2008 CPEO Brownfields List Archive

From: "Peter B. Meyer" <pbmeye02@louisville.edu>
Date: Fri, 4 Jul 2008 17:26:17 -0700 (PDT)
Reply: cpeo-brownfields
Subject: Re: [CPEO-BIF] Scope of Brownfield Program-continued
If I may enter this discussion between two learned practitioners I know fairly well ... it appears that what we have here a reflection of  the classic problem of the US focus on SITES, while the rest of the world addresses AREAS.

Larry is discussing whether a particular site, and a particular (private) developer deserves a subsidy from state funds that are designated for addressing contamination issues when there exist other state and national funds, in separate pots, accessed differently, that may help address dereliction and abandonment or the general need for attracting capital to an impoverished area.

Paul is providing the rationale for investing in the area, with the presumption that, if the non-contamination issues that contribute to the failure to driving capital away from that are addressed, then the funds will be available to mitigate and reuse the contaminated site.

As a general proposition, of course it is appropriate to use public funds to turn around otherwise depressed areas and attempt to attract private capital. However, subsidizing individual parcels within those areas is a different question.  As Larry would have it, and I am inclined to agree with him on this, funds designated for environmental responses should not be used for other redevelopment purposes.

However, Paul does have a point: if attracting investment to one site that is not polluted leads to a change in perception of an area or neighborhood and makes it more attractive to investors. At lease hypothetically, such a transformational investment might raise the market value of nearby brownfields to a level that they could then attract capital without further subsidy. In this case, it might be justifiable to use brownfield monies for a project that does not directly involve remediating contamination.

Granting the possibility that Paul's vision suggests, however, does not mean that it makes sense to use funds that are designated for contamination mitigation for the purpose. Such a use of  brownfield funds would be justified in my view if two standards were met:
    (1) there were not other funds for economic development or renewal that could have been used for the uncontaminated site - or the funds available were insufficient, and,
    (2) there was evidence on the basis of past patterns of investment and/or specific declarations and commitments from developers, that the redevelopment of the uncontaminated site would lead to their investing in the brownfield with no further (or substantially reduced) subsidy.
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