> From: MAUREEN BRENNAN <MBRENNEN@baker-hostetler.com>
> Subject: Response to Mr. Peter Gillon's Introduction
>
> Dear Mr. Gillon: I would be interested in obtaining the name and
> address of your trade association for Brownfields Developers. Is
> your group planning on commenting on the language that U.S. EPA has
> proposed for Memoranda of Understanding between U.S. EPA and states
> on the role of U.S. EPA in state Brownfields cleanups?
>
> U.S. EPA has published a great deal in the press about how vigorously
> it supports Brownfields redevelopment but the actual reform of its
> processes has not kept pace with its rhetoric. Does your group
> support the independent Brownfields bills that have been introduced
> or would it prefer to see Brownfields addressed as part of Superfund
> reform? Maureen Brennan, Baker & Hostetler
----------
Peter Gillon's response to Maureen Brennan
---------
Date: Thu, 09 Oct 1997 18:50:10 -0500
From: Peter Gillon (Wash) <gillonp@gtlaw.com>
The group uniformly hates the EPA proposal on voluntary cleanups as a
step backwards on the progress being made on a state-by-state and
site-by-site basis. The proposal would require EPA approval on each
agreement. We have not commented formally to date.
Also, as to Superfund reform, we do not see much in any reform
proposal that would encourage private development. The key reforms
we are advocating are:
1) improve the SEC reporting and FASB accounting rules to provide
more accurate reporting of contingent environmental liabilities.
2) permit prospective purchasers to inspect and evaluate contaminated
properties without obligation to report their findings to state or federal
agencies if the transaction does not proceed.