated to meet the community’s goals and needs and to provide more details on the benefits of reuse. These commenters argued that rehabilitating old schools has the benefit of keeping older neighborhoods intact. One element of this comment was the need to consider the implications of hazardous materials for reuse, demolishing and disposal.

Conversely, one large school district commented that these issues are outside the scope authorized under Section 502 of the Energy Independence and Security Act.

RESPONSE:
EPA agrees that in many instances renovation or adaptive reuse of existing schools or structures is a preferred option and noted at the beginning of the Environmental Siting Criteria Considerations section of the guidelines that: “The first criterion to consider is whether a new school is needed. Communities should consider renovation, repair and/or expansion options before deciding to build a new school.” The final guidelines retain this emphasis on considering renovation or adaptive reuse and identify a number of factors that should be considered as part of this decision-making process, including full consideration of environmental, public health and economic impacts of school renovation or construction.

EPA recognizes and supports consideration of reusing and upgrading existing schools, where possible and feasible. When location or property constraints or other factors make that impractical, LEAs and communities may need to explore options for new school siting and construction.

EPA has made an effort to identify and improve access to a variety of tools within the guidelines to help communities make these decisions; these tools are available under the renovation of existing buildings topic on the Resources page. However, the suitability of an existing school or structure for renovation and/or reuse has to be assessed on a case-by-case basis due to multiple complex factors that impact the decision.

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ISSUE: Considerations related to potential racial segregation.
A number of commenters were concerned that the guidelines do not mention how patterns of racial segregation should factor into school site selection. Commenters recommended that more discussion on this issue be added to the guidelines.

RESPONSE:
Economic, racial and ethnic segregation is a continuing challenge across the country. More diverse schools can provide educational as well as life attainment benefits to all school age children. While community centered schools can be part of improved educational, economic, community and public health outcomes for children, families and neighborhoods, LEAs should balance these issues with meeting the goal of diverse school populations. Techniques are available to help achieve the multiple goals of diverse student populations and schools located within the communities they serve. The Resources page contains information about techniques that have been identified to support these goals. While federal and state laws that address student diversity in public school districts are complex and beyond the scope of these guidelines, the revised guidelines include a summary of the major relevant federal laws in the Limitations of the Guidelines section.

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ISSUE: Public involvement opportunities.
One commenter highlighted the components of an effective public involvement process, which extend to providing the public with options and a forum to express their opinion and/or make a determination on the available options. Commenters also suggested that the information on public involvement encompass the siting process as a whole rather than focusing exclusively on the environmental risks and that the guidelines provide guidance on critical elements and/or key components that would be included in a successful public involvement plan.

RESPONSE:
The guidelines have been revised to provide more information on opportunities for public involvement and to emphasize the importance of meaningful public involvement throughout the school siting process. Exhibit 2: Meaningful Public Involvement Points and Opportunities was revised to encompass the entire process of considering environmental factors in school siting decisions, as described in these guidelines, instead of just the environmental review process.

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ISSUE: Membership of the School Siting Committee.
A significant number of commenters suggested additions and/or clarifications to the stakeholder groups that should be included as school siting committee (SSC) members. There was particular emphasis on ensuring engagement of groups that support healthier lifestyles through increased physical activity and eating behaviors. There was also a recognition that SSC members should have the necessary skills and knowledge to work effectively, and that measures are needed to achieve this objective. The importance of providing the public with training and technical assistance opportunities was emphasized by some commenters. Other commenters emphasized the need to facilitate access to independent technical assistance as a valuable contribution to meaningful public involvement.

One commenter opposed the formation of the SSC, suggesting that the requirements are burdensome and inconsistent with existing laws and policies. This issue is discussed elsewhere in this section.

RESPONSE:
In developing the guidelines, EPA recognizes the importance of the commenters’ emphasis on effective participation by a wide range of stakeholders. This is especially important for stakeholders representing environmental justice concerns, stakeholders from low-income communities and other stakeholders who play a critical role in informing decisions related to the school siting process. The final guidelines were revised to address these comments in a number of ways. The text of the guidance has been clarified to identify additional relevant stakeholders for inclusion on the SSC, and the potential purpose of the SSC has been expanded to consider processes for effective public engagement. Further, additional technical assistance and training resources intended to enhance the skills of the SSC members, as well as the public are identified in the Resource page (e.g., Technical Assistance and Capacity Building).

