RE: FW: [CPEO-BIF] Subsidies

["Trilling, Barry" <BTrilling@wiggin.com>]

Lenny:  Like Peter, you appear to take for granted that the historical
precedence of "claw backs" did not inhibit further development. These
are not, as you characterize them, "new impediments," but vestiges of
retrograde policy. Rather, policy should encourage responsible
development with minimal post-subsidy restraints within the realm of
that which is ethically acceptable and politically achievable.
Protection against irresponsible subsidies should begin with a diligent
screening process of both the developer and the project and the setting
of criteria for an award that meet appropriate goals.  Once through that
process, if a project fails to meet its goals then the screening process
or the criteria should be adjusted. This not mean we should ignore fraud
and blatant mismanagement, which should always be open for review and
remedy. The ability to take back what was promised short of the
recipient's fraud and mismanagement, however, does not recognize the
realities of a competitive market where even responsible developers
will, all other things being equal, take the path of least resistance;
of equal importance, "claw backs" provide short shrift to brownfields
development.  Barry

-----Original Message-----
From: brownfields-bounces@list.cpeo.org
[mailto:brownfields-bounces@list.cpeo.org] On Behalf Of Lenny Siegel
Sent: Thursday, October 26, 2006 5:44 PM
To: Brownfields Internet Forum
Subject: Re: FW: [CPEO-BIF] Subsidies


I like Peter's "clawback" proposal.

Unlike some of the private sector representatives on the list, I don't 
see such conditions as the imposition of new impediments to development.

Development has always been supported by a wide range of "carrots" and 
limited by a wide range of "sticks." Many of those are taken for granted

because they have been in state and federal tax code for a long time. 
Peter's proposal would refocus such carrots and sticks, not introduce 
them for the first time.

Lenny

-- 
Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
http://www.cpeo.org

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