From: | "Joe Schilling" <jms33@vt.edu> |
Date: | 2 Jul 2007 18:58:23 -0000 |
Reply: | cpeo-brownfields |
Subject: | RE: [CPEO-BIF] Re: Brownfields Digest, Vol 34, Issue 25 |
Peter of course makes a very compelling case for keeping BFs incentives "pure." He also offers many good points about making sure that BFs incentives should go towards properties that really need them in order to return these properties back into commerce. My perspective is probably a bit more futuristic. I start from the perspective that BFs redevelopment, somewhat by accident, perhaps by design, has probably become this country's e most successful community revitalization policy in the last forty years. And it is somewhat ironic that it happened at EPA as opposed to HUD or the typical revitalization policy silo. Given that it is unlikely anytime soon for the federal government to create a holistic and comprehensive community revitalization initiative is there a way we can build on the success of BFs redevelopment and tweak a few BFs policies here and there so that it can accomplish more area-wide revitalization. So, yes, I'm advocating a policy direction that would create "spill" over benefits from these BFs policies/projects so that a community could, if it wants, leverage, apply, use certain BFs incentives to redevelop true BFs AND adjacent/nearby vacant and abandoned properties (not functionally obsolescent) and thereby accomplish significant community revitalization goals instead of an isolated BFs project here and there. Such an area wide approach could also address the properties where the redevelopment market is non existent, perhaps transforming the properties into green infrastructure? However, I recognize there are certain dangers of such a direction. Some may contend that it's politically risky to extend BFs programs beyond their intended scope--obviously, I'm not advocating doing so without proper legislative reforms--that a backlash like eminent domain could arise. As Michigan illustrates, even if you make the legislative changes to encompass a broader definition of BFs you need to back that up with the funding and capacity to implement. My point is we should consider how to leverage the benefits of existing BFs incentives and policies to serve as the catalyst for community-scale revitalization. JMS -----Original Message----- From: brownfields-bounces@list.cpeo.org [mailto:brownfields-bounces@list.cpeo.org] On Behalf Of Peter B Meyer Sent: Monday, July 02, 2007 7:40 AM To: brownfields@list.cpeo.org Subject: [CPEO-BIF] Re: Brownfields Digest, Vol 34, Issue 25 I'm going to jump in on the Michigan issue since it relates to the whole issue of targeting subsidies, a topic of a great deal of interest to me. There are a lot of economic and social issues facing depressed cities and communities in addition to contamination, including abandonment and underutilization. Such settings generally need outside help if they are to regenerate. This is a fact that I doubt is controversial. There also are brownfields in real estate markets that are so hot that there is little, if any, need to provide any public support (other than regulatory clarity and consistency) to get them remediated and reused. The New York state brownfields program has been criticized for wasting money on such settings, and is undergoing some revisions, for that and other reasons (as has been evidenced in earlier postings to this liostserv). It is not clear to me whether or not the Michigan program has similar failings, though I suspect it is comparably flawed. What IS clear from earlier listserv postings is that (a) the state fund is virtually depleted, (b) it was spent in part (wasted) on grants that probably should have been loans (Evans Paull's last comment) -- and might even have been wasted in settings in which no support was needed to overcome non-contamination barriers to incentives, and (c) the case that started this discussion involved "functionally obsolete" student housing -- for which there was demand, since the students are still ther and it is just being replaced, and which was not clearly abandoned nor in a depressed real estate market. The specific student housing case in Mount Pleasant, in fact, does not appear to qualify for support on either Evans' or Joe Schilling's criteria for aid; it also was not a site with contamination problems, at least not as described. But the key question is whether BROWNFIELD funds should be used for abandoned or underutilized properties that do not have a contamination problem. Given the legal constraints under which EPA operates, federal funds should not be used for such projects -- and there is a risk to any state that wastes its brownfield monies on such projects that the funds involved include some federally-funded state records keeping or other program management support under the 2002 Act's funding to states, if not direct transfers of federal subsidy dollars. (I do not discount the possibility that, despite the language of the 2002 Brownfields Act, many of the applications for grants are actually for projects of the type that Joe and Evans would approve ... and I suspect that some have been so well pitched as brownfields in need that they have gotten funds when the key site problems were not environmental, despite the best proposal review efforts of the Office of Brownfields Cleanup and Redevelopment.) Like it or not, the funds for what I would characterize as neighborhood or urban regeneration are stovepiped legislatively to different functions. Monies appropriated in a stovepipe designated for any one function (such as dealing with brownfields) that get spent on other problems (such as functional obsolescence of buildings, infrastructure or the like) deplete the dollars available for the function for which they were appropriated. Larry Schnapf's desciption of the Petoskey Pointe project in Michigan underscores this argument. The developer will, apparently, end up with $4.5 million in tax credits, plus $450,000 for remediation cost reimbursement. The project will produce 115 jobs, it is true, but the subsidy for each of those jobs will be in excess of $43,000. The subsidy may or may not be needed to "create" those jobs -- and, of course, the claimed "new" jobs may simply be relocating from elsewhere. However, the real issue is what cleanups of dangerous sites with heavy contamination problems the $4.5 million in tax credits could have supported and will not continue to expose people and ecosystems until job creation funds are diverted to brownfields. I would advise anyone hoping for such an unlikely event not to hold his or her breath -- especially since the brownfield tax credits in Michigan, as is the case with brownfield funds in many other states, are allocated to projects by the Michigan Economic Development Corporation. That's Economic, not Environmental development ... The "novel definition" in Michigan thus tends to deprive true brownfield properties with real or perceived contamination of what we all know to be very limited funding. Given this conclusion, I wonder if Joe and Evans might want to reconsider their support for it. I know I do not want to see brownfield funds diverted in this manner. Peter Peter B. Meyer Professor Emeritus of Urban Policy and Economics Director, Center for Environmental Policy & Management University of Louisville WEB: <http://cepm.louisville.edu> - - - - - Director of Applied Research Center for Public Leadership and Public Affairs Northern Kentucky University - - - - - - 3205 Huntersridge Lane Taylor Mill, KY 41015 502-45-3240 (cell) _______________________________________________ Brownfields mailing list Brownfields@list.cpeo.org http://www.cpeo.org/mailman/listinfo/brownfields _______________________________________________ Brownfields mailing list Brownfields@list.cpeo.org http://www.cpeo.org/mailman/listinfo/brownfields |
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