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ISSUE: Technical assistance and training.
Some commenters noted that EPA should provide training and tools that can be used by the SSC and by community members to better understand and participate in the siting process. Several other commenters suggested that as an alternative solution to training and tools, communities could draw on independent technical assistance resources to ensure community members understand the complexities of the school siting process. One commenter noted that providing advice and recommendations on how members of the public can access scientific, technical and legal resources will help to facilitate a meaningful public involvement process.

RESPONSE:
EPA recognizes the importance of the commenters’ emphasis on the need for technical assistance and training on a variety of topics, both for members of the SSC and the community, to enable effective participation by a wide range of stakeholders. The final guidelines address these comments in the following ways. Text has been added to the guidelines to consider the importance of effective technical assistance and training during the school siting process. While it is beyond the scope of these guidelines to provide specific training or to develop core competency standards for SSC members, additional technical assistance and training resources intended to enhance the skills of the SSC and community members have been included in the Resource page (e.g., Technical Assistance and Capacity Building).

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ISSUE: Distance-based siting criteria (e.g., "buffer zones" or "desirable distances").
Commenters were concerned that the guidelines did not provide information on where schools should not be built to avoid toxic exposures from contaminated sites and major sources of air pollution. These commenters requested that EPA include two distance-based siting criteria screens such as those recommended by the Children’s Health Protection Advisory Committee (CHPAC):

  • A wide screening perimeter to identify potential environmental hazards within a large radius of a candidate school location (which is included in the guidelines); and
  • A narrow screening perimeter for exclusion/buffer zones that define a desirable distance between proposed school locations and environmental hazards (which is not included in the guidelines).

Commenters suggested that a second level of siting criteria can provide local governments with useful information early in the school site selection process, which could save time and money and could ensure that the public is fully informed of the potential hazards of a location. These commenters suggested that if a prospective location were located closer than the desirable distance it should not be considered as a candidate location for a school. However, if no other location was identified, then the school siting committee could go back to the site within the desirable distance and conduct a more thorough evaluation of the location and assess whether the benefits of the location outweigh the risks.

These commenters suggested that at such an early stage in the process, it is impractical to ask the local school district to spend substantial sums of money to determine safe distances from sources on a case- and site-specific basis.

Alternatively, multiple commenters suggested that EPA not include exclusion/buffer zones as part of the guidance. Some commenters noted that important sources of environmental contamination impact entire communities as well as individual school facilities, and such sources should be addressed in a community wide context. Other commenters argued that distance-based buffer zones could push schools to locations that may still pose health and safety risks and not address other community concerns.

RESPONSE:
EPA’s approach to the school siting 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. Addressing significant pollutions sources is important not only from the standpoint of locating new schools, but also from the broader perspective of the health of the entire community.

EPA recognizes the potential usefulness of including a simple metric such as an exclusion/buffer zone as part of the siting criteria and seriously considered whether such a metric could reasonably be applied to school siting decisions. However, EPA did not include this element in the final guidelines for several reasons. Some state 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 additional state and local regulations and guidance are available on the Resources page.

First, the complex relationship between a school location, a contaminant source and children and staff exposures to pollutants cannot be evaluated through a simple distance indicator such as a buffer/exclusion zone. 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 a 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. Several of these factors are listed and detailed in the following bullets, using near-roadway exposures as an example:

  • Source emissions/traffic activity - The number of vehicles on a road, the mix of vehicles on the road (e.g., cars, trucks) and the manner in which these vehicles are driven can all affect the amount and characteristics of pollutant emissions. This includes the roadway type such as highway, arterial road, etc.
  • Meteorology - Wind speed, wind direction, temperature and humidity can also affect how pollutants are transported away from the road and to the school location. Pollutant concentrations tend to be highest downwind of a road, so sites located predominantly upwind of the road may experience lower pollutant exposures. However, parallel and calm winds can also lead to higher exposures.
  • Roadway design - The physical location and characteristics of the road relative to the school location can also influence pollutant transport and dispersion. Sites at the same level as the roadway, with no obstructions to air flow, will likely experience the highest pollutant concentrations. Locations near roadways in cut sections, where the road surface is below the grade of the surrounding terrain, can experience lower pollutant concentrations as a result of increased dilution and mixing of the traffic emissions.
  • Roadside features - The presence of barriers between a school location and the roadway can also influence pollutant concentrations. Sound walls, vegetation and buildings have all been shown to increase dilution and mixing of traffic emissions, typically leading to lower pollutant concentrations beyond the obstruction.
  • Number of roads near the location - Many roads in the vicinity of a school location, even if farther away, may present a larger impact to the location rather than one roadway much closer to the location.

