I have to respectfully disagree with my friend from the other side of the
pond.
If the problem with a site is the underlying social-economic conditions,
shouldn't the problem be the focus of the public tools specially designed for
economic development. Brownfield programs are intended to address the sites
where the environmental issues are contributing to the under-utilization or
development.
We have been having quite a debate in NY on the proper scope of the
brownfield program. Upstate NY has lots of under-utilized sites that no amount
of brownfield incentives could fix because it is the regional economy and not
the contamination that is the obstacle for redevelopment. we have the most
generous brownfield program in the country and it has not been enough of an
incentive upstate because it does not change the underlying economic
conditions.
CERCLA type legislation is not the answer either since we have had lots of
sites cleaned up in NY but the sites remain un-used because the regional economy
does not support an economically-viable reuse.
If a state brownfield program has limited funds, why should it be used to
renovate an obsolete building when there is another redevelopment tool
available. The limited state brownfield funding should be reserved for those
sites where the contamination is the reason the site is not being redeveloped.
Larry
Lawrence
Schnapf
Adjunct Professor-New York Law School
55 E.87th Street
#8B/8C
New York, NY 10128
212-876-3189 (h)
212-756-2205
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212-593-5955 (f)
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www.environmental-law.net