2008 CPEO Brownfields List Archive

From: LSchnapf@aol.com
Date: Sat, 21 Jun 2008 12:08:51 -0700 (PDT)
Reply: cpeo-brownfields
Subject: [CPEO-BIF] NY Controllers Report
This report has some significant inaccuracies.
First, when reporting on the results of other state brownfield programs, it conflates the state voluntary cleanup program with the state brownfield program. For example, it states that the NJ brownfield program has addressed 23,000 sites. I believe that the number refers to the overall number of sites in the MOA or voluntary cleanup program. I think the actual number of sites that have been completed in the NJ brownfield program where up to 75% of cleanups are reimbursed is actually closer to 113 sites that has paid out approximately $500MM over a ten year period.
Comparing the number of NY BCP sites to those cleaned up under the VCP is misleading as a basis to suggest that the incentives do not lead to more cleanups. The VCP was open to any party who wanted to enroll whereas the BCP has the most stringent eligibility criteria in the country. There are lots of sites and applicants that would have sought admission into the BCP that were either (1) strongly discouraged from applying or (2) denied admission.
I had explained the inaccuracy of the information to the Controller's staff and am disappointed that they persisted in publishing this misleading information. It suggests to me that the report was not intended as an objective analysis but may have been issued to advance a specific agenda.
Lawrence Schnapf
Adjunct Professor-New York Law School
55 E.87th Street #8B/8C
New York, NY 10128
212-876-3189 (h)
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