Because of the complexity of factors impacting a school location, the science supporting distance-specific safe distances between sources and school locations is limited. Using the roadway example, there is no consensus on the amount of traffic on a nearby road (or roads) that poses a health risk, or alternatively, a traffic volume that does not pose a risk. A “safe” distance is also uncertain given the likely variability of emissions and pollutant concentrations that will be experienced at any distance from the road. Thus, an absolute exclusion criterion across all potential school locations in the nation is not feasible for inclusion in the guidelines.

Establishing distance-based restrictions for a school location could have a wide range of unintended consequences. The following are several of these potential adverse outcomes associated with exclusion/buffer zones, again using the roadway example:

  • Excluding near-roadway locations may increase local and regional air pollution and increase safety risks by requiring students to travel longer distances to attend school. This approach would require more travel by personal vehicles and/or school bus, increasing student exposures during the commute and drop off/pick up at school.
  • The limited availability of school locations within neighborhoods, especially in denser, urban areas, could force a school district to eliminate all locations near the populations they are intended to serve, which would restrict the siting of schools accessible by biking or walking from the neighborhoods being served. The benefits of active transport to school may far outweigh concerns related to nearby potential sources of pollutants.
  • Siting schools in greenfields, farther from the populations they serve, may increase traffic on local roads, encourage sprawl development and increase local and regional air quality impacts due to the increased traffic activity as a consequence of this type of development.

EPA agrees with those commenters that argued that screening out the most problematic locations early in the process is desirable from a cost, health and efficiency perspective and agrees that during the initial screening step, potential locations that may pose cleanup or other environmental challenges should be avoided if other suitable locations with fewer challenges exist. The final guidelines include distance-based screening recommendations in the Environmental Siting Criteria Considerations section of the guidelines under Exhibit 6: Screening Potential Environmental, Public Health and Safety Hazards. The screening perimeter distance represents the approximate distance from a prospective school location within which the LEA, an environmental professional and the school siting committee should, during the initial screening process of candidate locations, identify all potential hazards and determine those that need further evaluation.

The final guidelines also include additional discussion about the use of screening perimeters and emphasize that the potential environmental challenges of a particular location should be considered at the very earliest stages of identifying candidate locations.

During this initial screening phase, it is reasonable and prudent for potentially significant sources closest to the candidate location to be given early consideration and weighed against the challenges of other potential candidate locations. In general, the closer a major source is to a school, the more important it is to gain an early understanding of the potential ramifications of that proximity.

The guidelines also urge communities to focus on mitigating potential exposures from nearby sources where proximity to nearby sources cannot be avoided due to the absence of other suitable locations.

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ISSUE: Complexity of evaluating nearby sources of air pollution using modeling and risk assessment, and the need for simpler approaches for avoiding significant sources.
Several commenters noted that the guidance on evaluating nearby sources of air pollution describes a complex process that relies heavily on modeling and risk assessment to determine whether nearby sources of air pollution pose unacceptable risks at prospective school locations. These commenters recommended that EPA reframe this section to acknowledge the difficulty and expense of air pollution modeling and provide guidance on how LEAs can evaluate offsite air pollution impacts without having to conduct a “full blown” air quality monitoring and analysis study for every candidate location.

RESPONSE:
EPA recommends that an environmental professional conduct the evaluation of nearby sources of air pollution. The final guidelines discuss the steps for an initial screening assessment of area air quality. If the initial assessment of air quality identifies issues that require further study, the guidelines suggest that the LEA can consider the use of additional, more site-specific analyses if they wish to continue evaluation of the location for a school. The final guidelines website also includes links to Resources on Air Pollution and Technical Assistance, and the following examples are included in the Evaluating Impacts of Nearby Sources of Air Pollution section.

EPA’s Initiative Assessing Outdoor Air Near Schools: In 2009, EPA embarked on an initiative to understand whether outdoor toxic air pollution poses health concerns to school children. This initiative, Assessing Outdoor Air Near Schools, is instructive about some of the types of school air monitoring efforts that have been performed and provides useful examples of assessing outdoor air near schools.

