RE: [CPEO-BIF] Report on the 2006 EJ/Community Caucus

["peter " <petestrauss1@comcast.net>]

Lenny:

Thanks for the interesting reports.  May I suggest that the Draft Position
Paper include a reference to manufactured gas plant (MGP) sites.
Manufactured gas, or Town Gas sites, were introduced in the US in the
mid-1850s and were used to produce gas for lights, heating and cooking.
They were originally coal retorts, sort of coal gasification plants.  They
produced thousands of tons of waste, which were normally buried on-site.
These wastes contained carcinogenic coal tars and a host of PAHs.  At the
time when natural gas pipelines were introduced in the 1950s, there had been
over 2,000 sites built in the US.  Many of these were owned by utilities,
which are either no longer operating, or were predecessors to larger modern
gas and electric utilities.  As these utilities evolved, many gave away or
sold their MGP sites to local governments.  When I did a lot of research on
these sites in the mid-1990's, many had been used for parks, public housing
and schools. In many cases, if the ownership in the MGP sites could be
traced to an existing utility, they shared some responsibility for
remediation. (I became involved because I had clients who were state
sponsored ratepayer advocates who did not like the idea of utilities passing
on the costs of remediation to ratepayers.)

Peter

PM Strauss & Associates
415-647-4404


-----Original Message-----
From: brownfields-bounces@list.cpeo.org
[mailto:brownfields-bounces@list.cpeo.org] On Behalf Of Lenny Siegel
Sent: Thursday, November 16, 2006 11:49 AM
To: Brownfields Internet Forum
Subject: [CPEO-BIF] Report on the 2006 EJ/Community Caucus

Report on the November 12, 2006 Meeting of the
National Brownfields Environmental Justice/Community Caucus
By Lenny Siegel, CPEO


On Sunday night (November 12, 2006) the National Brownfields 
Environmental Justice/Community Caucus convened for tenth straight year. 
About 65 people, including community activists, academics, and EPA 
personnel gathered in room 205BC of the Boston Convention and Exhibition 
Center. Following introductions and announcements, David Lloyd, Director 
of the U.S. EPA Office of Brownfields Cleanup and Redevelopment, spoke 
briefly, introducing himself and welcoming caucus participants to the 
conference.

The balance of the meeting was devoted to open discussion of "Homes, 
Schools, and Parks," a draft position paper prepared by the Center for 
Public Environmental Oversight, which facilitates the Caucus. Developed 
from discussions at a regional workshop in Worcester, Massachusetts in 
September, the paper attempts to answer the question: "Where, when, and 
how is it appropriate to locate housing, schools or day care facilities, 
and recreational uses on contaminated properties?" The draft document 
may be downloaded as a Microsoft Word file from 
http://www.cpeo.org/pubs/Homes-Schools-Parks.doc.

"Homes, Schools, and Parks" notes, "Communities continue to see public 
uses, such as affordable housing, schools and day care, and parks or 
other open space as desirable outcomes for brownfield properties." Yet, 
largely because these are the sites where children are potentially 
exposed to environmental contamination, such uses trigger health 
concerns not generally in the forefront at industrial and commercial 
redevelopments.

At the Caucus, CPEO sought feedback to specific recommendations in the 
draft paper, such as "Landfills are generally unsuitable locations for 
the construction of homes and schools." Caucus participants asked 
whether such a finding applied to all dump sites equally, but more 
important, they reiterated what participants in previous years' Caucus 
sessions had argued: Public health is best protected at brownfields 
projects by early, frequent community involvement in land use and design 
decisions. In fact, many Caucus member statements reinforced the ten 
"Recommendations for Responsive Brownfields Revitalization," developed 
by a previous Caucus in 1999. That document may be viewed at 
http://www.cpeo.org/pubs/reccom.html.

The draft document lays out three contamination scenarios - landfills, 
potential vapor intrusion sites, and properties with residual soil 
contamination - each of which might call for different redevelopment 
guidelines. Caucus participants appeared to agree that in each instance 
that the thoroughness of long-term management, including the operation 
and maintenance of remedies, as well as monitoring and institutional 
controls, is central to the suitability of placing sensitive uses on all 
three examples of contaminated property.

Some participants suggested that if the true costs of adequate long-term 
management were considered at the time environmental responses were 
chosen, more treatment and removal would take place. Others warned that 
it is difficult for cities and school districts to fund long-term 
stewardship activities, particularly for uses - such as parks - that do 
not directly generate revenue. However, another Caucus member responded 
that parks can generate revenue, by increasing the value - and thus the 
taxation potential - of surrounding property. That value should generate 
revenue to ensure that the parks are indeed safe for public use.

One EPA participant warned that it may be shortsighted to consider only 
toxic contamination when evaluating the health impact of development. 
Parks enhance both the physical and emotional health of the communities 
in which they are located. She and other caucus participants urged a 
holistic, area-wide approach to Brownfields redevelopment.

In summary, participants in the 2006 EJ/Community Caucus were hesitant 
to endorse the findings and recommendations in "Homes, Schools, and 
Parks," a paper that most of them were reading for the first time. They 
did not necessarily disagree with the specific positions highlighted by 
CPEO. Rather, they felt that the general principles, such as those 
elucidated by the Caucus in 1999, were central to successful, safe 
Brownfields revitalization.



A version of this report appeared in the November 15, 2006 edtion of the 
"2006 National Brownfields Conference Brownfields Bulletin" (page 7).

For a formatted version (with photo), go to 
http://www.cpeo.org/pubs/Caucus06.doc.

-- 


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
<lsiegel@cpeo.org>
http://www.cpeo.org


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