Re: [CPEO-BIF] Re: Brownfields Digest, Vol 35, Issue 13

[Lenny Siegel <lennysiegel@gmail.com>]

Bob Paterson's comparison of risk assessment and cost-benefit analysis 
in his second paragraph is intriguing.

In most cases, people - community members or workers - who believe they 
have been victimized by toxic exposure face a nearly impossible burden 
of proof to win compensation, while developers seeking subsidies usually 
enjoy the benefit of the doubt: A successful development is generally 
considered good for the public.

Lenny


 Robert Paterson wrote:
> Peter could probably speak better to the metrics question, although 
> there is some controversy about how some of those numbers are derived. 
> For example, if a brownfield site is reclaimed and a new commercial 
> facility is created, is that new growth or just redistributed growth as 
> merchants move from one part of town to another with newer buildings and 
> amenities and market draw potential?  Vacancy rates go up elsewhere….so 
> getting a clean clear answer is not always as straight forward as one 
> would wish.
>
>  
>
> A full B/C analysis is time consuming and often a contested exercise 
> because like risk assessment, if you torture the numbers enough (or 
> shift assumptions or estimation methods) you can get them to say 
> anything you want…That’s not to say you cant first get agreement on 
> reasonable assumption and estimation methods and then say the numbers 
> are reasonable in light of the agreed upon approach--by both sides of 
> the issue) (this is a form of data mediation or joint fact finding).
>
>  
>
> In the end, the issue that is not stated as clearly as it should be is 
> really one of “opportunity costs”…all else being equal, is this the best 
> use of foregone revenues from tax abatements in cases when the level of 
> contamination is minor and liability issues are truly negligible (and 
> the open question remains, whether without subsidies, the market will 
> eventually pick up and reuse the site) – can state agencies do a better 
> job of steering resources where they are going to provide the greatest 
> net societal benefits, and perhaps have higher expectations for local 
> benefits as a quid pro quo for abatements or other subsidies?  Perhaps 
> the number of sites that would have developed anyway with or without 
> abatements and tax credits is small, but since we don’t seem to look 
> real close, it seems like the opportunities for abuse are significant 
> and real.  And given limited tax dollars and resources, waste is not an 
> option. There may well be better places to spend for net societal 
> benefits that exceed our current approach…such as more attention to 
> brownfield prevention efforts? Or whatever….
>
>  
>
> Empowerment and enterprise zones (federal and state varieties) tried to 
> ensure that employment gains would accrue to impacted areas with highest 
> unemployment and ideally be part of an overall economic redevelopment 
> program that is responsive to impacted neighborhoods and the overall 
> community needs.
>
>  
>
> Are we asking too much and how much should we be asking of subsidies 
> given to stimulate private sector brownfield action?
>
>  
>
> I’m curious what happened in DC where a small group of folks on this 
> list met and discussed this- I was abroad and could not attend.
>
>  
>
>  If someone can send a summary off-line – that would be greatly appreciated.
>
>  
>
> Kind regards
>
>  
>
> Bob
>
>  
>
> Robert G. Paterson
>
> Associate Professor
>
> Co-Director, Center for Sustainable Development
>
> 1 University Station B7500
>
> School of Architecture
>
> The University of Texas
>
> Austin TX 78712-1160
>
> 512-471-0734
>
> Fax 512-471-0716
>
> rgfp@mail.utexas.edu
>
>  
>
>  
>
> Whatever befalls the earth
>
> Befalls the sons and daughters
>
> Of the earth.
>
> We did not weave the web of life;
>
> We are merely a strand in it.
>
> Whatever we do to the web.
>
> We do it to ourselves… 
>
>  -Chief Seattle (1788-1866)
>
> Native American (Suquamish leader)
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> ------------------------------------------------------------------------
>
> From: brownfields-bounces@list.cpeo.org 
> [mailto:brownfields-bounces@list.cpeo.org] On Behalf Of LSchnapf@aol.com
> Sent: Wednesday, July 18, 2007 11:25 PM
> To: brownfields@list.cpeo.org
> Subject: [CPEO-BIF] Re: Brownfields Digest, Vol 35, Issue 13
>
>  
>
> As a followup to Ken Kamlet's letter to the editor, the statistics 
> publicized by the article fail to mention the benefits from the 
> brownfield program. There is no estimation of the jobs created or taxes 
> generated by the BCP projects.
>
>  
>
> The data only presents one side of the story..and several of the 
> attorneys I know who were queried as part of the study by the 
> Environmental Business Association brownfield task force that I chair 
> indicate that the estimates produced by the Division of Budget are 
> inaccurate for a number of sites by either overestimating the tax 
> credits or underestimating the cleanup costs. As one attorney told me, 
> if the state numbers are right about the tax credit his client got, then 
> he did not bill his client enough in legal fees. )
>
>  
>
> I would like to know if there are metrics that are used by government or 
> academics that predict the number of jobs and taxes generated by 
> redevelopment projects. This information is missing from the data 
> generated by the state and thus does not tell the whole picture about BCP.
>
>  
>
> Larry  
>
>  
>
> Lawrence P. Schnapf, Esq.
> 55 E.87th Street #8B
> New York, NY 10128
> 212-756-2205 (office)
> 212-876-3189 (home office)
> 203-263-5212 (weekends)
> 212-593-5955 (fax)
> LSchnapf@environmental-law.net
> www.environmental-law.net <http://www.environmental-law.net/> (website)
>
>
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--


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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