Community Scale Air Toxics Ambient Monitoring (CSATAM) Projects: Since 2003/2004, EPA has conducted periodic Community-Scale Air Toxics Ambient Monitoring grant competitions to support state, local and tribal communities in identifying and profiling air toxics sources, characterizing the degree and extent of local air toxics problems and tracking progress of air toxics reduction activities. The CSATAM website has grant information, final project reports and a training module, How to Create a Successful Air Toxics Monitoring Project.

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ISSUE: Safety and security criteria and information on emergency planning should be included throughout the guidelines.
Commenters argued that emergency planning should be included throughout the document. One commenter expressed concern that the draft guidelines did not address the impact of a school siting decision on local emergency planning.

RESPONSE:
EPA recognizes the need to factor school locations and the needs of students and staff in local emergency planning. We have added “emergency planners and responders” as recommended participants in the school siting committee. In addition, a section on considering the use of a school as an emergency shelter is included in the Environmental Siting Criteria Considerations section, and links to resources related to emergency planning are provided in the Resources page. Safety is incorporated in Exhibit 4: Desirable Attributes of Candidate Locations and Exhibit 5: Factors Influencing Exposures and Potential Risks, and safety is also emphasized in the Safe Routes to School discussion.

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ISSUE: Consistency in discussion of cleanup standards.
Some commenters noted that the draft guidelines' discussion of the appropriate cleanup standard for remediating sites with onsite contamination was inconsistent in different sections of the guidelines.

RESPONSE:
The guidelines have been revised to further clarify that schools can be safely located on property where residual contamination remains on site only if steps are taken to ensure that no exposure to contamination occurs. If feasible, sites should be cleaned up to standards for residential use. In cases where cleanup to such standards is not feasible, exposures can be prevented through the use of engineering controls and/or institutional controls, provided a plan to ensure long-term stewardship of the engineering controls and institutional controls is in place. The use of engineering controls and institutional controls is effective, but only if the systems to maintain and enforce them are in place, including periodic monitoring to ensure their continued protectiveness and safe operation. Nationwide, brownfields, including those with residual contamination on site, now safely support housing, schools, clinics, hospitals and other reuses that meet community needs.

The guidelines also note that, currently, many states and tribes establish their own cleanup levels based on state or tribal laws and regulations, or they perform site-specific risk assessments to determine appropriate cleanup levels. The guidelines recommend that, in the absence of state, tribal or local standards developed specifically for schools, school sites be cleaned up to a residential use cleanup standard. The guidelines also recommend that, if cleanups are going to leave residual contamination on a school location that require implementation of engineering and institutional controls, an objective evaluation of the school district's capacity to effectively maintain those controls over time be conducted before the site cleanup plan is approved by state or tribal regulatory agencies. In the event that the support to effectively and reliably manage any institutional and engineering controls is not ensured, the location should either be cleaned to residential use levels or another location should be used.

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ISSUE: Financial and cost information and considerations.
A number of commenters requested that EPA provide more specific cost information or tools to estimate costs for a variety of topics, including transportation, disposal of hazardous materials from demolishing an old school, remediation technologies and engineering controls.

RESPONSE:
EPA agrees with the commenters that costs will be an important factor in any school siting decision. During the siting process, the LEA will consider costs related to comparing desirable attributes of candidate sites, performing the assessments recommended in these guidelines and acquiring the site or structure. Some of these cost considerations include: cost of land and location preparation, short- and long-term construction or renovation costs, transportation costs for students and staff, and cost estimates for mitigating or reducing environmental risks and long-term stewardship of remediation measures. In a set of national guidelines, it is not feasible to provide specific cost information on the various aspects of the siting process; however, throughout the guidelines, general cost/financial considerations are mentioned.

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ISSUE: Comments that were outside the scope of the guidelines.
A number of comments addressed issues that were outside of the scope of the School Siting Guidelines. Examples of these issues include site layout and orientation with regard to daylight and air flow, the most desirable physical size of school buildings and the proximity of schools to fast food restaurants.

RESPONSE:
These are all important issues for communities to consider in the context of the development of school facilities. However, they are outside of the scope of the School Siting Guidelines and are not addressed in this document. A number of resources addressing these important issues can be found on EPA's Healthy Schools, Healthy Kids site.

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