2008 CPEO Brownfields List Archive

From: Lenny Siegel <lennysiegel@gmail.com>
Date: Sat, 21 Jun 2008 12:40:01 -0700 (PDT)
Reply: cpeo-brownfields
Subject: Re: [CPEO-BIF] NY Controllers Report
Setting aside for the moment the question of the fairness of the comparisons in the New York Comptroller's report on Brownfields, I'd like to hear what our readers think about the efficiency of New York's brownfields tax credits.

From a distance, it has been my impression that some of the credits have supported high-rise developments in New York City, where cleanup is a small fraction of overall costs, and thus environmental remediation accounts for a small portion of the tax credits.

Does the coverage of development costs, not just cleanup, weaken the aim of the credits? Have enough projects been supported for the amount of taxes not collected? Is the distribution of credits equitable by size and type of developer, or by geography?


LSchnapf@aol.com wrote:
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. Larry Lawrence Schnapf
Adjunct Professor-New York Law School
55 E.87th Street #8B/8C
New York, NY 10128
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Lenny Siegel
Executive Director, Center for Public Environmental Oversight
a project of the Pacific Studies Center
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Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918

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