[CPEO-BIF] Questions and concerns?

[rgfp@mail.utexas.edu]

 Thought I might stimulate some discussion given recent federal
 reauthorization of brownfield funding.  Simply put, in the opinion of
the
 list serve members, what are some of the important concerns or
outstanding
 questions that we have on brownfield redevelopment as it is currently
 practiced in the U.S.?  This may lead to some new threads of discussion
or
 reinvigorate some old ones.  I always want to look at the cup as half
empty
 AND half full.  So on the half empty end of the continuum, my list of
issues
 includes:

 1. Is there really enough quality control in VCP programs?  The recent
episode in Texas with an Environmental Lab getting in trouble for
falsification of
lab tests raises the issue of the fox guarding the chicken coup?  Are
liability concerns on the part of prospective purchasers/consultants
etc.,
really enough to ensure that field sampling strategies and testing is
really
done well and appropriately?  For that matter, what is really being done
to
objectively field verify what is reported as a remediated condition?  It

seems to me that the lure of profits could lead to corruption/collusion
scenarios that downplay or misrepresent actual contamination/remediation

conditions (e,.g., strategic sampling to miss hot spots that carry high
remediation costs but that otherwise have a low probability of injury or

exposure from the prospective purchasers perspective). No insult
intended to
environmental professionals/consulting firms, but this is not an
improbable
scenario in my estimation.

2. Do we have enough confidence in our understanding of public health
and
safety risks to be operating under RBCA as we currently are?  It seems
for
 many substances with toxic impacts, our knowledge base is largely
limited to
 "acute -- high dose exposure" data as opposed to "chronic -- low dose
 exposure" as we might find in a brownfield setting.  I have two small
 children and my concern over what we don't know is increasingly
 troublesome--which side should we err on as a society and have we
really
 debated this openly and adequately to date (at least from a brownfields

 perspective).

 3. Does the public really have adequate say in redevelopment decisions
or is it possible that the priorities of environmental protection and
tax
 base/economic development squelch social justice voices and choices?

 4. Are we comfortable with the long-term sustainability of
institutional
 controls as they are currently applied, and if not, should we still be
using
 them until we address our concerns?

 That should stir things up a bit.....please add your own issues to the
list.
 Look forward to the ensuing discussions.

 Cheers,

 Bob Paterson
 University of Texas at Austin



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